20160414Petition to Intervene.pdf

Peter J. Richardson ISB No. 3195 Rf CEIVED
Gregory M. Adams ISB No. 7454
Richardson Adams, PLLC ?016 RPR lt+ Pll 2:22
515 N. 27th Street i- : ,: , I lji>LiC
P.O. Box 7218 i': ' il rl,-)liill$Sl0l'J
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMTSSION
IN THE MATTER OF THE APPLICATION OF )IDAHO POWER COMPANY FOR ) CeSp NO. IpC-E-t6-07
AUTHORITY TO TRANSFER TITLE OF ) pprnION TO INTERVENEMOBIL MANOR MOBILE HOME PARK ) OT THE TNDUSTRIAL CUST9MERS
METER PEDESTALS.. ) op IDAHO PowER
)
)
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:
Industrial Customers of ldaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27ft 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@mindsprin g.com
2. This Intervenor, the Industrial Customers of ldaho 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 are interested in, and directly impacted by, the
administration and application of Idaho Power's rules, policies and practices as they impact the
sale, disposal, operation, maintenance and cost of ldaho Power owned facilities beyond the point
of delivery. In addition, the ICIP members are interested in the potential discriminatory impact
of the sale, disposal, operation, maintenance and cost of ldaho Power owned facilities beyond the
point of delivery that are not governed by the administration of Rule M versus those that are
govemed by the administration of Rule M.
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
means of participation in this proceeding
members pay for electric service.
ICIP Intervention - IPC-E-16-07
intervene herein, this Intervenor would be without any
which may have a material impact on the rates its
6. Granting this Intervenor's petition to intervene
nor will it prejudice any party to this case.
not unduly broaden the issues
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
Peter J. Richardson
RICHARDSON AU$MS, PLLC
CERTTFTCATE OF SERVICE
I HEREBY CERTIFY that on the l4th day of April,20l6, 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-16-07 was served electronically and by HAND
DELIVERY, tO:
Julia A. Hilton
Matt Larkin
Idaho Power Company
l22l West Idaho Street
Boise, Idaho 83707 -0070
j hilton@idahopower. com
mlarkin@idahopower. com
dockets@idahopower. com
Nina Curtis
Administrative Assistant
Jean Jewell
Idaho Public Utilities Commission
472West Washington St.
Boise, Idaho 83702
i ean j [e-mail]. gov
l4th day of April,20l6
ICIP Intervention - IPC-E-16-07