20080703Petition to Intervene.pdf

~r.Ql;m..-y PW;ATTORNEYS AT LAW 8: I (I
Peter Richardson
Tel: [phone] Fax: [phone]
petetfl richardso n an dol eary. com
P.O. Box 7218 Boise.1D 83707 - 515 N. 27th St. Boise.ID 83702
July 1, 2008
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise i D 83720-0074
RE: Case No.lPC-E-ÐS-10
Dear Ms. Jewell:
Enclosed please find an original and seven (7) copies of the PETITION TO
INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER in the
above case.
i have also enclosed an extra copy to be serviæ-dated and returned to us for
our files. Thank you.
Sinærely,
Ç\n ~ /,1. /1 1 Ad- \Nin~'
Administrative Assistant
encl.
Peter J. Richardson
ISB No. 31951
Richardson & O'Lear
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(irichardsonandoleary.com
8: 10
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES 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. IPC-E-08-10
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho 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:
Industral Customers of Idaho Power
c/o Peter J. Richardso~
Richardson & O'Leary
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(irichardsonandolear .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(imindspring.com
2. This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule 19 customers of Idaho Power. All I CIP members receive
electric utilty 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. Ths Intervenor, in its capacity as a representative of industrial customers intends
to paricipate herein as a par, 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 natue and effect of other evidence in this
proceeding.
5. Without the opportty to intervene herein, this Intervenor would be without any
means of paricipation in this proceeding which may have a material impact on its electric rates
and terms and conditions of service.
Intervention - IPC-E-08-10 2
6. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any par to this case.
WHEREFORE, the Industrial Customers ofIdaho Power respectfully requests that this
Commission grant its Petition to Intervene in these proceedings and to appear and paricipate in
all matters as may be necessar and appropriate; and to present evidence, call and examine
witnesses, present argument and to otherwse fully paricipate in these proceedings.
DATED this 1 st day of July 2008.
Richardson & O'Lear, LLP
BYp~4:~
Industrial Customers of Idaho Power
Intervention - IPC-E-08-1 0 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1st day of July, 2008, 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:
Jean Jewell
Commission Secretar
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
Baron L. Kline
Senior Regulatory Attorney
Idaho Power Company
POBox 70
Boise, Idaho 83707-0070
~~~
Nina Curis
Administrative Assistat
Intervention - IPC-E-08-1 0 4