20160713Petition to Intervene.pdf

P.ECEIVED
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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
gre g@richardsonadams. com
Attorneys for the lndustrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR )APPROVAL OF NEW TARIFF SCHEDULE )
CASE NO. IPC-E-16-14
PETITION TO INTERVENE
OF THE INDUSTzuAL CUSTOMERS
OF IDAHO POWER
63, A COMMUNITY SOLAR PILOT
PROGRAM
)
)
)
)
COMES NOW, The lndustrial Customers of Idaho Power, hereinafter referred to as
"Intervenor," and pursuant to this Commission's Rules of Procedure, Rule 7l IDAPA
31.01.01 .71 and, pursuant to that Notice of Application and Notice of Intervention Deadline
issued by the Commission on July 7,2016, in Order No. 33552, 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. 27ft St
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@:ichardsonadams. 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 Intervenor, 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 its members' electric service options 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.
ICIP Intervention - IPC-E-16-14
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
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 l3s day of July,
RICHARDSON ADAMS, PLLC
ICIP Intervention - IPC-E-16-14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 13th day of July,2016, 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-16-14 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
Matt Larkin
Peter Pengilly
Idaho Power Company
l22l West Idaho Street (83702)
Boise, Idaho 83707 -0070
mlarkin@ idahopower. com
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6ft St.
Boise,Idatro 83702
[e-mail]
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,Idaho 83702
i [e-mail]. gov
Kandi Walters
Administrative Assistant
ICIP Intervention - IPC-E-16-14