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]
peter(irichardsonandoleary.com
greg(irichardsonandolear.com
ZOlU OCT 27 PH 3:13
Attorneys for the Industrial Customers of Idao Power
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S REQUEST TO MODIFY
RECOVERY OF INCENTIVES PAID TO
SECURE DEMAND-SIDE
RESOURCES
)
) CASE NO. IPC-E-I0-27
) 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 Procedure, Rule 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. 2ih St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
1
PETITION TO INTERVENE
IPC-E-10-27
Fax: [phone]
peter(irichardsonandolear.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]
dreading(imindspring.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]
peter(irichardsonandolear.com
greg(irichardsonandolear .com
2. This Intervenor, ICIP, is an uncorporated association of Schedule 19 customers
of Idaho Power Company. All ICIP members receive electrc utilty services from Idaho Power
Company. ICIP claims a direct and substatial interest in this proceeding in that its members'
rates for service from Idaho Power Company may be afected 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 necessar, 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 natue and effect of other evidence in this
proceeding.
4. Without the opportunity to intervene herein, ths Intervenor would be without
adequate means of paricipation in this proceeding which may have a material impact on its
electric rates and terms and conditions of service.
WHEREFORE, the Industral Customers of Idaho Power respectfully requests that this
2
PETITION TO INTERVENE
IPC-E-I0-27
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 27th day of October, 2010.
RICHARDSON AND O'LEARY, PLLC
By:G-
P er J. Richardson
egory M. Adams
Attorneys for the Industral
Customers of Idaho Power
3
PETITION TO INTERVENE
IPC-E-I0-27
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 27th day of October, 2010, I caused a true 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 Offce 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
PO Box 70
Boise, Idaho 83707
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
John R. Gale
Darlene Nemnich
Idaho Power Company
POBox 70
Boise, ID 83707
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
Signed ~i'íGUkÏ.
Nina M. Curis
CERTIFICATE OF SERVICE - 1