20100310Petition to Intervene.pdf

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t:"l~r.Q~p~ 5ATTORNEYS AT LAW iß'ßM~R \0 PM 3: \
Peter Richardson
Tel: [phone] Fax: [phone]
p ere r~ r ic h a rdoo n an do leary. com
P.O. Box n18 Boise. 10 83707 - 515 N. 27th St. Boise,
10 March 2010
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise ID 83720-0074
RE: Case No.lPC-E-10-o4
Dear Ms. Jewell:
Enclosed please find an original and (7) copies of the PETITION TO
INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO
POWER COMPANY in the above case.
An extra copy is also enclosed to be stamped & returned to our offæ.
Sincerely,~av.ll
Nina Curtis
Administrative Assistant
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..
RECEI\/
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 27th Street
P.O. Box 7218
Bois., Idaho 83702
Telephone: [phone]
Fax: [phone]
petertãrichardsonandolearv. com
greg(ârichardsonandoleary. com
2010 MAR 10 PM 3: 15
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 AN )
ENERGY EFFICIENCY RIDER TO FUND )PARTICIPATION IN NW ENERGY )ALLIANCE )
)
CASE NO. IPC-E-10-04
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power ("ICIP"), hereinafter
referred to as "Intervenor," and pursuant to this Commission's Rules of Proædure, Rule
71 IDAPA 31.01.01.71 hereby petitions the Commission for leave to intervene herein
and to appear and participate herein as a part, and as grounds therefore states:
1. The name and address of this Intervenor is:
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson & O'Leary, PLLC
515 N. 2¡th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(ârichardsonandoleary. com
1
PETITION TO INTERVENE
IPC- E-l 0-04
... "
Copies of all pleadings, production requests, production responses, commission
orders, and other documents should be provided to:
Dr. Don Reading
6070 Hil Road
Boise, Idaho 83703
Telephone: [phone]
Fax: [phone]
d readingCãmindspring .com
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 2¡th Street
P.O. Box 7218
Boise, ID 83702
Telephone: [phone]
Fax: [phone]
peterCãrichardsonandoleary. com
gregCãrichardsonandoleary.com
2. This Intervenor, ICIP, is an unincorporated association of Schedule 19
customers of Idaho Power Company. AIlICIP members receive electric utility services
from Idaho Power Company. ICIP claims a direct and substantial interest in this
proceeding in that its members' 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 participate herein as a part, and if necessary, to introduæ evidenæ, 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
nature and effect of other evidence in this proceeding.
4. Without the opportunity to intervene herein, this Intervenor would be
without any means of participation in this proæeding which may have a material impact
on its electric rates and terms and conditions of service.
2
PETITION TO INTERVENE
iPC- E-l 0-04
"-. .
5. Granting this Intervenor's petition to intervene wil not unduly broaden the
issues nor wil it prejudice any part to this case.
WHEREFORE, the Industrial Customers of Idaho Power respectfully requests
that this Commission grant its Petition to Intervene in these proæedings and to appear
and participate in all matters as may be neæssary and appropriate; and to present
evidence, call and examine witnesses, present argument and to otherwise fully
participate in these proæedings.
DATED this 10th day of March, 2010.
By:1¡i-ha~ ~
RICHARDSON AND O'LEARY, PLLC
Attorneys for the Industrial Customers of
Idaho Power
3
PETITION TO INTERVENE
iPC- E-l 0-04
. .
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of March, 2010, 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:
Lisa Nordstrom
Barton Kline
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
InordstromCãidahopower.com
CLAIRE FULENWIDER
Executive Director I
Northwest Energy Effciency Allance
529 SW Third Avenue, Suite 6
Portland, Oregon 97204
CF ulenwidertãnwalliance. org
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
~.ÓhÒ-\
Nina Curtis
Administrative Assistant
1
PETITION TO INTERVENE
iPC- E-l 0-04