20031017Irrigation Pumpers Petition to Intervene.pdf

Randall C. Budge, ISB No. 1949
Eric L. Olsen, ISB No. 4811
RACINE, OLSON, NYE, BUDGE &
BAlLEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
f1ECEIYED
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1033 OCT I 7 PH 12: 31
iLii\!,U (UBLiCUTILITIES COMMISSION
Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE RATEBASING OF
THE BENNETT MOUNTAIN POWER PLANT
Case No. IPC-O3-
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION. INC..
FOR LEAVE TO INTERVENE
COMES NOW Idaho Irrigation Pumpers Association, Inc., herein called "this Intervenor
and pursuant to Rule 72 of the rules of Procedure ofthe Idaho Public Utility Commission, and by
this Petition asks leave to intervene herein and to appear and participate as a party herein, and as
basis therefor states as follows:
(1)The name and address of this Intervenor is:
Idaho Irrigation Pumpers Association, Inc.
c/o Lynn Tominaga
O. Box 2624
Boise, Idaho 83701-2624
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INe.
FOR LEAVE TO INTERVENE - 1
This Intervenor will be represented by:
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Chartered
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
and requests that copies of all pleadings and production requests and responses should be provided
to the following:
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Chartered
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
E-mail: rcb~racinelaw.net
E-mail: elo~racinelaw.net
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
Fax: [phone]
E-mail: yankel~attbi.com
(2)This Intervenor and its members have a direct and substantial interest in this
proceeding and intend to participate in all respects herein as a party as may be required to represent
its interests.
(3)Without the opportunity to intervene herein, this Intervenor would be without a
mamler or means of participating in the lawful determination of issues which will result in affecting
its rates for electric service.
WHEREFORE, this Intervenorrequests that this Commission confirm this Intervenor s leave
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, cross-examine witnesses, present
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FOR LEAVE TO INTERVENE - 2
argument, and to otherwise fully participate in the proceedings.
DATED this 17th day of October, 2003.
RACINE, OLSON, NYE, BUDGE &
BAlLEY, CHAR TE
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 17th day of October, 2003, I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
E-mail: jjewell~puc.state.id.Hand Delivery
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
bkline~idahopower.com
mmoen~idahopower.com Hand Delivery
John P. Prescott
Vice President, Power Supply
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
j prescott~idahopower. com
ERIC L. OLSEN
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INe.
FOR LEAVE TO INTERVENE - 3