20060517Petition to intervene.pdf

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ATTORNEYS AT LAW
Tel: [phone] Fax: [phone] '
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P.O. Box 7218 Boise,1D 83707 - 515N.27thS(.Boise,ID'8?~6~\ i :,
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May 17, 2006
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
Boise ID 83720-0074
RE: Case No.lPC-O6-
Dear Ms. Jewell:
Enclosed please find an original and seven (7) copies of the PETITION TO
INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO
POWER COMPANY 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,~M%
Nina Curtis
Administrative Assistant
encl.
Peter 1. Richardson
ISB No. 3195
Richardson & O'Leary
515 N. 27th Street
O. Box 7218
Boise, Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
peter~richardsonando 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 PETITION OF
IDAHO POWER COMPANY FOR
MODIFICATION OF THE LOAD GROWTH
ADJUSTMENT RAE WITHIN THE POWER
COST ADJUSTMENT METHODOLOGY PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
CASE NO. IPC-06-
COMES NOW, The Industrial Customers ofIdaho Power, hereinafter referred to as
Intervenor " and pursuant to this Commission s Rules of Procedure, Rule 71 ID AP A
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. 27th St
O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonandoleary .com
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 ~minds 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-O6-
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 17th day of May 2006.
Richardson & O'Leary, LLP
By if .d)~
Peter 1. Richardson
Industrial Customers of Idaho Power
Intervention - IPC-O6-
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 17th day of May, 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
James C. Miller
Sr. Vice President, Generation
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
And hand-delivered to:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
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Nina Curtis
Administrative Assistant
Intervention - IPC-O6-