20090505Petition to Intervene.pdf

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Eric L. Olsen, ISB No. 4811
RACINE, OLSON, NYE, BUDGE &
BAlLEY, CHATERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
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2009 HAY -l.i P~î ll: 38
Attorneys for Intervenor
Idaho Irigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S PETITION FOR APPROVAL )
OF CHANGES TO THE IRRGATION PEAK )REWARS PROGRAM. )
)
IDAHO POWER COMPANY'S PROPOSAL )
TO RECOVER THE ANUAL COST OF THE )PROGRA IN THE PCA. )
)
CASE NO. IPC-E-08-23
PETITION OF IDAHO IRGATION PUMPERS ASSOCIATION, INC.,
FOR LEAVE TO INTERVENE
COMES NOW Idaho Irrgation Pumpers Association, Inc., herein called "ths Intervenor"
and pursuant to Rules 72 and 73 of the rules of Procedure of the Idaho Public Utilty Commission,
and by ths Petition asks leave to intervene herein and to appear and paricipate as a par herein, and
as basis therefor states as follows:
(1) The name and address of this Intervenor is:
Idaho Irigation Pumpers Association, Inc.
c/o Lyn Tominaga
P.O. Box 2624
Boise, Idaho 83701-2624
PETITION OF IDAHO IRRGATION PUMERS ASSOCIATION, INC.
FOR LEAVE TO INTERVENE - 1
This Intervenor will be represented by:
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Charered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
and requests that copies of all pleadings and production requests and responses should be provided
to the following:
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Charered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
E-mail: elo(iracinelaw.net
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
Fax: [phone]
E-mail: tony(iyane1.net
(2) This Intervenor and its members have a direct and substatial interest in this
proceeding and intend to paricipate in all respects herein as a par as may be required to represent
its interests.
(3) Without the opportity to intervene herein, ths Intervenor would be without a
maner or means of paricipating in the lawfl determination of issues which will result in affecting
its rates for electrc service.
(4) This Intervenor recognizes that the time for filing this Petition to Intervene has passed
as provided in Order No. 30694. However, this Petitioner is filing ths late request for intervention
status as provided in Rule 73 and in conjunction with this Intervenor's Petition for Reconsideration
and/or Clarfication of Order No. 30771 (the "Petition for Reconsideration"). The reasons for this
Petition are set fort in the Petition for Reconsideration.
PETITION OF IDAHO IRGATION PUMERS ASSOCIATION, INC.
FOR LEAVE TO INTERVENE - 2
WHEREFORE, ths Intervenor requests that ths Commssion conf ths Intervenor's leave
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 exame witnesses, cross-examne witnesses, present
argument, and to otherwse fully parcipate in the proceedings.
DATED this 4th day of May, 2009.
RACIN, OLSON, NYE, BUDGE &
BAlLEY, CHATERED
..BY~"'~~ERICL. SEN ~
PETITION OF IDAHO IRGATION PUMERS ASSOCIATION, INC.
FOR LEAVE TO INTERVENE - 3
\ ..
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 4th day of May, 2009, I served a tre, correct and complete
copy of the Petition ofIdaho Irrigation Pumpers Association, Inc. For Leave to Intervene to each of
the following, via U.S. Mail or private courier, e-mail or hand delivery, as indicated below:
Jean D. Jewell, Secreta
Idaho Public Utilties Commission
P.O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
j j ewell(ipuc.state. id. us
U.S. Mail/ostage Prepaid
E-mail
Facsimile
Overnght Mail
X Hand Delivered
Baron L. Kline
Donovan E. Walker
Idaho Power Company
P.O. Box 70
Boise,ID 83707-0070
bkline(iidahopower.com
dwalker(iidahopower.com
X U.S. Mail/ostage Prepaid
X E-mail
Facsimile
Overnght Mail
Hand Delivered
..E~')~
PETITION OF IDAHO IRGATION PUMERS ASSOCIATION, INC.
FOR LEAVE TO INTERVENE - 4