20070711Petition to Intervene.pdf

BOEHM, KURTZ & LOWRY
A'ITORNEYS AT LAW
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SUITE 1510
CINCINNATI, OHIO 45202
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IQAHO FUGUe
U 'Ill I IES COMMISS1Oi\
VIA OVERNIGHT MAIL
July 10, 2007
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720
In re: Case No. IPC-O7-
Dear Ms. Jewell:
Enclosed please find the original and seven (7) copies of the PETITION TO INTERVENE OF THE
KROGER CO. dba FRED MEYER AND SMITH'S to be filed in the above referenced matter.
Copies have been served on all parties on the attached certificate of service. Please place this document
of file.
MLKkew
EneL
G:\WORK\MLK\KROGER\IDAHO\IPC-E-O7-08\Commission Itr (Idaho).doc
CERTIFICATE OF SERVICE
I hereby certify that true copy of the foregoing was served by electronic mail, unless otherwise noted, this
10th day of July, 2010 to the following:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, ill 83707-0070
John R. Gale
VP-Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, ill 83707-
Michael L. Kurtz, Esq.
Kurt J. Boehm, Esq.
nECE\\r,
BEFORE THE zmn JUL II IU:;j 9: 43
IDAHO PUBLIC UTILITIES COMMISSION
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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-07-
PETITION FOR LEAVE TO INTERVENE OF KROGER CO.
Pursuant to the Idaho Administrative Code 31.01.01-071 through .073, the Kroger Co.
Kroger ) petitions to intervene in the above captioned proceeding. In support, Petitioner states as
follows:
Name and Addresses of Petitioner
The Kroger Co.
Attn: Corporate Energy Manager, (009)
1014 Vine Street
Cincinnati, Ohio 45202
Name and Address of Attorneys Reuresentin2 Petitioner
Michael L. Kurtz, Esq.
Kurt J. Boehm, Esq.
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
Telephone: [phone] Facsimile: 513-421-2764
E-mail: mkurtz~BKLlawfirm.com kboehm~BKLlawfirm.com
Petitioner s Interest in this Proceedin2
Kroger is a corporation engaged in the business of selling groceries at retail throughout the
United States.One of the largest retail food companies in the United States, Kroger operates
approximately 10 grocery stores and other facilities in the state of Idaho. These stores purchase more
G:\ WORKIMLKIKROGER\IDAHO\IPC-E-O7-08\Petition Intervene (IDAHO).doc
than 30 million kWh of electricity from the Company annually. Petitioner is one of the largest
commercial customers served by the Company. The grocery stores operated by Kroger are high load
factor facilities that use energy for food storage, lighting, heating, cooling and distribution, often on a 24
hour a day, 7 day a week basis. If the Company s application is granted, then the cost for electric power
service to Petitioner could be substantially impacted. Petitioner has a substantial and vital interest in the
outcome of this proceeding which cannot be adequately represented by any other party.
Evidence to be Presented:
Kroger intends to present evidence related to rate design and revenue allocation.
WHEREFORE for the reasons set forth above, Petitioner requests that this Petition to Intervene
be granted.
DATED this 10th day of July, 2007.
Kurt J. Boehm, Esq.
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
Ph: 513-421-2255 Fax: [phone]
E-mail: mkurtz~BKLlawfirm.com
kboehm~BKLlawfirm.com
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