20250218Petition to Intervene.pdf

RECEIVED
Tuesday, February 18, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
I Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
2 515 N. 271" Street
3 Boise, Idaho 83702
[phone] DD
4 [phone] Cell
5 peter(a-_)richardsonadams.com
6
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
8
9 IN THE MATTER OF IDAHO POWER Case No.: IPC-E-24-45
COMPANY'S APPLICATION FOR A
to CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR TWO BATTERY PETITION TO INTERVENE OF THE
I I STORAGE FACILITIES
INDUSTRIAL CUSTOMERS OF IDAHO
12 POWER
13
14
COMES NOW, The INDUSTRIAL CUSTOMERS OF IDAHO POWER, hereinafter
15
16 referred to as "Intervenor," and pursuant to this Commission's Rules of Procedure, Rule 71
17 IDAPA 31.01.01.71 hereby petitions the Commission for leave to intervene herein and to appear
18 and participate herein as a party, and as grounds therefore states as follows:
19
20 1. The name and address of this Intervenor is:
21 Industrial Customers of Idaho Power
c/o Peter J. Richardson
22 Richardson Adams, PLLC
23 515 N. 27" St
Boise, Idaho 83702
24 Telephone: [phone]
Fax: [phone]
25 [e-mail]
26
27
PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
28 IPC-E-24-45
PAGE 1

I Copies of all pleadings, production requests, production responses, Commission orders
2 and other documents should be provided to Peter J. Richardson as noted above and to:
3
4 Dr. Don Reading
280 S. Silverwood Way
5 Eagle, Idaho 83716
6 [phone]
dread ingta mindsprin
7
8
9 2. This Intervenor, the Industrial Customers of Idaho Power is an unincorporated
10 association of Schedule 19 (large power schedule) customers of Idaho Power Company all of
I I whom receive electric utility services from Idaho Power Company. This Intervenor claims a
12
direct and substantial interest in this proceeding in that its rates for electric service from Idaho
13
Power Company will be affected by the outcome of this proceeding.
14
15 3. This Intervenor intends to participate herein as a party, and if necessary, to
16
introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in
17
18 argument. The nature and quality of evidence which this Intervenor will introduce is dependent
19 upon the nature and effect of other evidence in this proceeding.
20
21 4. Without the opportunity to intervene herein, this Intervenor would be without any
22 means of participation in this proceeding which may have a material impact on its electric and
23 natural gas rates and the terms and conditions of such service.
24
25 5. Granting this Intervenor's petition to intervene will not unduly broaden the issues
26 nor will it prejudice any party to this case.
27
PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
28 1PC-E-24-45
PAGE

1
2 WHEREFORE, the Industrial Customers of Idaho Power respectfully requests that this
3
Commission grant its Petition to Intervene in these proceedings and to appear and participate in
4
5 all matters as may be necessary and appropriate; and to present evidence, call and examine
6 witnesses, present argument and to otherwise fully participate in these proceedings.
7
Richardson Adams, PLLC
8 Attorneys for the Industrial
9 Customers of Idaho Power
10
11 Dated this 171h day of February 2025.
12
13 y: Peter FICichardson ISB # 3195
14
15
16
17
18
19
20
21
22
23
24
25
26
27
PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
28 IPC-E-24-45
PAGE 3

1
I HEREBY CERTIFY that on the 17th day of February 2025, a true and correct copy of the
2 within and foregoing PETITION TO INTERVENE of the Industrial Customers of Idaho Power
3 was served, pursuant to Commission Order No. 34602, by electronic copy only, to:
4 Commission Secretary Tim Tatum
Idaho Public Utilities Commission Donovan E. Walker
5 PO Box 83720 Idaho Power Company
6 Boise, ID 83720-0074 1221 West Idaho Street
secr�l(4yuc.idaho.gov Boise, Idaho 83702
7 ttatum&idahopower.com
8 dwalkerQaidahopower.com
dockets idaho_powcr.com
9 Monica Barrios-Sanches
Commission Secretary
10 Idaho Public Utilities Commission
I monica.bariossanches puc.idaho.gov_
12
13
14
15 /
By: Peter J. Richardson ISB # 3195
16
17
18
19
20
21
22
23
24
25
26
27
PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
28 IPC-E-24-45
PAGE 4