The URL can be used to link to this page

Home My WebLink About20031110Petition to Intervene.pdfORIGINAL Dean J. Miller (ISB No. 1968) McDEVITT & MILLER LLP 420 West Bannock Street O. Box 2564-83701 Boise, Idaho 83702 Tel: 208.343.7500 Fax: 208.336.6912 RECEIVED 0 FILED ZnO3 NOV II PM 3: 2 I IDA!'iO PUbliC UTILITIES COM~1ISSION Attorneys for United Water Idaho Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF THE IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS INTERIM AND BASE RATES AND CHARGES FOR ELECTRIC SERVICE Case No. IPC,O3, PETITION TO INTERVENE COMES NOW United Water Idaho Inc. (United Water), and pursuant to this Commission s Rule of Practice and Procedure, Rule 071 , IDAPA 31.10.01074, and pursuant to that Notice of Application, Notice ofIntervention 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: The name and address ofthis Intervenor is: United Water Idaho Inc. O. Box 190420 Boise, Idaho 83719-0420 Tel: 362-7337 Fax: 362- 7069 Email: ierry.healy~unitedwater.com PETITION TO INTERVENE- This Intervenor will be represented herein by: Dean 1. Miller McDEVITT & MILLER LLP O. Box 2564 Boise, Idaho 83701 Tel: 343- 7500 Fax: 336-6912 Email: ioe~mcdevitt-miller.com and Jeremiah J. Healy UNITED WATER IDAHO INC. O. Box 190420 Boise, Idaho 83719-0420Tel: 362- 7337 Fax: 362- 7069 Email: ierry.healy~unitedwater.com Copies of all pleadings, production requests, production responses, Commission Orders and other documents should be provided to Dean Miller and Jeremiah Healy as noted above. United Water is a corporation authorized to do business in the state ofIdaho. It provides potable water service, under rates established by the Commission, to approximately 74 000 customers, all within Idaho Power s service area. In order to operate its electric motors for supply, boosting and distribution purposes, United Water purchases significant quantities of electric power, primarily under Idaho Power s Tariff Schedule 9 Large General Service and Primary Service. For the most recent calendar year ending December 31 , 2002 United Water spent over $1.8 million on energy purchases from Idaho Power, utilizing 35 million kwh at 124 separate electric service points of delivery. Accordingly, United Water has a direct and substantial interest in this proceeding. United Water 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 PETITION TO INTERVENE- nature and quality of evidence which United Water will introduce is dependent upon the nature and effect of other evidence in this proceeding. WHEREFORE United Water requests 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 10th day of November, 2003. McDEVITT & MILLER LLP ~tL Dean J. Miller Attorneys for United Water Idaho Inc. PETITION TO INTERVENE- CERTIFICATE OF SERVICE I hereby certify that on the 10th day of November, 2003, a true and correct copy of the foregoing Petition to Intervene was served, by the methode s) indicated below, upon the following: Peter J. Richardson RICHARDSON &: O'LEARY 99 East State Street O. Box 1849 Eagle, Idaho 83616 Fax: 208-938-7904 Hand Delivered S. Mail Fax Fed. Express Barton L. Kline Monica B. Moen IDAHO POWER COMPANY 1221 West Idaho Street O. Box 70 Boise, Idaho 83707 Fax: 388-6936 Hand Delivered S. Mail Fax Fed. Express Gregory W. Said IDAHO POWER COMPANY 1221 West Idaho Street O. Box 70 Boise, Idaho 83707 Fax: 388-6936 Hand Delivered S. Mail Fax Fed. Express Lisa Nordstrom Deputy Attorney General IDAHO PUBLIC UTILITIES COMMISSION 472 W. Washington Street O. Box 83720 Boise, Idaho 83720-0074 Fax: 334-3762 Hand Delivered S. Mail Fax Fed. Express Randall C. Budge Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY 201 East Center Street O. Box 1391 Pocatello, Idaho 83204-1391 Fax: 232-6109 Hand Delivered S. Mail Fax Fed. Express Anthony Yanke! 29814 Lake Road Bay Village, Ohio 44140 Fax: 440-808~14S0 Hand Delivered S. Mail Fax Fed. Express PETITION TO INTERVENE-4 !6' 1-= 12( i6" Q"'" Lawrence A. Gollomp Assistant General Counsel UNITED STATES DEPARTMENT OF ENERGY 1000 Independence Avenue, SW Washington, D.c. 20585 Fax: Dale Swan EXETER ASSOCIATES, INc. 5565 Sterret Place, Suite 310 Columbia, Maryland 21044 Fax: ffJh-~~~ 'l PETITION TO INTERVENE- Hand Delivered S. Mail Fax Fed. Express Hand Delivered S. Mail Fax Fed. Express p('