20150723Petition to Intervene.pdf

Peter J. Richardson ISB No. 3195
Gregory M. Adams tSB No. 7454
Richardson Adams, PLLC
515 N.27th Street
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadams. com
Attomeys for the Industrial Customers of tdaho Power
I,:lii Jitj
t.
-- i.l
CASE NO. IPC-E-15.17
PETITION TO TNTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
?;i Pr1'f l: lg
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
TN THE MATTER OF THE APPLICATION OF )IDAHO POWER COMPANY FOR
APPROVAL OF LONG.TERM
MAINTENANCE PROGRAM CONTRACT )WITH SIEMENS ENERGY, SALE OF SPARE )
PARTS TNVENTORY TO SIEMENS ENERGY,)
AND DEFERRAL OF ASSOCIATED COSTS )
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:
1. The name and address of this Intervenor is:
lndustrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27tr St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] I
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
dreadine(@ mindsprin g. co m
2. This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule l9 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 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.
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
ICIP Intervention - IPC-E-15-17
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.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on ttre ASeo day of July,2}l5,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-15-17 was served electronically and by HAND
DELIVERY, tO:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707 -0070
lnordstrom@ idahopower. com
dockets@ idahopower. com
Timothy E. Tatum
Gregory W. Said
Idaho Power Company
1221 West ldaho Steet
Boise, Idalro 83707 -0070
ttatum@ idahopower. com
[e-mail]
ff.t J,tta-O r lfr\
Nina Curtis
Administrative Assistant
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington St.
Boise, tdaho 83702
j eanj [e-mail]. gov
RICHARDSON ADAMS, PLLC
ICIP Intervention - IPC-E-15-17