20151215Petition to Intervene.pdf

Peter J' tuchardson ISB No' 3195 REcEluiir
Gregory M. Adams ISB No. 7454
Richardson Adams, PLLC 2{l1$ ntC 15 Pl'l hr 38
5l5N.27thStreet ,nAir..r _rri,,.p.o. Box 7218 uiurTlHs"C'iii;r$sloHrBoise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attomeys for the Industrial Customers of ldaho Power
BEFORE THE
TDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )IDAHO POWER COMPANY FOR AN ORDER) CASE NO. IPC-E-15-26
APPROVING THE TRANSFER AND SALE ) PEUTION TO INTERVENE
OF CERTAIN ASSETS TO THE UNITED ) OT THE INDUSTRIAL CUSTOMERS
STATES DEPARTMENT OF JUSTICE ) Op IDAHO pOWER
FEDERAL BUREAU OF INVESTIGATION. )
)
COMES NOW, The lndustrial Customers of Idaho Power, hereinafter referred to as
"lnteryenor," 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. 27h 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
dreadin g@mindsprins. com
2. This Intervenor, the Industrial Customers of ldaho Power, ("IC[P") 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 are interested in the administration and application
of Idaho Power's Rule M as its members have an interest in Idaho Power owned facilities
beyond the point of delivery. In addition the ICIP members are interested as to the impact of the
administration of Rule M on Schedule l9 retail rates.
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-15-26
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.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the l5th day of December, 2015, a true and correct copy of the
within and foregoing PETITION TO TNTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER in Docket No. IPC-E-15-26 was served electronically and by HAND
DELIVERY, tO:
Lisa Nordstrom
Shelli D. Stewart
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 837 07 -0070
lnordstrom@idahopower. com
sstewart@ idahopower.com
Tami White
Idaho Power Company
l22l West Idaho Street
Boise, Idaho 83707 -0070
twhite@idahopower. com
Nina Curtis
Administrative Assistant
Jean Jewell
Idaho Public Utilities Commission
472West Washington St.
Boise,Idaho 83702
i ean. i ewell@puc. idaho. gov
DATED thi December,20l5
J.
RICHARDSON ADAMS, PLLC
ICIP Intervention - IPC-E-15-26