20150428Petition to Intervene.pdf

Peter J. Richardson ' I :j r'l 'r
ISB No. 3195
Gregory M. Adams iiliS {Pil 2E fl}f lf , i0
ISB No. 7454
Richardson Adams, PLLC .' r i-l'i i -- ;r '' ;, . ,, , i.
515 N. 27s Street \.'!'irJi '
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attomeys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMTSSION
IN THE MATTER OF THE APPLTCATION OF )
IDAHO POWER COMPANY FOR A ) CeSp NO. rpC-E-15-06
DETERMINATION OF 2014 DEMAND-SIDE )
MANAGEMENT EXPENDITURES AS ) PPTITTON TO INTERVENEPRUDENTLY TNCURRED ) OT THE INDUSTRIAL CUSTOMERS) op rDAHo PowER
)
COMES NOW, The tndustrial Customers of ldaho Power, hereinafter referred to as
"Intervenor," 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:
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]
Fax: [phone]
peter@richardsonadams. com
Copies of all pleadings, production requests, production responses, 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
dreading@mindsprine. com
2. This Intervenor, the Industrial Customers of ldaho 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' 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 [ntervenor 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-15-06
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 28e day of April,2015
zuCHARDSON ADAMS, PLLC
ICIP Intervention - IPC-E-15-06
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 20th day of April,2Dls, a true and correct copy of the within
and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER in DocketNo. IPC-E-15-06 was served electronically and by HAND
DELIVERY, tO:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street
Boise, Idatro 837 07 -007 0
lnordstrom@idahopower. com
dockets@ idahopower. com
Darlene Nemnich
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707-0070
dnemnich@idahopower. com
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,Idaho 83702
ieanj [e-mail]. eov
Benjamin J. Otto
Idaho Conservation League
710 N. 6th st.
Boise,Idaho 83702
Ph: (208) 345-6%3 xA
Fax [phone]
botto@idahoconservation. org
Nina Curtis
Administrative Assistant
ICIP Intervention - IPC-E-15-06