20031030Petition 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]
l~ECEIVED illFiLED
lOB3 OCT 30 At; IO~ Zlt
iU/\r;u i LIC
UTILiTIES COfYiMISSION
Attorney for Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN MA ITER OF THE APPLICATION OF THE)
IDAHO PO~R COMPANY FOR
AUTHORITY TO INCREASE ITS INTERIM
AND BASE RATES AND CHARGES FORELECTRIC SERVICE
CASE NO. IPC-03-
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO PO~R
COMES NOW, The Industrial Customers ofIdaho Power, hereinafter referred to
Intervenor " and pursuant to this Commission s Rule of Practice and Procedure, Rule 071
IDAP A 31.10.01074, and pursuant to that Notice of Application, Notice of Intervention
Deadline, Notice of Oral Argument and Notice of Pre hearing Conference in Order No. 29369
issued on October 28, 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-E-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]
Email: peter~richardsonandolearv.com
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]
Email: peter(Q)J"ichardsonandolearv.com
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83703
Telephone: [phone]
Fax: [phone]
Email: dreading(Q)mindspring. com
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter J. Richardson and Don Reading as noted above.
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
IPIC Intervention - IPC-E-O3- 7
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
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.
;tY-
DATED thi Jo/day of October, 2003.
Richardson & O'Leary, PLLC
By (j)f)k~Peter J. RicHardson
Attorneys for the Industrial Customers
of Idaho Power
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on th day of October, 2003 , a true and correct copy of
the within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS
OF IDAHO PO~R 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
~(YJ. CuJ\\hs
Nina M. Curtis
Legal Assistant
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