20090310Petition to Intervene.pdf

Peter Richardson
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peter~ richardson andoleary. com
P.O. Box 7218 Boise. 10 83707 - 515 N. 27th St. Boise, ID 83702
10 March 2009
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilties Commission
472 W. Washington
Boise, ID 83702
RE: IPC-E-09-03
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.
An additional copy is enclosed for you to stamp for our records.
Sincerely,~ÚU\h'.\
Nina Curtis
Richardson & O'Leary PLLC
Peter 1. Richardson
ISB No. 3195 )
Richardson & O'Leary
515 N, 27th Street
P,O. Box 7218
Boise, Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
peter~richardsonandoleary .com
Attorneys for the Industrial Customers of Idaho Power
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FORA )
CERTIFICATE OF PUBLIC CONVENIENCE)
AND NECESSITY FOR THE LANGLEY )GULCH POWER PLANT )
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CASE NO. IPC-E-09-03
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 RTd
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 1. Richardson
Richardson & O'Leary
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonandoleary .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~mindspring.com
2. This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unncorporated association of Schedule 19 customers ofIdaho Power. All ICIP members receive
electric utility services from Idaho Power Company. The ICIP claims a direct and substantial
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 paricipate herein as a par, and if necessary, to introduce evidence, cross-examine witnesses,
call and examine witnesses, and be heard in argument. The natue 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 opportunity 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.
6. Granting ths 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 Idao 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 10th day of March 2009.
Richardson & O'Leary, LLP
Intervention - IPC-E-08-07 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of March, 2009, a tre and correct copy of the
within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER was served by HAND DELIVERY, to:
Baron L. Kline
Donovan E. Walker
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707-0070
Jean Jewell
Commission Secretay
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
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Nina CUris
Administrative Assistat
Intervention - IPC-E-08-07 4