20140703Petition to Intervene.pdf

Peter J. Richardson ISB No. 3195
Gregory M. Adams ISB No. 7454
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone] Tel
Fax: [phone]Fax
peter@richardsonadams. com
Attorneys for the Industrial Customers of Idatro Power
RTCEIVriI
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSTON
IN THE MATTER OF THE COMMISSION'S
TNQUIRY INTO IDAHO POWER
COMPANY'S FIXED COST ADJUSTMENT
MECHANISM
CASE NO. IPC.E-T4-17
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The lndustrial Customers of Idaho 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 Intervenor is:
lndustrial Customers of ldaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 276 St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
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
(208) 342-t700Tel
[phone] Fax
dreading@mindspring. com
2. This Intervenor, the Industrial Customers of Idaho Power, ("[CIP") is an
unincorporated association of Schedule 19 customers of Idaho Power. All ICIP members receive
electric utility services from Idaho Power Company. The ICIP claims a direct and substantial
interest in this proceeding in that its members' electric rates 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 pay for electric services.
6. Granting this lntervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
ICIP lntervention - trC-E-14-17
WHEREFORE, the Industrial Customers of ldaho 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 3rd day of July,2014.
Richardson Adams, LLP
Peter J. Richardson
Industrial Customers of Idatro Power
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3m day of July ,2014, a true and correct copy of the within
and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER in DocketNo. IPC-E-14-17 was served by HAND DELIVERY, to:
Dockets
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707 -0070
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,Idaho 83702
Administrative Assistant
ICIP Intervention - IPC-E-14-1 7