20130419Petition to Intervene.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
greg(richardsonandoleary.com
2O13 RAN I9 AHII:146
TjTfts ij
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. IPC-E-13-10
APPLICATION OF IDAHO POWER )
COMPANY FOR AUTHORITY TO ) PETITION TO INTERVENE OF THE
IMPLEMENT POWER COST ) INDUSTRIAL CUSTOMERS OF
ADJUSTMENT MECHANISM ("PCA") ) IDAHO POWER
RATES FROM JUNE 1, 2013 THROUGH )
MAY 31, 2014
COMES NOW the Industrial Customers of Idaho Power, herein referred to as
"Intervenor" and pursuant to this Commission's Rules of Procedure, Rule 71 IDAPA
31.01.01.74 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 of this Intervenor is:
Industrial Customers of Idaho Power
do Peter J. Richardson
Richardson & O'Leary, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Tel. [phone]
Fax [phone]
[e-mail]
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
Tel. [phone]
Fax [phone]
dreadingmindspring.com
and electronically to:
greg(richardsonandoleary.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 their rates for service from Idaho Power 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 any
means of participation in this proceeding which may have a material impact on its members'
electric rates and terms and conditions of service.
Granting this Intervenor's petition to intervene will not unduly broaden the issues
PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
IPC-E-13-10
PAGE 2
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 and to otherwise fully participate in these proceedings.
DATED this 19 day of April 2013.
Richa son S O'Leary, PLL4C
By 1? L
Peter J. Ric ardson
Industrial Customers of Idaho Power
CERTIFICATE OF SERVICE
I hereby certify that on April 16, 2012, copies of the foregoing Petition to Intervene of the
Industrial Customers of Idaho Power were hand delivered to:
Lisa Nordstrom
Idaho Power Company
1221 West Idaho
Boise, Idaho 83702
ma Curtis
Administrative Assistant
Timothy E. Tatum
Gregory Said
Idaho Power Company
1221 West Idaho
Boise, Idaho 83702
Jean Jewel
Secretary
Idaho Public Utilities Com'n
472 West Idaho
Boise, Idaho 83702
PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
IPC-E-13-10
PAGE 3