20121114Petition to Intervene.pdf

t' RECEIVED
20I2NOV1+ PMLI+O
intnr41,uJ1r & IDAHO PUU-Lk'-' ATTORNEYS AT LAW bTIL3COMMSSIO
Tel: [phone] Fax: [phone]
P.O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, ID 83702
14 November 2012
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
P 0 Box 83720
Boise ID 83720-0074
RE: Case NoIPC-E-12-24
Dear Ms. Jewell:
Enclosed please find an original and 7 (seven) copies of the PETITION TO
INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER in the
above case.
I have also enclosed an extra copy to be service-dated and returned to us for
our files. Thank you.
Sincerely,
&'(Jvt~k
Nina Curtis
Administrative Assistant
end.
RECEVrD
Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richardson & O'Leary, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
reg(richardsonandoleary.com
Attorneys for the Industrial Customers of Idaho Power
2012 NOV I4 PM I: LO
IDAHO PJ8L!ry
UTILITIES COMMISSIO N
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
)
IN THE MATTER OF THE APPLICATION OF)
IDAHO POWER COMPANY FOR )
AUTHORITY TO IMPLEMENT RATES FOR )
ELECTRIC SERVICE TO INCLUDE )
CAPITALIZED CUSTOM EFFICIENCY )
INCENTIVE PAYMENTS
CASE NO. IPC-E-12-24
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
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. 27' St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(richardsonando1earv.com
PETITION TO INTERVENE
IPC-E- 12-24
Copies of all pleadings, production requests, production responses, commission orders,
and other documents should be provided to:
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Telephone: [phone]
Fax: [phone]
dreading(mindspring.com
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 27" Street
P.O. Box 7218
Boise, ID 83702
Telephone: [phone]
Fax: [phone]
peter(richardsonandolearv.com
gregrichardsErnandolearv.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.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- 12-24
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 14th day of November, 2012.
RICHARDSON AND O'LEARY, PLLC
By: ,CkL
~~eter J. Richardson
Gregory M. Adams
Attorneys for the Industrial
Customers of Idaho Power
3
PETITION TO INTERVENE
IPC-E- 12-24
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of November, 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-12-24 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
Idaho Power Company XU.S. Mail, postage pre-paid
P0 Box 70 Facsimile
Boise, Idaho 83707-0070 Electronic Mail
[e-mail]
[e-mail]
Matt Larkin Hand Delivery
Greg Said XU.S. Mail, postage pre-paid
Idaho Power Company - Facsimile
P0 Box 70 Electronic Mail
Boise, Idaho 83707-0070
[e-mail]
gsaididahopower.com
Nina M. Curtis