20070712Petition to Intervene.pdf

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Department of Energy
Washington, DC 20585 F~ECE!\":'
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July 10, 2007
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, ID 83720-0074
RE: Case No. IPC-O7-
Dear Ms. Jewell:
Enclosed please find the original and seven (7) copies of the PETITION OF THE
UNITED STATES DEPARTMENT OF ENERGY FOR LEAVE TO INTERVENE in
the above-captioned proceeding. Also enclosed is an additional copy of the Petition for
Leave to Intervene that I ask be date stamped and returned in the enclosed stamped
envelope. If you have any questions concerning this filing you can contact me at (202)
586-0503.
Lot H. Cooke
Acting Assistant General Counsel
United States Department of Energy
1000 Independence Avenue
Washington, D.c. 20585
Lot.Cooke~hq.doe.gov
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LOT H. COOKE
United States Department of Energy
1000 Independence Avenue, SW
Washington, D.c. 20585
Telephone: [phone]
Fax: [phone]
E-mail: LotCooke(Q),hq.doe.gov
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BEFORE THE IDAHO PUBLIC UTILITY 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. 1PC-07-
PETITION OF THE UNITED STATES
DEPARTMENT OF ENERGY
FOR LEAVE TO INTERVENE
COMES NOW the United States Department of Energy ("DOE") 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 Utility Commission ("Commission ) to grant this Petition for
Leave to Intervene in the above-captioned proceeding pursuant to Rules 071-075 of the
Commission s Rules of Practice and Procedure. In support thereof, DOE states:
DOE has been delegated authority by the General Services Administration pursuant to
PETITION TO INTERVENE
UNITED STATES DEP AR TMENT OF ENERGY
section 201 (a)(4) of the Federal Property and Administrative Services Act of 1949, as
amended (40 U.C. 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:
Lot H. Cooke
Acting Assistant General Counsel
United States Department of Energy
1000 Independence Avenue, SW
Washington, D.C. 20585
Telephone: [phone]
E-mail: Lot.Cooke~hq,doe.gov
Dale Swan
Exeter Associates, Inc.
5565 Sterrett Place
Suite 310
Columbia, MD 21044
Telephone: [phone]
E-mail: Dswan~exeterassociates.com
III.
On June 8, 2007, IPC filed an Application with the Commission for authority to
increase its rates an average of 10.35%. If approved, IPC's revenues would increase by
$63.9 million.
PETITION TO INTERVENE
UNITED STATES DEPARTMENT OF ENERGY
IV.
The proposed tariffs will affect the rates which DOE and the other Federal
Executive Agencies 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 which would not be represented by any other party in this proceeding.
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 arguments 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.
VI.
For the purposes of the above-captioned proceeding, I have designated as local
counsel and an active member of the Idaho State Bar, Dennis A. Love, (Bar No. 3402)
O. Box 1625, Idaho Fall, Idaho, 83415-2506, [phone].
WHEREFORE DOE respectfully requests the Commission to grant this Petition
for Leave to Intervene in the above-captioned proceeding.
Dated this 10th day of July, 2007.
By
~~/
Lot H. Cooke
Acting Assistant General Counsel
United States Department of Energy
PETITION TO INTERVENE
UNITED STATES DEPARTMENT OF ENERGY
CERTIFICATE OF SERVICE
CASE NO. IPC-O7-
I hereby certify that I have this 10th day of July, 2007 , served or caused to be
served a true and correct copy ofthe attached PETITION OF THE UNITED STATES
DEPARTMENT OF ENERGY FOR LEAVE TO INTERVENE upon each of the parties
listed below by placing the same in the u.S. Mail, postage prepaid.
Barton L. Kline
Lisa D. Nordstrom
Idaho Power Company
Boise, ID 83707
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
Boise, ID 83707
Peter J. Richardson
Richardson & O'Leary
505 N. 27th St.
O. Box 7218
Boise, ID 83702
Dr. Don Reading
6070 Hill Road
Boise, ID 83703
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Chartered
O. Box 1390; 201 E. Center
Pocatello, ID 83204-1391
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
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L'O t H. Cooke
Acting Assistant General Counsel
United States Department of Energy
PETITION TO INTERVENE
UNITED STATES DEPARTMENT OF ENERGY