20140319Petition to Intervene.pdf

Peter J. Richardson
ISB No. 3195
Gregory M. Adams
ISB No. 7454
Richardson Adams, PLLC
515 N. 27tr Street
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
peter@richardsonadams. com
Attorneys for the Industrial Customers of ldaho Power
BEFORE TI{E
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF APPLICATION OF
TDAHO POWER COMPANY FOR A
DETERMINATION OF 2OI3 DEMAND.SIDE
MANAGEMENT ("DSM") EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. IPC.E.I4.O4
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
'olntervenor," 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:
1. The name and address of this Intervenor is:
lndustrial Customers of tdatro Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27n St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadams. com
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 tntervenor, the tndustrial Customers of ldatro Power, ("ICIP") is an
unincorporated association of Schedule 19 customers of Idatro Power. All ICP members receive
electric utility services from Idaho Power Company. The ICIP claims a direct and substantial
interest in this proceeding in that its members' rates for electrical services from Idaho Power
may be directly 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 lntervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
lntewention - IPC-E-14-04
WHEREFORE, the lndustrial Customers of Idaho Power respectfully requests that this
Commission grant its Petition to lntervene 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 19ft day of March,z}l4.
Richardson Adams, LLP
,rP'{ 'n
Peter J. Richardson
Industrial Customers of ldaho Power
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of March,20l4, a true and correct copy of the within
and foregoing PETITION TO INTERVENE BY THE INDUSTzuAL CUSTOMERS OF
IDAHO POWER was served by HAND DELIVERY, to:
Julia Hilton
Darlene Nemnich
Idaho Power Company
1221 West ldaho Street
Boise, Idatro 83707 -0070
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,Idatro 83702
Intervention - trC-E-14-04