20080423Petition to Intervene.pdf

Peter J. Richardson
ISB No. 3195
Richardson & O'Lear
515 N. 2ih Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
peter(frichardsonandolear .com
Attorneys for the Industrial Customers of Idaho Power
RECEiVED
APi( 23 Ali
IDAdO
UTILITIES ie
ISSJON
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
IDAHO POWER COMPANY FOR )
AUTHORITY TO IMPLEMENT POWER )
COST ADJUSTMENT (PCA) RATES FOR )
ELECTRIC SERVICE FROM JUNE 1,2008 )THROUGH MAY 31,2009 )
)
)
CASE NO. IPC-E-08-07
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 this Commission's Rules of Procedure, Rule 71 IDAPA
31.01.01.71 hereby petitions the Commission for leave to intervene herein and to appear and
paricipate herein as a party, and as grounds therefore states as follows:
1. 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
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(frichardsonandolear .com
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 Hil Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreading(fmindspring.com
2. This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule 19 customers ofIdaho Power. All ICIP members receive
electric utility services from Idaho Power Company. The ICIP claims a direct and substatial
interest in this proceeding in that their rates for service from Idaho Power Company may be
affected by the outcome of this proceeding.
3. This Intervenor, in its capacity as a representative of industrial customers intends
to participate herein as a pary, and if necessar, to introduce evidence, cross-examine witnesses,
call and examine witnesses, and be heard in argument. The nature and quality of evidence which
this Intervenor wil introduce is dependent upon the nature and effect of other evidence in this
proceeding.
5. 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.
6. Granting this Intervenor's petition to intervene wil not unduly broaden the issues
nor wil it prejudice any pary to this case.
Intervention - IPC-E-08-07 2
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 necessar and appropriate; and to present evidence, call and examine
witnesses, present argument and to otherwise fully paricipate in these proceedings.
DATED this 23th day of April 2008.
Richardson & O'Lear, LLP
r-d~By
Peter J. Richardson
Industrial Customers of Idaho Power
Intervention - IPC-E-08-07 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 23th day of April, a true and correct copy of the within
and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER, was served by HAND DELIVERY, to:
Barton L. Kline
Donovan E. Walker
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707-0070
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
~tL)
Nina Curtis
Administrative Assistant
Intervention - IPC-E-08-07 4