20110329Petition 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(frichardsonandolear.com
greg(frichardsonandolear .com
RECEI D
t011 l1AR 29 PH i: 00
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
)IN THE MATTER OF IDAHO POWER )
COMPANY'S REQUEST TO INCREASE ITS )
RATES FOR ELECTRIC SERVICE TO )
RECOVER ITS 2010 PENSION CASH )CONTRIBUTION )
CASE NO. IPC-E-II-04
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, the Industrial Customers ofIdaho Power ("ICIP"), hereinafter referred to
as "Intervenor," and pursuant to ths 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 par, 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
Telephone: [phone]
Fax: [phone]
peter(frichardsonandoleary.com
1
PETITION TO INTERVENE
IPC- E-II-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]
dreading(fmindspring.com
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, ID 83702
Telephone: [phone]
Fax: [phone]
peter(frichardsonandoleary.com
greg(frichardsonandoleary .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 substantial interest in this proceeding because its members'
rates for service from Idaho Power Company may be affected by the outcome of this proceeding.
3. Ths Intervenor, in its capacity as a representative of industral 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 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.
4. Without the opportunity to intervene herein, this 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.
2
PETITION TO INTERVENE
IPC- E-II-04
WHEREFORE, the Industrial Customers of Idaho 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 arguent and to otherwse fully paricipate in these proceedings.
DATED ths 29th day of March, 2011.
RICHASON AND O'LEARY, PLLC
By:f!~
Peter J. Richardson
Gregory M. Adams
Attorneys for the Industrial
Customers of Idaho Power
3
PETITION TO INTERVENE
IPC- E-II-04
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the29th day of March, 2011, a tre and correct copy of the
within and foregoing PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER IN CASE NO.IPC-E-II-04 was served in the maner shown to:
Ms. Jean Jewell
Commssion Secreta
Idao Public Utilties Commssion
POBox 83720
Boise, il 83720-0074
X Hand Delivery
~ U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Lisa D Nordstrom
Jason B Wiliams
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
lnordstrom(fidahopower.com
i wiliams(fidahopower. com
_ Hand Delivery
X-U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Tim Tatum
Greg Said
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
ttatum(fidahopower.com
gsaid(fidahopower.com
_ Hand Delivery
X-U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
QiMúu'ti,
Nina Curis
Administrative Assistant