20111108ICIP Petition to Intervene.pdf

RECEIVED
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~chardsonandolear.com
gregrgchardsonandolear.com
20n NOV -8 PH 12: 30
Attorneys for the Industral Customers of Idaho Power
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR AN )
EXTENDED AND MODIFIED ACCOUNTING)
ORDER TO AMORTIZE ADDITIONAL )
ACCUMULATED DEFERRD INCOME TAX )CREDITS. )
CASE NO. IPC-E-II-22
PETITION TO INTERVENE
OF THE INUSTRAL CUSTOMERS
OF IDAHO POWER
COMES NOW, the Industral Customers ofIdaho Power ("ICIP"), hereinafer referred to
as "Intervenor," and pursuat to ths Commission's Ru1es of Procedure, Rule 71 IDAPA
31.01.01.71 hereby petitions the Commission for leave to intervene herein and to appear and
parcipate herein as a par, and as grounds therefore states:
1. The name and address of ths Intervenor is:
Industral Customers of Idao Power
c/o Peter J. Richardson
Richardson & O'Lear, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~chardsonandolear.com
1
PETITION TO INTERVENE
IPC- E-II-08
Copies of all pleadings, production requests, production responses, commission orders,
and other documents shou1d be provided to:
Dr. Don Readig
6070 Hil Road
Boise, Idaho 83703
Telephone: [phone]
Fax: [phone]
dreading~indspring.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(grichardsonandolear.com
greg(grichardsonandolear.com
2. This Intervenor, ICIP, is an uncorporated association ofSchedu1e 19 customers
ofIdaho Power Company. All ICIP members receive electrc utility services from Idaho Power
Company. ICIP claims a direct and substatial interest in ths proceeding because its members'
rates for service from Idaho Power Company may be affected by the outcome of ths proceeding.
3. Ths Intervenor, in its capacity as a representative of industral customers, intends
to parcipate herein as a par, and if necessar, to introduce evidence, cross-examine witnesses,
call and examine witnesses, and be heard in arguent. The natue and quaity of evidence which
ths Intervenor will introduce is dependent upon the natue and effect of other evidence in ths
proceeding.
4. Without the opportty to intervene herein, ths Intervenor wou1d be without
adequate means of parcipation in ths proceeding which may have a material impact on its
electrc rates and terms and conditions of service.
2
PETITION TO INTERVENE
IPC-E-II-22
WHEREFORE, the Industral Customers of Idaho Power respectfly requests that ths
Commission grant its Petition to Intervene in these proceedings and to appear and parcipate in
all matters as may be necessar and appropriate; and to present evidence, call and exame
witnesses, present arguent and to otherwse fuly paricipate in these proceedings.
~l1DATED ths ~day of November, 2011.
RICHASON AND O'LEARY, PLLC
BY:~~
Peter J. Richardson
Gregory M. Adams
Attorneys for the Industral
Customers of Idaho Power
3
PETITION TO INTERVENE
IPC-E-II-22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th day of November, 2011, a tre and correct copy of the
with and foregoing PETITION TO INTERVENE OF THE INUSTRAL CUSTOMERS
OF IDAHO POWER IN CASE NO.IPC-E-II-22 was served in the maner shown to:
Ms. Jean Jewell
Commssion Secreta
Idao Public Utilities Commssion
POBox 83720
Boise, il 83720-0074
jean.jewell(gpuc.dao.gov
X Hand Delivery
~ U.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
Lisa D Nordstrom
Jason B Wiliams
Idaho Power Company
POBox 70
Boise, Idaho 83707-0070
lnordstrom~idahopower.com
j willams(gidahopower. com
K Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
-- Electronic Mail
Timothy E Tatu
Cost of Service Manager
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
ttatu~idahopower.com
X Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
lLElectronic Mail
1a~