20060601Petition to intervene.pdf

Department of Energy
Washington , DC 20585
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VIA FEDERAL EXPRESS
May 31 2006
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
Re: Case No. IPC-O6-
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 in this matter.
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Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
Enclosure:
PETITION OF THE UNITED STATES
DEP ARTMENT OF ENERGY FOR
LEAVE TO INTERVENE
Printed with soy ink on recycied paper
LAWRENCE A. GOLLOMP
United States Department of Energy
1000 Independence Avenue SW
Washington, D.C. 20585
Te1ephone:[phone]
E-mail: lawrence.gollomp~hq.doe.gov
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR
MODIFICATION OF THE LOAD GROWTH)
ADJUSTMENT FACTOR WITHIN THE
POWER COST ADJUSTMENT (PCA)
METHODOLOGY
CASE NO. IPC-06-
PETITION OF THE UNITED STATES
DEPARTMENT OF ENERGY
FOR LEAVE 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 ofIdaho 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.
ll.
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. Gollomp~hq .doe.gov
Dale Swan
Exeter Associates, Inc.
5565 Sterret Place
Suite 310
Columbia, MD. 21044
[phone]
Ds wan~exeterassoci oates. com
Ill.
On April 13, 2006, IPC filed a Petition with the Commission to modify the
method for determining the load growth adjustment rate, which is one of the components used
to determine Idaho s Power s ( annual) Power Cost Adjustment ((PCA)) rate." The load growth
adjustment is included as a component in the PCA's true-up computation. Idaho Power explains
that the load growth adjustment rate results in a credit during periods of load growth and results
in a debit during periods of load decline.
The proposed load growth adjustment 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.
Accordingly, DOE seeks the right to fully participate in this proceeding
WHEREFORE DOE respectfully requests the Commission to grant this Petition for
Leave to Intervene in the above-captioned proceeding.
Dated: May 31 , 2006 By G.J.
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 31st day of May 2006, I served a true, correct
and complete copy of the foregoing document on the following via Federal Express:
Barton L. Kline
Monica B. Moen
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702
bkline(fYidahopower. com
mmoen(fYidahopower. com
Gregory W. Said
Director, Revenue Requirement
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702
gsaid(fYidahopower. com
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Petition to Intervene
United States Department\of Energy