20160919Petition to Intervene.pdf

Peter J. Richardson ISB No. 3195
Gregory M. Adams ISB No. 7454
Richardson Adams, PLLC
515 N. 2ih Street
P.O. Box 7218
Boise, Idaho 83 702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for the Industrial Customers of Idaho Power
OF CEIVED !'\-
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
IDAHO POWER COMPANY FOR DEFERRAL)
AND RECOVERY COSTS AS SOCIA TED )
WITH PARTICIPATION IN AN ENERGY )
IMBALANCE MARKET. )
) _________________ )
CASE NO. IPC-E-16-19
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"Intervenor," and pursuant to this Commission's Rules of Procedure, Rule 71 IDAPA
31.01.01.71 and pursuant to that Notice of Application and Notice of Intervention Deadline
issued in Commission Order No. 33595 on September 13, 2016, and 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:
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 2ih St
P.O. Box 7218
Boise, Idaho 83 702
Telephone: [phone]
Fax: [phone]
[e-mail]
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 83 703
[phone] Tel
[phone] Fax
[e-mail]
2. This Intervenor, the Industrial Customers ofldaho 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 matter 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.
4. 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.
5. 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-16-19 2
WHEREFORE, the Industrial Customers ofldaho 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 19th day of September, 2016 rxo~~
Peter J. Richardson
RICHARDSON ADAMS, PLLC
ICIP Intervention -IPC-E-16-19 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of September, 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-16-19 was served electronically and
by HAND DELIVERY, to:
Julia Hilton
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83 707-0070
[e-mail]
[e-mail]
Matthew T. Larkin
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83 707-0070
[e-mail]
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
4 72 West Washington
Boise, Idaho 83 702
[e-mail]
Kandi Walters
Administrative Assistant
ICIP Intervention -IPC-E-16-19 4