20030611ICIP Petition to Intervene.pdf

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Peter Richardso n
Tel: [phone] Fax: [phone]
pererfl!!richardso nandolea ry.com
O. Box 1849 99 East Srare Streer, Eagle, Idaho 83616
June 10 , 2003
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
Boise ID 83720-0074
RE: Case No.IPC-03-
Dear Ms. Jewell:
Enclosed please find an original and seven (7) copies of the Petition to
Intervene of the Industrial Customers of Idaho Power (ICIP) in the above-designated
case.
I have also enclosed an extra copy to be service-dated and returned to us for
our files.
Sincerely,
~~
O;J\ en s
Nina CurtiS
Administrative Assistant
Peter J. Richardson
ISB No. 3195
Richardson & O'Leary
99 East State Street, Suite 200
O. Box 1849
Eagle, Idaho 83616
Telephone: [phone]
Fax: [phone]
Attorney for Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN MATTER OF THE APPLICATION OF THE)
IDAHO POWER COMPANY TO REVISE ITS
DEPRECIATION RATES FOR PLANT IN SERVICE. CASE NO. IPC-03-
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
Intervenor " and pursuant to this Commission s Rule of Practice and Procedure, Rule 071
IDAP A 31.10.01074, and pursuant to that Notice ofIntervenor Deadline, Notice of Pre hearing
Conference in Order No. 29253 , issued on June 3rd, 2003 , 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-O3- 7
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
O. Box 1849
Eagle, Idaho 83616
Telephone: [phone]
Fax: [phone]
This Intervenor will be represented herein by:
Peter J. Richardson, Esq.
Richardson & O'Leary
99 East State Street, Suite 200
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 1. Richardson as noted above, and to Don
Reading at Ben Johnson Associates, 6070 Hill Road, Boise, Idaho, 83703.
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 ofIdaho 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.
This Intervenor, in its capacity as a representative of industrial consumer
interests, 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
IPIC Intervention - IPC-O3- 7
quality of evidence which this Intervenor will introduce is dependent upon the nature and effect
of other evidence in this proceeding.
Although not required by this Commission s Rule, the multiple representation 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 examine witnesses, present
argument and to otherwise fully participate in these proceedings.
DATED this day of June, 2003.
Richardson & O'Leary, PLLC
By 4J~Peter J. Richardson
Attorneys for the Industrial Customers
of Idaho Power
IPIC Intervention - IPC-O3- 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 11'11.--day of June, 2003 , a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER, Case No. IPC-03-, was served by u.s. Mail, postage prepaid, to:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Gregory W. Said
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Eric L. Olsen
Racine Olson Nye et al
O. Box 1391
Pocatello, Idaho 83204-1391
Lisa Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise, Idaho 83702
(Hand Delivered)
0AN C() (im \Ii )
Nina M. Curtis
Legal Assistant
IPIC Intervention - IPC-O3- 7