20031014Industrial Customers Petition to Intervene.pdf

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]
RECEIVED mFILED
ZOllnCT 14 1"5:51
IDAHO PUBLIC
UTILITIES COMMISSION
Attorney for Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN MATTER OF THE APPLICA nON OF THE)IDAHO POWER COMPANY FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE RATBASING OF)THE BENNETT MOUNTAIN POWER PLANT.
CASE NO. IPC-03-
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers ofIdaho Power, hereinafter referred to as
Intervenor " and pursuant to this Commission s Rule of Practice and Procedure, Rule 071
IDAPA 31.10.01074, and pursuant to that Notice of Intervenor Deadline, Notice of Pre hearing
Conference in Order No. 29354, issued on October 8, 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:
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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 J. 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 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.
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
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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 ofIdaho 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 !Iris I '3 of October, 2003.
Richardson & O'Leary, PLLC
By 1? fi) Peter J. Richardson
Attorneys for the Industrial Customers
of Idaho Power
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the day of October, 2003 , a true and correct copy of
the within and foregoing PETITION TO INTERVENE OF 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
Lisa Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise, Idaho 83702
~(\\CUJ\~,
Nina M. Curtis
Legal Assistant
Certificate of Service - IPC- E-O3-