20060201Petition to Intervene.pdf

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Peter Richardson
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O. Box 7218 Boise, 1D 83707 - 515 N. 27th Sr. Boise, 1D 83702
31 January 2006
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
Boise ID 83720-0074
RE: Case NoJPC-O5-
Dear Ms. Jewell:
Enclosed please find an original and seven (7) copies of the PETITION TO
INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER in the
above case
I have also enclosed an extra copy to be service-dated and returned to us for
our files. Thank you.
Sincerely,
~\hs
Nina Curtis
Administrative Assistant
encl.
Peter J. Richardson
ISB No. 3195
Richardson & O'Leary
515 N. 2ih Street
O. Box 7218
Boise, Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
peter~richardsonandoleary .com
Attorneys for the Industrial Customers of Idaho Power
Idaho PU~jjc LJlJJlCles Commission
OffIce of the SecretaryRECEIVED
JAN 3 1 2006
Boise, Idaho
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATIONOF APPROPRIATE RATE MAKING TREATMENT OF IDAHO POWER
COMPANY'S SO2ALLOWANCE SALE PROCEEDS
CASE NO. IPC-05-
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 that Notice of Application and Notice of Intervention Deadline
issued on January 12 , 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 J. Richardson as noted above and to:
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreading(illminds pring. com
This Intervenor, the Industrial Customers ofIdaho 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 their rates for service from Idaho Power Company may be
affected by the outcome of this proceeding.
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 its electric rates
and terms and conditions of service.
Granting this Intervenor s petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
Intervention - IPC-26-
WHEREFORE the Industrial Customers ofIdaho 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 31st day of January 2006.
Richardson & O'Leary, LLP
By 6M);!~
Peter J. R chardson
Industrial Customers of Idaho Power
Intervention - IPC-26-
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 31 st day of January 2006, a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER, was served by U.S. Mail, postage prepaid, to:
Barton Kline
Monica Moen
Idaho Power Company
PO Box 70
Boise, Idaho 80707-0070
John R. Gale
Vice President Regulatory Affairs
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
Nina Curtis
Administrative Assistant
Intervention - IPC-26-
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 31 st day of January, 2006, I caused a true and
correct copy of the foregoing PETITION TO INTERVENE OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER to be served by the method indicated below, and
addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
( ) U.S. Mail, Postage Prepaid
(X) Hand Delivered
( ) Overnight Mail
( )
Facsimile
( ) Electronic Mail
Barton L. Kline
Idaho Power Company
PO Box 70
Boise, Idaho 83707
( ) u.S. Mail, Postage Prepaid
(X) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( ) Electronic Mail
Signed: \'(\ CuA
Nina M. Curtis
CERTIFICATE OF SERVICE - 1