20130319Petition to Intervene.pdf

R
Peter J. Richardson (ISB No. 3195)
Greg Adams (ISB 7454)
Richardson & O'Leary
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peterrichardsonando1eary.com
Attorneys for the Industrial Customers of Idaho Power
741TMiR 19 PH 3: 50
LD.AHC JLft.
UTILITIES CO;4MISso
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR )
APPROVAL OF ITS AGREEMENT WITH
ENERNOC TO IMPLEMENT AND ) OPERATE A VOLUNTARY COMMERCIAL)
DEMAND RESPONSE PROGRAM )
)
)
)
CASE NO. IPC-E-13-04
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, 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 as follows:
1. The name and address of this Intervenor is:
Industrial Customers of Idaho Power
do Peter J. Richardson
Richardson & O'Leary
515 N. 27" St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peterrichardsonandoleary.com
Intervention - IPC-E-13-04 1
Copies of all pleadings, production requests, production
responses, Commission orders and other documents should be
provided to Peter J. Richardson as noted above and to:
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreadingmindspring.com
2.This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule 19 customers of Idaho Power. All ICIP members receive
electric utility services from Idaho Power Company. The ICIP claims a direct and substantial
interest in this proceeding in that the outcome will affect the company's demand response
program for its industrial customers.
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, submit comments, and
fully participate in any hearing that may occur including the calling and cross examination of
witnesses. The nature and quality of evidence which this Intervenor will introduce is dependent
upon the nature and effect of other evidence in this proceeding.
5. Without the opportunity to intervene herein, this Intervenor would be without any
effective means of participation in this proceeding which may have a material impact on its
members' participation in Idaho Power's demand response program.
Intervention - IPC-E-08-13 2
6. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
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 at any hearing that may occur, and to otherwise fully participate in
these proceedings.
DATED this 19th day of March 20138.
Richardson & O'Leary, LLP
By
Peter J. Richardson
Industrial Customers of Idaho Power
Intervention - IPC-E-08-13 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of March, 2013, a true and correct
copy of the within and foregoing PETITION TO INTERVENE OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY IN CASE NO.
IPC-E-13-04 was served in the manner shown to:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
jean. jewell(puc.idaho.gov
Lisa D Nordstrom
Julia A Hilton
Idaho Power Company
P0 Box 70
Boise, Idaho 83707-0070
[e-mail]
jhilton@idahot,ower.com
X Hand Delivery
U.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
- Hand Delivery
XU.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
Signed
Nina Curtis