20110620Petition to Intervene.pdf

Department of Energy
Washington, DC 20585 RECEIV
2611 JUN 20 AM 9: 16
Ms. Jean D. Jewell, Secretar
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
June 17,2011
Re: Case No. IPC-E-II-08
United States Department of Energy's Petition for Leave to Intervene
Dear Ms. Jewell:
An original and seven (7) copies of the United States Department of Energy's Petition for
Leave to Intervene in the above-captioned proceeding are enclosed herewith for fiing.
At your convenience, please date stamp and retur the enclosed extra copy of the petition.
The petition has been transmitted to the parties via electronic emaiL.
Than you for your kind attention.
Very truly yours,
~a. -:..L¿. ..
Arhur Perry Bruder
Attorney for the
United States Deparment of Energy
1000 Independence Avenue SW
Washington, DC 20585
arhur. bruder~hq.doe.gov
phone: [phone]
cell: [phone]
* Printed with soy ink on reccled paper
RECEIVED
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION au 9" l 6
2a1\ JUN 20 Hn "l
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE TO ELECTRIC
CUSTOMERS IN THE STATE OF IDAHO
)
)
) CASE NO. IPC-E-ll-08
)
)
THE UNITED STATES DEPARTMENT OF ENERGY'S
PETITION FOR LEAVE TO INTERVENE
COMES NOW, the United States Department of Energy, ("the Deparment" or
"DOE") and, pursuant to Rule 72 ofthè Commission's rules of procedure and by this
petition, asks leave to intervene, and to appear and paricipate as a pary, herein. As
grounds for this petition, the Deparment states that:
(1) Its name and address are:
The United States Deparment of Energy
1000 Independence Ave. SW
Washington, DC 20585
(2) The Deparment wil be represented by:
Steven A. Porter
Assistant General Counsel
Electricity and Fossil Energy .
United States Deparment of Energy
1000 Independence Ave. SW
Washington, DC 20585
Steven.porter(fhq.doe. gov
Phone: [phone]
Arhur Perry Bruder
Attorney -Advisor
United States Deparment of Energy
1000 Independence Ave. SW
Washington, DC 20585
Arthur. bruder~hq.doe.gov
Phone: [phone]
Fax: [phone]
(3) DOE requests that all pleadings, production requests and responses, orders and other
documents be provided to Arhur Perry Bruder as indicated above, and to:
Mr. Dwight Etheridge
Exeter Associates
detheridge~exeterassociates.com
5565 Sterrett Place, Suite 310
Columbia, MD 21044
phone: [phone]
fax: [phone]
(4) The Deparment's Idaho National Laboratory ("INEL") is one of Idaho Power
Company's ("the Company") largest customers and one of the Company's four "special
contract" customers, As such, DOE has a substantial interest in the outcome ofthis
proceeding which canot be adequately represented by any other party. The Company
puroses to increase INEL's rate by $1,191,668, or 14.95%. If DOE were denied the
opportunity to intervene, it could not paricipate in the lawfl determination of issues
which will have a material effect upon the rates, terms and conditions under which it
receives service;
(5) The Deparment intends to paricipate fully as a pary herein in all respects that may
be required for it to represent its interests, including, but not limited to, submission of
direct and responsive testimony, examination and cross-examination of witnesses,
submission of briefs, and presentation of and response to motions and oral argument.
WHEREFORE, the Deparment of Energy respectfully requests that this
Commission grant this petition to intervene in this proceeding.~nQ._~
Arthur Perry Bitde~
Office of the General Counsel
United States Deparment of Energy
1000 Independence Ave. SW
Washington, DC 20585
arhur. bruder~hq.doe.gov
phone: [phone]
cell: [phone]
DATED this 17th day of June, 2011
-2-
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of June, 2011, I served a true, correct and
complete copy of the within and foregoing document, the United States Deparent or811 JUN 20
Energy's Petition for Leave to Intervene in IPC-E- 11-08, upon all of the parties of record
in this proceeding, by:
RECEfVl=n¡"'."'" l...
AM 9: 20
(1) delivering the original and seven copies of the document by overnight delivery
service, properly addressed and prepaid, to:
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
P.O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
(2) transmitting the document via electronic mail to each of the following persons at the
email address shown:
Randy Lobb
Idaho Public Utilities commission
472 W. Washington St.
Boise, ID 83702
Randy.Lobb~puc..Idaho.gov
Weldon Stutzman
Idaho Public Utilities commission
472 W. Washington St.
Boise, ID 83702
Weldon.Stutzman~puc.idaho.gov
Neil Price
Idaho Public Utilties commission
472 W. Washington St.
Boise, ID 83702
Neil.Price ~puc.Idaho.gov
Lisa D. Nordstrom
Donovan E. Walker
Chrstina Bear
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
dwalker(fidahopower .com; lnordstrom(Ðidahopower .com;cbearr(fidahopower.com
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
rgale(Ðidahopower.com
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Chartered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
rcb(ßracinelaw.net; elo(Ðracinelaw.net
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
yankel~attbi.com
Michael L. Kurz, Esq.
Kur J. Boehm, Esq.
Boehm, Kurz & Lowry
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
mkurz(ßbkllawfrm.com; kboehm~bkllawfirm.com
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 South State Street, Suite 200
Salt Lake City, Utah 84111
khiggins~energystrat.com
Peter J. Richardson
Richardson & O'Leary
515 N.27th St
P.O. Box 7218
Boise, Idaho 83702
peter~richardsonandoleary .com
Dr. Don Reading
6070 Hil Road
Boise, Idaho 83703
dreading~mindspring.coma~~r..
Arhur Perr B der .
Attorney for the
United States Deparment of Energy
offce: [phone]
cell: [phone]