20101027Petition to Intervene.pdf

Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richardson & O'Lear, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702 .
Telephone: [phone]
Fax: [phone]
peterCirichardsonandolear .com
gregCirichardsonandoleary.com
ium OCT 27 PH 3: 12
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 AUTHORITY TO MODIFY SPECIAL )
CONTRACT ELIGIBILITY BY )
REDUCING THE UPPER LIMIT OF POWER )REQUIREMENTS FOR )
LARGE LOAD CUSTOMERS
CASE NO. IPC-E-I0-23
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers ofIdaho Power ("ICIP"), hereinafter referred
to as "Intervenor," and pursuat to this Commission's Rules of Procedure, Rile 71 IDAPA
31.01.01.71 hereby petitions the Commission for leave to intervene herein and to appear and
paricipate herein as a pary, 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'Lear, PLLC
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
1
PETITION TO INTERVENE
IPC-E-10-23
Telephone: [phone]
Fax: [phone]
peterCirichardsonandolear .com
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]
dreadingCimindspring.com
Peter J. Richardson
Gregory M. Adams
Richardson & O'Lear, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, ID 83702
Telephone: [phone]
Fax: [phone]
peterCirichardsonandolear.com
gregCirichardsonandolear.com
2. This Intervenor, ICIP, is an unincorporated association of Schedule 19 customers
of Idaho Power Company. All ICIP members receive electric utility services from Idaho Power
Company. ICIP claims a direct and substatial interest in ths 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 paricipate herein as a pary, and if necessary, to introduce evidence, cross-examine witnesses,
call and examine witnesses, and be heard in arguent. The natue and quality of evidence which
this Intervenor will introduce is dependent upon the nature and effect of other evidence in ths
proceeding.
4. Without the opportty to intervene herein, this Intervenor would be without
adequate means of paricipation in this proceeding which may have a material impact on its
electrc rates and terms and conditions of service.
WHEREFORE, the Industrial Customers ofIdaho Power respectfully requests that this
2
PETITION TO INTERVENE
IPC-E-I0-23
Commission grant its Petition to Intervene in these proceedings and to appear and participate 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 ths 27th day of October, 2010.
RICHARDSON AND O'LEARY, PLLC
By:
eter J. Richardson
Gregory M. Adams
Attorneys for the Industrial
Customers of Idaho Power
3
PETITION TO INTERVENE
IPC- E-l 0-23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 27th day of October, 2010, I caused a tre and
correct copy of the foregoing PETITION TO INTERVENE OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER to be served by the method indicated below, and
addressed to the following:
Jean Jewell
Idaho Public Utilties Commission
472 West Washington Street (83702)
Post Office Box 83720
Boise, Idaho 83720-0074
( ) U.S. Mail, Postage Prepaid
(x) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
Lisa Nordstrom
Donovan Walker
Idaho Power Company
POBox 70
Boise, Idaho 83707
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnght Mail
( ) Facsimile
( ) Electronic Mail
Gregory W. Said
Michael J. Youngblood
Darlene Nemnch
Idaho Power Company
POBox 70
Boise, ID 83707
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
Signed Qut\útih\
Nina M. Curis
CERTIFICATE OF SERVICE - 1