20130708Petition to Intervene.pdf

Peter J. Richardson
ISB No. 3195
Gregory M. Adams
ISB No. 7454
Richardson Adams
515 N.27rt Street
Boise,Idaho 83616
Telephone: [phone]
Fax: [phone]
Attomeys for Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF rDAHO POWER )
COMPANY'S APPLICATION FOR A ) CeSp NO. IPC-E-13-16
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR THE INVESTMENT ) PPUTION TO INTERVENEIN SELECTIVE CATALYTIC REDUCION ) OT THE INDUSTRIAL CUSTOMERSCONTROLS ON JIM BRIDGER UNITS 3 AND) OF IDAHO POWER4)
)
COMES NOW, The lndustrial Customers of Idaho 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 31.10.01074, 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:
lndustrial Customers of ldaho Power
c/o Peter J. Richardson
Richardson Adams
515 N. 27th Street
Boise, Idaho 83616
Telephone: [phone]
Fax: [phone]
ICIP Intervention - IPC-E-13-16
This Intervenor will be represented herein by:
Peter J. Richardson, Esq.
515 N. 27th 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]
dreadin g@mindsprin g. com
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 proceeding to determine the prudence of
installing new pollution control equipment at Idaho Power's Bridger Coal Plant will have direct
impact on the electric rates the industrial customers of Idaho Power will be assed.
This Intervenor, in its capacity as a representative of industrial consumer's interests,
intends to participate herein as a party, and if necessilry, to introduce evidence, cross-examine
witnesses, call and examine witnesses, and be heard in argument. The nature and quality of
Intervention - IPC-E-13-16
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 Intervenor would be without any means
of participation in this proceeding to determine the status of Idaho Power's demand response
progftrms 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
Intervenor 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 maffers 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 8th day of Ju1y,2013.
Attorney for the Industrial Customers
of Idaho Power
Intervention - IPC-E-13-l 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th day of June,2013, a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER, Case No. IPC-E-13-16, was served by electronic mail and U.S. Mail, postage
prepaid, to:
Lisa D. Nordstrom
Idaho Power Company
1221 West Idatro Street (83702)
PO Box 70
Boise, Idaho 83707 -0070
E-mail : lnordstrom@ idahopower. com
Jennifer Reinhardt-Tess,er
Idaho Power Company
1221 West Idatro Street (83702)
PO Box 70
Boise, Idaho 837 07 -0070
E-mail : cwaites@ idahopower. com
ttatum@ idahopower. com
(h4,rrrt-r
Nina Curtis
Legal Assistant
lntervention - IPC-E-13- I 6