20150420Petition 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]
Fax: [phone]
peter@richardsonadams. com
Attorneys for the [ndustrial Customers of Idaho Power
i'i.,1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER
COST ADJUSTMENT (*PCA") RATES FOR
ELECTRIC SERVICE FROM JUNE I,2OI5,
THROUGH MAY 31,2016.
CASE NO. IPC.E-I5-I4
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of ldaho Power, hereinafter referred to as
"Intervenor," and pursuant to this Commission's Rules of Procedure, Rule 71 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 Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27& 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
dreadin g@mindsprin g. com
2. This Intervenor, the Industrial Customers of Idaho Power, ("[CIP") is an
unincorporated association of Schedule l9 customers of Idaho Power. All ICIP members receive
electric utility services from ldaho Power Company. The ICIP claims a direct and substantial
interest in this proceding 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 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 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-15-14
WHEREFORE, the Industrial 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 20ft day of April,2}ls
Peter J. Richardson
RICHARDSON ADAMS, PLLC
ICIP Intervention - IPC-E-I5-14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 20th day of April, 2015, a true and correct copy of the within
and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER in DocketNo. IPC-E-15-14 was served electronically and by HAND
DELIVERY, tO:
LisaNordstrom
Regulatory Dockets
Idaho Power Company
1221 West Idatro Street
Boise, Idalro 83707 -007 0
[e-mail]
dockets@idatropower. com
Timothy E. Tatum
Gregory W. Said
Idaho Power Company
l22l West Idatro Street
Boise, Idatro 837 07 -007 0
ttatum@ idahopower. com
[e-mail]
Jean Jewell
Commission Secretary
Idatro Public Utilities Commission
472West Washington
Boise,Idatro 83702
i ean j [e-mail]. gov
Qru^C,,.n+,:
Nina Curtis
Administrative Assistant
ICIP Intervention - IPC-E-I5-14