20250218Petition to Intervene.pdf

RECEIVED
Tuesday, February 18, 2025
IDAHO PUBLIC
I Peter J. Richardson ISB # 3195 UTILITIES COMMISSION
2 Gregory M. Adams ISB # 7454
515 N. 27th Street
3 Boise, Idaho 83702
[phone] DD
4 [phone] Cell
peter i richardsonadains.com
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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9 IN THE MATTER OF IDAHO POWER Case No.: IPC-E-24-46
COMPANY'S APPLICATION FOR
to APPROVAL OF A POWER PURCHASE
AGREEMENT WITH JAKALOPE WIND, PETITION TO INTERVENE OF THE
t l LLC, AND A CERTIFICATE OF PUBLIC
INDUSTRIAL CUSTOMERS OF IDAHO
12 CONVENIENCE AND NECESSITY FOR POWER
THE JAKALOPE WIND PROJECT
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15 COMES NOW, The INDUSTRIAL CUSTOMERS OF IDAHO POWER, hereinafter
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:
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20 1. The name and address of this Intervenor is:
21 Industrial Customers of Idaho Power
22 c/o Peter J. Richardson
Richardson Adams, PLLC
23 515 N. 27`h St
Boise, Idaho 83702
24 Telephone: [phone]
25 Fax: [phone]
peter a,richardsonanadams.com
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PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
28 IPC-E-24-46
PAGE 1

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2 Copies of all pleadings, production requests, production responses, Commission orders
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and other documents should be provided to Peter J. Richardson as noted above and to:
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5 Dr. Don Reading
6 280 S. Silverwood Way
Eagle, Idaho 83716
7 [phone]
8 dreading,L&mindspring com
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10 2. This Intervenor, the Industrial Customers of Idaho Power is an unincorporated
I I association of Schedule 19 (large power schedule) customers of Idaho Power Company, all of
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whom receive electric utility services from Idaho Power Company. This Intervenor claims a
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direct and substantial interest in this proceeding in that its rates for electric service from Idaho
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15 Power Company will be affected by the outcome of this proceeding.
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3. This Intervenor intends to participate herein as a party, and if necessary, to
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18 introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in
19 argument. The nature and quality of evidence which this Intervenor will introduce is dependent
20 upon the nature and effect of other evidence in this proceeding.
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22 4. Without the opportunity to intervene herein, this Intervenor would be without any
23 means of participation in this proceeding which may have a material impact on its electric and
24 natural gas rates and the terms and conditions of such service.
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26 5. Granting this Intervenor's petition to intervene will not unduly broaden the issues
27 nor will it prejudice any party to this case.
PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
28 IPC-E-24-46
PAGE 2

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2 WHEREFORE, the Industrial Customers of Idaho Power respectfully requests that this
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Commission grant its Petition to Intervene in these proceedings and to appear and participate in
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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.
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Richardson Adams, PLLC
8 Attorneys for the Industrial
9 Customers of Idaho Power
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Dated this 171h day of February 2025.
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13 I3y: Peter J. I ichardson ISB # 3195
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PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
28 IPC-E-24-46
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I HEREBY CERTIFY that on the 171h 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
s_ecretary&a puc.idaho.gov Boise, Idaho 83702
7 ttatum(aidahopower.com
8 dwalker0lidahaDower.com
dockets idahovower.com
9 Monica Barrios-Sanches
Commission Secretary
10 Idaho Public Utilities Commission
monica.bariossanchesCd
I uc.idaho.gov
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14 X4"
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By: Peter J. Richardson ISB # 3195
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PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
28 IPC-E-24-46
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