20120412Petition to Intervene.pdf

RECEIVED
Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454) 2U1? APR 12 PM 3. 1+8
Richardson & O'Leary, PLLC iLR
515 N. 27th Street UTILITIES COMMISSION
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
gregrichardsonando1earv.com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
)
IN THE MATTER OF THE APPLICATION OF) CASE NO. IPC-E-12-15
IDAHO POWER COMPANY FOR A )
DETERMINATION OF 2011 DEMAND-SIDE ) PETITION TO INTERVENE
MANAGEMENT ("DSM") EXPENDITURES ) OF THE INDUSTRIAL CUSTOMERS
AS PRUDENTLY INCURRED. ) 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
participate herein as a party, and as grounds therefore states:
1. The name and address of this Intervenor is:
Industrial Customers of Idaho Power
do Peter J. Richardson
Richardson & O'Leary, PLLC
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
1
PETITION TO INTERVENE
IPC-E- 12-15
Copies of all pleadings, production requests, production responses, commission orders,
and other documents should be provided to
Dr. Don Reading Peter J Richardson
6070 Hill Road Gregory M. Adams
Boise, Idaho 83703 Richardson & O'Leary, PLLC
Telephone: [phone] N. 27th Street
Fax [phone] P.O.Box 7218
[e-mail] Boise, ID 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
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 This Intervenor, in its capacity as a representative of industrial customers, intends
to participate herein as a party, and if necessary, to introduce evidence, cross-examine witnesses,
call and examine witnesses, and be heard in argument The nature 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 participation 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- 12-15
WHEREFORE, the Industrial Customers of Idaho Power respectfully requests that this
Commission grant its Petition to Intervene in these proceedings and to appear and participate in
all matters as may be necessary and appropriate, and to present evidence, call and examine
witnesses, present argument and to otherwise fully participate in these proceedings.
DATED this 12 th day of April, 2012
RICHARDSON AND O'LEARY, PLLC
By____
Peter J Richardson
Gregory M Adams
Attorneys for the Industrial
Customers of Idaho Power
3
PETITION TO INTERVENE
IPC-E-12-15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 12th day of April, 2012, a true and correct copy of the
within and foregoing PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER IN CASE NO IPC-E-12-15 was served in the manner shown to
Ms. Jean Jewell X Hand Delivery
Commission Secretary U.S. Mail, postage pre-paid
Idaho Public Utilities Commission - Facsimile
P 0 Box 83720 - Electronic Mail
Boise, ID 83720-0074
Lisa D Nordstrom - Hand Delivery
Julia A Hilton X_U S Mail, postage pre-paid
Idaho Power Company - Facsimile
P0 Box 70 X Electronic Mail
Boise, Idaho 83707-0070
1nordstromidahopower corn
jhilton@idahopower corn
Darlene Nemnich - Hand Delivery
Greg Said X U S Mail, postage pre-paid
Idaho Power Company - Facsimile
P0 Box 70 X Electronic Mail
Boise, Idaho 83707-0070
dnemnich(@idahopower.com
gsaidClidahot,ower.com
no /1'. 6 A