20130606Petition to Intervene.pdf

Peter J. Richardson
ISB No. 3195
Richardson & O'Leary
515 N.27th Street
Boise, Idaho 83616
Telephone: [phone]
Fax: [phone]
Attomey for Industrial Customers of Idaho Power
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE CONTINUATION )
OF IDAHO POWER COMPANY'S A/C COOL )
CREDIT, IRRIGATION PEAK REWARDS, )AND FLEXPEAK DEMAND RESPONSE )PROGRAMS FOR 2014 AND BEYOND )
)
)
CASE NO. IPC-E-13-14
PETTTION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF TDAHO POWER
COMES NOW, The Industrial Customers of ldaho Power, hereinafter referred to as
"Intervenor," and pursuant to the Notice of Informal Prehearing Conference in this matter, and
pursuant to this Commission's Rule of Procedure, Rule 071 , IDAPA 3 I . I 0.01 074, 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:
The name and address of this Intervenor is:
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson & O'Leary
515 N. 27& Street
Boise,Idaho 83616
Telephone: [phone]
Fax: [phone]
ICIP Intervention - IPC-E-13-14
This Intervenor will be represented herein by:
Peter J. Richardson, Esq.
515 N. 27ft Street
Boise,Idaho 83616
Telephone: [phone]
Fax: [phone]
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]
dreadine@mindsprin g. som
This Intervenor, the Industrial Customers of Idaho Power, is an unincorporated
association of large industrial consumers of electricity. All of the members of the Industrial
Customers of Idaho Power receive electric utility services from the Applicant under Tariff
Schedule 19. These industrial consumers claim a direct and substantial interest in this
proceeding in that their ability to participate in the FlexPeak and/or other similar demand
response progftrms for industrial customers of ldaho Power will be directly affected.
This Intervenor, in its capacity as a representative of industrial consumer's interests,
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.
Without the opportunity to intervene herein, this lntervenor would be without any means
of participation in this proceeding to determine the status of Idaho Power's demand response
Intervention - IPC-E-l 3-l 4
programs as they impact the industrial class of customers, and this Intervenor would be unable to
participate in proceedings which may have a material impact on its electric rates.
Although not required by this Commission's Rules, the multiple representation by this
lntervenor of its members' interests will prevent duplication of effort and aid in the
administration of these proceedings.
WHEREFORE, the Industrial Customers of Idaho Power request 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 6th day of June,2013.
Richardson & O'Leary, LLP
Peter J. Richardson
Attorney for the Industrial Customers
of Idatro Power
Intervention - IPC-E- I 3-14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of June,2073, a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER, Case No. IPC-E-13-14, was served by electronic mail and U.S. Mail, postage
prepaid, to:
Lisa D. Nordstrom
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street (83702)
PO Box 70
Boise, Idaho 83707 -0070
E-mail : lnordstrom@idahopower. com
Courtney Waites
Tim Tatum
Idaho Power Company
l22l West Idaho Street (83702)
PO Box 70
Boise, Idaho 83707 -0070
E-mail : cwaite s@idahopower. com
ttatum@ idahopower. com
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472West Washington Street (83702)
PO Box 83720
Boise,Idaho 83720
E-mail don.howell@puc. idaho. gov
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chartered
201E. Center Street
PO Box 1391
Pocatello, Idaho 83204-139 I
E-mail [e-mail]
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
E-mail ton),@yankel.net
Intervention - IPC-E- I 3-14
Ken Miller
Snake River Alliance
PO Box 1731
Boise,Idaho 83701
E-mail: [e-mail]
(),u^anou
Nina Curtis
Legal Assistant
Intervention - IPC-E- I 3- 14