20060314Petition to intervene.pdf

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Peter J. Richardson
ISB No. 3195
Richardson & O'Leary
515 N. 27th Street
O. Box 7218
Boise, Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
peter(illrichardsonando I eary com
Attorneys for the Industrial Customers of Idaho Power
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
OF FINANCIAL DISINCENTIVES TO
INVESTMENT IN ENERGY EFFICIENCY BY)IDAHO POWER COMPANY
CASE NO. IPC-04-
PETITION TO INTERVENE
COMES NOW, The Industrial Customers ofIdaho Power, hereinafter referred to as
Intervenor " and pursuant to that NOTICE OF APPLICATION filed on March 6 2006 and this
Commission s Rules of Procedure, Rule 71 IDAPA 31.01.01.71 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 of this Intervenor is:
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson & O'Leary
515 N. 2ih St
O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
Copies of all pleadings, production requests, production
responses, Commission orders and other documents should be
provided to Peter 1. Richardson as noted above and to:
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreading(illmindspring. com
This Intervenor, the Industrial Customers of Idaho Power
, ("
ICIP") is an
unincorporated association of Schedule 19 customers of Idaho Power. All ICIP members receive
electric utility services from Idaho Power Company. The ICIP claims a direct and substantial
interest in this proceeding in that the appropriate methodology for setting rates for service from
Idaho Power Company may be affected by the outcome of this proceeding. Although this
proceeding only directly affects the residential and commercial classes, its stated purpose is to
evaluate a "new mechanism" for setting rates, including someday, possibly, the industrial class.
This Intervenor, in its capacity as a representative of industrial customers 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.
Without the opportunity to intervene herein, this Intervenor would be without any
means of participation in this proceeding which may have a material impact on the methodology
this Commission uses to set electric rates.
Intervention - IPC-O4-
Granting this Intervenor s petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
WHEREFORE the Industrial Customers of Idaho Power respectfully 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 14th day of March 2006.
Richardson & O'Leary, PLLC
By
Peter J. Richardson
Industrial Customers of Idaho Power
Intervention - IPC-O4- I 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of March 2006, a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER, was sent via U.S Postal Service, postage prepaid, to the following parties:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
llewell(illpuc.state.id. us
( ) U.S. Mail, Postage Prepaid
(X) Hand Delivered
( )
Overnight Mail
( ) Facsimile
( ) Electronic Mail
Barton Kline
Monica Moen
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( ) Facsimile
( ) Electronic Mail
John R. Gale
Vice President Regulatory Affairs
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
(X) u.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( ) Electronic Mail
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Nina M. Curtis
Intervention - IPC-O4-