20140317Petition to Intervene.pdf

:i:"r i'':l ij i""?z72
Peter J. Richardson
ISB No. 3 195
Gregory M. Adams ' '
ISB No.7454
Richardson Adams, PLLC
515 N. 27tr Street
P.O. Box 7218
Boise,ldaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
[e-mail]
Attorneys for the Industrial Customers of ldaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY,S APPLICATION FOR ) CESE NO. IPC-E-14-02
APPROVAL OF ITS AGREEMENT WITH )
ENERNOC, NC., TO IMPLEMENT AND ) peftUON TO INTERVENEOPERATE A VOLUNTARY COMMERCIAL ) OF THE INDUSTRIAL CUSTOMERSDEMAND RESPONSE PROGRAM ) Op IDAHO pOWER
)
)
COMES NOW, The Industrial Customers of ldaho Power, hereinafter referred to as
"lntervenor," and pursuant to this Commission's Rules of Procedure, Rule 7l 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:
l. The name and address of this lntervenor is:
Industrial Customers of ldaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th st
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] I
Fax: [phone]
[e-mail]
Copies of all pleadings, production requests, production resoponses, Commission orders
and other documents should be provided to Peter Richardson as noted above and to:
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
[e-mail]
2. This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule l9 customers of Idaho Power. All ICIP members receive
electric utility services from ldaho Power Company. The ICIP claims a direct and substantial
interest in this proceeding in that its members' rates for voluntary curtailment of electrical
services for ldaho Power's benefit 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.
5. 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 the rates its
members receive for voluntary curtailment of electrical services for Idaho Power's benefit.
6. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
lntervention - IPC-E-14-02
WHEREFORE, the Industrial Customers of [daho 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 17tr day of March,2Ol4.
Richardson Adams, LLP,,Mfu
Peter J. Richardson
Industrial Customers of Idaho Power
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 17th day of March, 2014, a true and correct copy of the within
and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER was served by HAND DELIVERY, to:
Julia Hilton
Tami White
Idaho Power Company
l22l West Idaho Street
Boise, ldaho 83707 -0070
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,ldaho 83702
[}rr,o-nl 4 ' ^.0=,'Nina Curtis
Administrative Assistant
Intervention - IPC-E-14-02