20051125Petition to intervene.pdf

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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~ri chardsonando 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 APPLICATION OF)IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
TO ELECTRIC CUSTOMERS IN THE STATE)OF IDAHO
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 November 22 2005 and pursuant to this Commission s Rules of Procedure, Rule 71
IDAP A 31.01.01.71 and 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. 27th 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~mindspring.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 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-28-
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 23rd day of November, 2005.
Richardson & O'Leary, LLP
By
DY-tl Peter J. Richardson
Industrial Customers of Idaho Power
Intervention .- IPC-28-
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the ~~P day of November 2005, 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
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Nina Curtis
Administrati ve Assistant
John R. Gale
Vice President Regulatory Affairs
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
Intervention - IPC-28-