20150209Petition to Intervene.pdf

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RICIIARIISON AD.AMS, er,rr
ATTORNEYS AT LAV
Peter J. Richardson
Tcl: 208-938-7901 Fax: [phone]{
pctc r@ richardsonadams. co m
P.O. Box 7218 Boisc, lD 83707 - 5lt N.27th St. Boisc. lD 83702
February 10,2015
Jean Jewell, Commission Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise, Idaho 83702
Corrected Cover Page - ICIP Petition to Intervene IPC-15-03
Dear Ms. Jewell:
Enclosed you will find an original and seven copies of replacement page one of the
Petition to Intervene filed yesterday by the Industrial Customers of ldaho Power in the
above referenced matter. Would you please substitute the enclosed for the page one that
was filed yesterday as it contains an incorrect address for our law firm. Thank you for
your attention to this matter.
Very truly yours,
Re:
P-qw
Peter J. Richardson
Richardson Adams, PLLC
Cc: Lisa Nordstrom
Tami White
Quentin Nesbitt
Idaho Power Company
l22l West Idaho Street
Boise, Idaho 83702
Peter J. Richardson (ISB No. 3195)
Greg Adams (lSB 7454)
Richardson Adams, PLLC
515 N.27ft Street
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF NEW TARIFF
SCHEDULE 82, A COMMERCIAL AND
INDUSTRIAL DEMAND RESPONSE
PROGRAM (FLEX PEAK PROGRAM).
CASE NO. IPC-E-I5-03
PETTTION TO INTERVENE
OF THE INDUSTRTAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of [daho Power, hereinafter referred to as
"Intervenor," 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 Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N.27tr St
P.O. Box 7218
Boise,ldaho 83702
Telephone: [phone] I
Fax: [phone]
[e-mail]
Intervention - IPC-E-I5-03
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] Tel
(208) 384-l5ll Fax
dreading@mindspring. com
2. This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule 19 customers of ldaho 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 the outcome will affect its members' participation in the
demand reduction program designed for industrial customer use.
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, submit comments, and
fully participate in any hearing that may occur including the calling and cross examination of
witnesses. 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
effective means of participation in this proceeding which may have a material impact on its
members' participation in demand reduction programs offered by Idaho Power.
Intervention - IPC-E-l 5-03
6. Granting this lntervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
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 at any hearing that may occur, and to otherwise fully participate in
these proceedings.
DATED this 9th day of February 2015.
Richardson Adams, PLLC
Industrial Customers of Idaho Power
lntervention - IPC-E-I 5-03
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the fth day of February, 2015, a true and correct copy of
the within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER, in Docket No. IPC-E-15-03 was served as indicated below to:
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
P O Box 83720
Boise lD 83720-0074
Lisa D. Nordstrom
Idaho Power Company
l22l West Idaho Street
Boise, Idalro 83707 -007 0
lnordstrom@ idahopower. com
dockets@ idahopower. com
Tami White
Quentin Nesbitt
Idaho Power Company
1221 West ldaho Street
Boise, Idaho 83702
twhite@ idahopower. com
qnessbitt@ idahopower. com
[_ Hand Delivery
_ U.S. Mail, postage pre-paid
_ Facsimile
_ Electronic Mail
X Hand Delivery
_ U.S. Mail, postage pre-paid
_ Facsimile
_ Electronic Mail
_ Hand Deliver
X_U.S. Mail, postage pre-paid
_Facsimile
X_ Electronic Mail
O, 4,trtt,
Nina Curtis
Administrative Assistant
Intervention - IPC-E-l 5-03