20020403ICIP Petition to Intervene.pdf

RICHARDSON &O'LIMInf
ATTORNEYS AT LAW
Tel:[phone] Fax:[phone]
P.O.Box 1849 99 East State Street,Eagle,Idaho 3 16
April 1,2002
Ms.Jean J.Jewell,Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise ID 83720-0074
RE:Case Nos.IPC-E-02-2/IPC-E-02-3
Dear Ms.Jewell:
Enclosed please find an original and seven (7)copies of the Industrial Customers of
Idaho Power's Petition to Intervene in the above-named cases.
Also enclosed is an extra copy of the petition.Will you please have it date-stamped and
return it to us for our files,in the self-addressed,stamped envelope provided.
Thank you for your consideration.
Sincerely,
Myrna J.Walters
Legal Assistant
M)w
Enclosures
Peter J.Richardson,ISB #3195
Richardson &O'Leary
99 East State Street,Suite 200
P.O.Box 1849 04
Eagle,Idaho 83616
Telephone:[phone]
Fax:[phone]
[e-mail]
Attorneyfor Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)IDAHO POWER COMPANY FOR AN )CASE NO.IPC-E-02-02ENERGYCOSTFINANCINGORDERAND)AUTHORITY TO INSTITUTE AN ENERGY )PETITION TO INTERVENECOSTBONDCHARGE)OF THE INDUSTRIAL CUSTOMERS)OF IDAHO POWER
IN THE MATTER OF THE APPLICATION OF)IDAHO POWER COMPANY FOR )CASE NO.IPC-E-02-03AUTHORITYTOIMPLEMENTAPOWER)COST ADJUSTMENT (PCA)RATE FOR )PETITION TO INTERVENEELECTRICSERVICEFROMMAY16,2002 )OF THE INDUSTRIAL CUSTOMERSTHROUGHMAY15,2003.)OF IDAHO POWER
COMES NOW,The Industrial Customers of Idaho Power,hereinafter referred to as
"Intervenor,"and pursuant to the Notice of Application/Notice of Intervention Deadline/Notice
in these matters issued by the Commission Secretary on March 27,2002,and pursuant to this
Commission's Rule of Procedure,Rule 071,IDAPA 31.10.01074,and hereby petitions the
Commission for leave to intervene herein and to appear and participate herein as a party,and as
grounds therefore states as follows:
IPIC Intervention -IPC-E-02-02;IPC-E-02-03
1.The name and address of this Intervenor is:
Industrial Customers of Idaho Power
c/o Peter J.Richardson
Richardson &O'Leary
99 East State Street,Suite 200
P.O.Box 1849
Eagle,Idaho 83616
Telephone:[phone]
Fax:[phone]
This Intervenor will be represented herein by:
Peter J.Richardson
RICHARDSON &O'LEARY,PLLC
99 East State Street,Suite 200
P.O.Box 1849
Eagle,Idaho 83616
Telephone:[phone]
Fax:[phone]
Copies of all pleadings,production requests,production responses,Commission orders
and other documents should be provided to Peter J.Richardson as noted above.
2.This Intervenor,the Industrial Customers of Idaho Power,is an unincorporated
association of large industrial consumers of electricity.All of the members of the Industrial
Customers of Idaho Power receive electric utility services from the Applicant under Tariff
Schedule 19.These industrial consumers claim a direct and substantial interest in this
proceeding in that their rates for service from Idaho Power may be affected by the outcome of
this proceeding.
3.This Intervenor,in its capacity as a representative of industrial consumer's
interests,intends to participate herein as a party,and if necessary,to introduce evidence,cross-
Intervention -IPC-E-01-42 2
examine witnesses,call and examine witnesses,and be heard in argument.The nature and
qualityof evidence which this Intervenor will introduce is dependent upon the nature and effect
of other evidence in this proceeding.
5.Without the opportunity to intervene herein,this Intervenor would be without and
means of participation in this proceedingto determine the appropriateness of the 2002 PCA rate
and whether an Energy Cost Financing Bond should be implemented,and this Intervenor would
be unable to participate in proceedings which may have a material impact on its electric rates.
6.Althoughnot required by this Commission's Rule,the multiplerepresentation by
this Intervenor of its members'interests will prevent duplication of effort and aid in the
administration of these proceedings.
WHEREFORE,the Industrial Customers of Idaho Power request 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 examinewitnesses,present
argument and to otherwise fullyparticipate in these proceedings.
DATED this lst day of April,2002.
Richardson &O'Leary,LLP
By
Peter J.Richardson
Attorneyfor the Industrial Customers
of Idaho Power
Intervention -IPC-E-01-42 3
CERTIFICATE OF SERVICE
I HEREBY CERTlFY that on the 1"'day of April,2002,a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER,Case Nos.IPC-E-02-02 and IPC-E-02-03,was served by U.S.Mail,postage
prepaid,to:
Larry Ripley
John R.Gale
Idaho Power Company
P.O.Box 70
Boise,Idaho 83707-070
Myrna'J.WaltdËs
Legal Assistant
Intervention -IPC-E-01-42 4