20100202Petition to Intervene.pdf

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(grichardsonandoleary .com
Attorneys for the Industrial Customers of Idaho Power
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BEFORE THE
IDA 0 PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PPLICATION )
OF IDAHO POWER COMP NY TO )
ESTABLISH ITS BASE LE EL FOR NET )
POWER SUPPLY EXPEN ES FOR 2010. )
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CASE NO. IPC-E-10-01
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 711DAPA
31.01.01.71 hereby petitions the Commission for leave to intervene herein and to
appear and participate 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((richardsonandoleary.com
Intervention -IPC-E-10.01 1
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
dreadingCCmindspring .com
Gregory Adams
Richardson & O'Leary
515 N 27th St / P.O. Box 7218
Boise, Idaho 83702
[phone]
greg((richardsonandoleary.com
2. This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule 19 customers of Idaho Power. AIlICIP
members receive electric utility services from Idaho Power Company. ICIP claims a
direct and substantial interest in this proceeding in that the outcome wil affect the
Company's power purchase costs which is 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 participate herein as a party, and if necessary, to introduce evidence, submit
comments, and fully participate in any hearing that may occur including the callng and
cross examination of witnesses. The nature and quality of evidence which this
Intervenor wil introduce is dependent upon the nature and effect of other evidence in
this proceeding.
Intervention -IPC-E-10.01 2
5. Without the opportunity to intervene herein, this Intervenor would be
without any effective 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 party to this case. Intervenors acknowledge the
Commission's Notice of Modified Procedure issued for this case on June 25, 2008.
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 necessary and appropriate; and to present
evidence, call and examine witnesses, present argument at any hearing that may occur,
and to otherwise fully participate in these proceedings.
I);iDATED this ~ day of February, 2010.
Richardson & O'Leary, LLP
By f¥
Peter J. Richardson
Industrial Customers of Idaho Power
Intervention -IPC-E-10.01 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the _day of February, 2010, a true and correct
copy of the within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER, was served in the method shown to:
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
~ Hand Delivery
_ U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Gregory W. Said
Director of State Regulation
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
i Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Barton L. Kline
Lisa D. Nordstrom
Donovan E. Walker
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
i Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
~ÚUm)
Nina Curtis
Administrative Assistant
Intervention -IPC-E-10.01 4