20240610Petition to Intervene.pdf

RECEIVED
Monday, June 10, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Peter J. Richardson
ISB No. 3195
Richardson Adams, PLLC
515 N. 27"' Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
[e-mail]
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY TO INCREASE ) CASE NO. IPC-E-24-07
RATES FOR ELECTRIC SERVICE TO )
RECOVER COSTS ASSOCIATED WITH ) PETITION TO INTERVENE
INCREMENTAL CAPITAL INVESTMENTS ) OF THE INDUSTRIAL CUSTOMERS
AND CERTAIN ONGOING OPERATIONS ) OF IDAHO POWER
AND MAINTENANCE EXPENSES. )
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"Intervenor" or the "ICIP" and pursuant to the Rules of Procedure, Rule 71 IDAPA 31.01.01.71
of the Idaho Public Utilities Commission ("Commission") and hereby petitions the Commission
for leave to intervene herein and to appear and participate herein as a party. In support of said
Petition to Intervene the [CIP says as follows:
I
INTRODUCTION — BACKGROUND
Idaho Power Company ("Idaho Power" or the "Power Company") initiated this docket on
May 31, 2024, for the purpose revising its retail rates in Idaho via an increase in annual revenue
in the amount of$99,293,220 or approximately a 7.3% overall rate increase.

II.
PETITION TO INTERVENE
The name and address of this Intervenor is:
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27" St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(a,richardsonadams.com
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter Richardson as noted above and to:
Dr. Don Reading
280 S. Silverwood Way
Eagle, Idaho 83616
[phone] Tel
[phone] Fax
[e-mail]
This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an unincorporated
association of Schedule 19 customers of Idaho Power. All ICIP members receive electric utility
services from Idaho Power Company. The ICIP claims a direct and substantial interest in this
proceeding in that it will have an ultimate impact on the retail rates the industrial customers pay
the Power Company for their electric service.
This Intervenor, in its capacity as a representative of industrial customers intends to
participate herein as a party, and if necessary, to introduce evidence, cross-examine witnesses,
call and examine witnesses, and be heard in argument. The nature and quality of evidence which
this Intervenor will introduce is dependent upon the nature and effect of other evidence in this
proceeding.
ICIP Intervention 2
—IPC-E-24-07

Without the opportunity to intervene herein, this Intervenor would be without any means
of participation in this proceeding which may have a material impact on the retail electric rates
paid by the industrial class of customers to the Power Company.
Granting this Intervenor's petition to intervene will not unduly broaden the issues nor
will it prejudice any party to this case.
WHEREFORE, the Industrial Customers of Idaho Power respectfully requests that this
Commission grant its Petition to Intervene in these proceedings and to appear and participate in
all matters as may be necessary and appropriate; and to present evidence, call and examine
witnesses, present argument and to otherwise fully participate in these proceedings.
DATED this 1 Oth day of June 2024.
S
Peter J. Richa Edson
RICHARDSON ADAMS, PLLC
ICIP Intervention 3
—I PC-F.-24-07

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of June 2024, a true and correct copy of the within
and foregoing PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER in Docket No. IPC-E-24-07 was served electronically to:
Lisa Nordstrom Commission Secretary
Donovan E. Walker Idaho Public Utilities Commission
Megan Goicoechea Allen secretary�a,nuc.idaho.gov
Regulatory Dockets
Idaho Power Company Monica Barrios-Sanchez
PO Box 70 Commission Secretary
Boise, Idaho 83707 monica.barriossanchez(@puc.idaho.gov
[e-mail]
idahopower.com
[e-mail]
dwalkeerAidahopower.com
mj,,[e-mail]
Eric L. Olsen Lance Kaufman, Ph.D.
Idaho Irrigation Pumpers Association Idaho Irrigation Pumpers Association
ECHO HAWK& OLSEN, PLLC 2623 NW Bluebell Place
505 Pershing Ave., Ste. 100 Corvallis, OR 97330
P.O. Box 6119 lanceLyae Tis�insi ht.com
Pocatello, Idaho 83205
elo(a-)echohawk.com
Timothy Tatum
Connie Aschenbrenner
Matt Larking
Idaho Power Company
[e-mail]
[e-mail]
mlarkina,idahopower.com
Peter Richardson
RICHARDSON ADAMS, PLLC
ICIP Intervention 4
—IPC-E-2a-07