20131106Petition to Intervene.pdf

Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (lSg No. 7454i) ijl' lii,r -'.= i'i 3: ?5
Richardson Adams, PLLC
515 N.27th Street , 'i' i
Boise, tdaho 83616
Telephone: [phone]
Fax: [phone]
Attorneys for Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-13-20
AUTHOzuTY TO ESTABLISH A NEW BASE )
LEVEL OF NET POWER SUPPLY EXPENSE ) pprtUON TO INTERVENE) OP THE INDUSTRIAL CUSTOMERS) op rDAHo PowER
)
)
COMES NOW, The lndustrial Customers of Idaho Power, hereinafter referred to as
"Intervenor,'o and pursuant to this Commission's Rule of Procedure, Rule 071, IDAPA
3 I .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:
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27ft Street
Boise, Idaho 83616
Telephone: [phone]
Fax: [phone]
ICIP Intervention - IPC-E-13-20
This Intervenor will be represented herein by:
Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (tSB No. 7454)
Richardson Adams, PLLC
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]
[e-mail]
This Intervenor, the lndustrial Customers of ldaho 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 the outcome of this case will have direct impact on their electric rates.
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 Intervenor would
be without any meaningful opportunity to participate in this proceeding.
Intervention - IPC-E- I 3-20
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 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 November, 2013.
zuCHARDSON ADAMS, PLLC
Attorney for the Industrial Customers
of Idaho Power
Intervention - IPC-E- I 3 -20
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5th day of November,2}l3,a true and correct copy of
the within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER, Case No. IPC-E-13-20, was served by electronic mail and U.S. Mail,
postage prepaid, to:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472West Washington
Boise,ID 83702
[e-mail]. gov
Lisa D. Nordstrom
Idaho Power Company
l22l West Idaho Street (83702)
PO Box 70
Boise, Idaho 83707 -0070
E-mail : [e-mail]
dockets @idahopower. com
Tim Tatum
Idaho Power Company
l22l West Idatro Street (83702)
PO Box 70
Boise, Idaho 83707 -0070
E-mail : [e-mail]
Nina Curtis
Legal Assistant
Intervention - IPC-E-13-20