20160414Petition to Intervene.pdf

Peter J. Richardson ISB No. 3195 lf |:CEiVED
Gregory M. Adams ISB No. 7454
Richardson Adams, PLLC :'':"1 l,,i-i ! b Pi'i 2: 23
515 N. 27th Street -. ; -: t.-il , i l
P.O. Box 7218 ,,'l;.1, 'riiS:CilBoise,Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATTON OF )PACIFICORP DBA ROCKY MOUNTAIN ) CESp NO. IPC-E-I6-06
POWER AND IDAHO POWER COMPANY ) pprtUON TO TNTERVENE
FOR AN ORDER AUTHORIZING THE ) OT THE INDUSTRIAL CUSTSMERSEXCHANGE OF CERTAIN TRANSMISSION ) Op IDAHO pOWERASSEETS. )
)
COMES NOW, The Industrial 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:
l. The name and address of this Intervenor is:
lndustrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th 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
[e-mail]
2. This lntervenor, the Industrial Customers of Idaho Power, ("ICIP") 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 the outcome will likely affect the company's electric rates for
its industrial customers.
3. This [ntervenor, 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-16-06
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 l4th day of April,20l6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of April,20l6, a true and conect copy of the within
and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER in Docket No. IPC-E-16-06 was served electronically and by HAND
DELIVERY, tO:
Julia Hilton
Tim Tatam
Idaho Power Company
l22l West tdatro Street
Boise, Idaho 83707-0070
i hilton@ idahopower.com
ttatum@ idahopower.com
and by U.S. Mail postage prepaid and electronically to:
Daniel E. Solander
Yvonne R. Hogle
Rocky Mountain Power
201 South Main St., Ste. 2400
Salt Lake City, UT 83707
Daniel. solander@pacifi corp. com
Yvonne.ho [e-mail]
Jean Jewell
Daphne Haung
472 West Washington St.
Boise, Idaho 83702
i ean [e-mail]. gov
daphne.huan g@puc. idaho. eov
Peter J. Richardldn
RICHARDSON ADAMS, PLLC
f ), (rtt$-+
Nina Curtis
Administrative Assistant
ICIP Intervention - IPC-E-16-06