20031104Petition to Interevene.pdf

LAWRENCE A. GOLLOMP
United States Department of Energy
1000 Independence Avenue SW
Washington, D.c. 20585
Telephone:[phone]
E-mail: lawrence.gollomp(0hq.doe.gov
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS
INTERIM AND BASE RATES AND
CHARGES FOR ELECTRIC SERVICE.
CASE NO. IPC-03-
PETITION OF THE UNITED STATES
DEPARTMENT OF ENERGY
FOR LEAVE TO INTERVENE
COMES NOW the United States Department of Energy ("DOE" or "Petitioner ) on
behalf of its Idaho Operations Office and on behalf of other Federal Executive Agencies, all of
whom are customers of Idaho Power Company ("IPC"), and by and through counsel, respectfully
requests the Idaho Public Utilities Commission ("Commission ) to grant this Petition for Leave
to Intervene in the above-captioned proceeding. In support thereof, DOE states:
DOE has been delegated authority by the General Services Administration ("GSA"
pursuant to Section 201 (a)(4) of the Federal Property and Administration Services Act of 1949
PETITION TO INTERVENE
UNITED STATES DEPARTMENT
OF ENERGY
as amended (40 U.A. Sec. 481 (a)(4)), to represent the customer interests of the Executive
Agencies of the United States Government in this proceeding.
II.
The following persons are designated to receive service in this matter:
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Avenue, SW
Washington, D.C. 20585
Telephone: [phone]
Lawrence. Gollomp~hq .doe. gov
Dale Swan
Exeter Associates, Inc.
5565 Sterret Place
Suite 310
Columbia, MD. 21044
[phone]
Dswan(0exeterassoci oates. com
III.
On October 16, 3003 , IPC filed an Application with the Commission for authority to
increase the Company s general rates and charges for electric service in the State ofldaho by
$85 561 910 annually. The Company s filing also included a request tor $20 million in interim
rate relief in the event the Commission suspended IPC's proposed rates and charges.
PETITION TO INTERVENE
UNITED STATES DEPARTMENT
OF ENERGY
IV..
The proposed tariffs will affect the rates which DOE and the other Federal executive
Agencies currently pay for electricity from IPc. Procurement of electricity from IPC by DOE
and other Federal Executive Agencies is made entirely from public funds. Therefore, DOE and
the other Federal Executive Agencies have a direct and substantial interest in this proceeding
which would not be represented by other parties in this proceeding.
IV.
DOE seeks the right to participate fully in this proceeding, including the right to present
expert witnesses and cross-examine witnesses, to take part in oral argument and file briefs, and
to request such relief as may be determined necessary to protect the interests of DOE and
the other Federal Executive Agencies.
F or the purposes of the above-captioned proceeding, I have designated as local counsel
and an active member of the Idaho State Bar, Dennis A. Love, (Bar No. 3402) P.O. 1625. Idaho
Falls, Idaho, 83415-3899 (208-526 8765).
PETITION TO INTERVENE
UNITED STATES DEPARTMENT\
OF ENERGY
WHEREFORE DOE respectfully requests the Commission to grant this Petition for
Leave to Intervene in the above-captioned proceeding.
Dated this 3rd day of November, 2003
~~d O~ O
Law ence A. Go omp
Assistant General Counsel
United States Department of Energy
PETITION TO INTERVENE
UNITED STATES DEPARTMENT
OF ENERGY
CERTIFICATE OF SERVICE
CASE NO. IPC-O3-
I hereby certify that I have this 3rd day of November, 2003, served or caused to be served a
true and correct copy of the attached PETITION OF THE UNITED STATES DEPARTMENT
OF ENERGY FOR LEAVE TO INTERVENE upon on each of the parties listed below by
placing the same in the u.S. Mail, postage prepaid or by Federal Express.
BY FEDERAL EXPRESS
Barton L. Kline, Esq.
Monica Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707
208-388-2682
John R. Gale
Vice President Regulatory Affairs
Idaho Power Company
PO BOX 70
Boise, Idaho 83707
208-388-2867
Lisa Nordstrom, Esq.
Commission Counsel
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
206-334-0314
L~ rence
Assistant General Counsel
United States Department of Energy
PETITION TO INTERVENE
UNITED STATES DEPARTMENT
OF ENERGY