20080703Petition to Intervene.pdf

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Peter Richardson
Tel: [phone] Fax: [phone]
p eter~ richardson andoleary. co m
P.O. Box 7218 Boise,ID 83707 - 515 N. 27th St. Boise, ID 83702
2 July 2008
Ms. Jean Jewell
Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, I D 83702
RE: IPC-E-08-13
Dear Ms. Jewell:
We are enclosing an original and seven (7) copies of the PETITION TO
INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, in the
above case.
We have included a copy to be conformed by your offce, as welL.
Sincerely,
~WlLúrJJ
Richardson & O'Leary PLLC
Ci:
Peter J. Richardson
ISB No. 3195
Richardson & O'Leary
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(ßrichardsonandoleary.com
-)..ti: 50
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FORAN ~
ACCOUNTING ORDER AUTHORIZING )
THE INCLUSION OF POWER SUPPLY)
EXPENSES ASSOCIATED WITH THE )
PURCHASE OF CAPACITY AND ENERGY)
FROM PPL ENERGYlLUS, LLC IN THE ))POWER COST ADJUSTMENT )
CASE NO. IPC-E-08-13
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers ofIdaho Power, hereinafter referred to as
"Intervenor," and pursuat 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 part, 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'Lear
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonandolear .com
Intervention - IPC-E-08-13 1
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 Hil Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreading~mindspring.com
2. This Intervenor, the Industrial Customers ofIdaho Power, ("ICIP") is an
unincorporated association of Schedule 19 customers ofIdaho Power. All ICIP members receive
electric utilty services from Idaho Power Company. The ICIP claims a direct and substatial
interest in this proceeding in that the outcome will affect the company's power purchase costs
whichis likely to affect this intervenor's rates for service from Idaho Power Company.
3. This Intervenor, in its capacity as a representative of industrial customers intends
to paricipate herein as a party, and if necessary, to introduce evidence, submit comments, and
fuly participate in any hearing that may occur including the calling and cross examination of
witnesses. The nature and quality of evidence which this Intervenor will introduce is dependent
upon the nature and effect of other evidence in this proceeding.
5. Without the opportunty to intervene herein, this Intervenor would be without any
effective 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-08-13 2
6. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor wil it prejudice any pary to this case. Intervenors acknowledge the Commission's Notice of
Modified Procedure issued for this case on June 25, 2008.
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 necessary and appropriate; and to present evidence, call and examine
witnesses, present argument at any hearng that may occur, and to otherwse fully paricipate in
these proceedings.
DATED this 2nd day of July 2008.
Richardson & O'Lear, LLP
ByVda~
Peter J. Richardson
Industrial Customers of Idaho Power
Intervention - IPC-E-08-13 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2nd day of July, 2008, a tre 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:
Ms. Jean Jewell
Commssion Secreta
Idao Public Utilities Commssion
POBox 83720
Boise ID 83720-0074
2L Hand Delivery
_ U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
-- Hand Delivery
_ U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Baron L. Kline
Senior Regulatory Attorney
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
-- Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
~Cù~d\\
Nina Curis
Administrative Assistat
Intervention - IPC-E-08-13 4