20140417Petition 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
[e-mail]
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
TN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR ) CaSe NO. IPC-E-14-05
AUTHORITY TO TMPLEMENT POWER )
COST ADJUSTMENT ("PCA") RATES FOR ) peUUON TO INTERVENEELECTRIC SERVICE FROM JUNE I,2OI4, ) OP THE TNDUSTRIAL CUSTOMERSTHROUGH MAY 31,2015, AND TO UPDATE ) OF IDAHO pOWER
BASE RATES TN COMPLIANCE WITH )
oRDER NO. 33000 )
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
3l .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 Intervenor 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]
oeter@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, tdaho 83703
[phone]Tel
[phone] Fax
dreadin g@m indsprin g.com
2. This Intervenor, the Industrial Customers of ldaho Power, ("ICIP") is an
unincorporated association of Schedule l9 customers of ldaho Power. All ICIP members receive
electric utility services from [daho Power Company. The ICIP claims a direct and substantial
interest in this proceeding in that its members' rates for electric service 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 lntervenor 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 pay for electric service.
6. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
ICIP Intervention - IPC-E-14-05
WHEREFORE, the Industrial Customers of Idaho 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 17fr day of April,2014.
Richardson Adams, LLP
Peter J. Richardson
Industrial Customers of tdaho Power
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the lTth day of April,2Dl4, a true and correct copy of the within
and foregoing PETITION TO TNTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER in DocketNo. IPC-E-14-05 was served by HAND DELIVERY, to:
Lisa Nordstrom
Timothy E. Tatum
Idaho Power Company
l22l West Idaho Street
Boise, Idaho 837 07 -007 0
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
Nina Curtis
Administrative Assistant
ICIP Intervention - IPC-E-14-05