20051206Petition to intervene.pdf

Department of Energy
Washington, DC 20585
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VIA FEDERAL EXPRESS ! r i L! 'I E S ~Ni;;!dE S 10 1J
December 5, 2005
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
Re: Case No. IPC-OS-
Dear Ms. Jewell:
Please find enclosed for filing in the above-captioned docket an original and seven
(7) copies of the Petition of the United States Department of Energy for Leave to Intervene. An
additional copy is enclosed, which we ask be date stamped for our records, and returned to our
office in the enclosed postage-paid, self-addressed envelope.
Thank you for your assistance inn this matter.
Lawrence A. Gollo
Assistant General Counsel
United States Department of Energy
Enclosure:
PETITION OF THE UNITED STATES
DEPARTMENT OF ENERGY FOR
LEAVE TO INTERVENE
LAWRENCE A. GOLLOMP
United States Department of Energy
1000 Independence Avenue SW
Washington, D.c. 20585
Telephone:[phone]
E-mail: lawrence.gollompCip,hq.doe.gov
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS
BASE RATES AND CHARGES FOR
;EELECTRIC SERVICE IN THE STATE
OF IDAHO.
CASE NO. IPC-05-
PETITION OF THE UNITED STATES
DEPARTMENT OF ENERGY
FOR LEA VE 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.S.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. Goll ompCip,hq. doe. gov
Dale Swan
Exeter Associates, Inc.
5565 Sterret Place
Suite 310
Columbia, MD. 21044
[phone]
Dswan~exeterassocioates. com
III.
On October 28, 2005, IPC filed an Application with the Commission for authority to
increase its electric rates an average of7.8%. If approved, the Company s revenues would
increase $43 947 847 annually.
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.
WHEREFORE DOE respectfully requests the Commission to grant this Petition for
Leave to Intervene in the above-captioned proceeding.
Dated this 6th day of December 5, 2005.
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
PETITION TO INTERVENE
UNITED STATES DEPARTMENT
OF ENERGY
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of December 2005, I served a true, correct
and complete copy of the foregoing document on the following via electronic mail:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 63707-0070
Lawrence A.
Petition to Intervene
United States Department\ofEnergy