20161206Petition to Intervene.pdf

Peter J. Richardson
ISB No. 3195
Gregory M. Adams
ISB No. 7454
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Richardson Adams, PLLC
515 N. 2ih Street
P.O. Box 7218
Boise, Idaho 83 702
Telephone: [phone] Tel
Fax: [phone] Fax
[e-mail]
Attorneys for the Industrial Customers of Idaho Power
I .. ,! ~) COMM! S!ON
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE RA TES DUE )
TO REVISED DEPRECIATION RA TES FOR )
ELECTRIC PLANT-IN-SERVICE )
)
) ________________ )
CASE NO. IPC-E-16-23
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 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 proceeding in that its members' rates for electrical services for Idaho Power's
benefit 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 receive for voluntary curtailment of electrical services for Idaho Power's benefit.
6. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case. The ICIP acknowledges this Petition is less than one
Intervention -IPC-E-16-23 2
full day out of time due to an internal calendaring error. Nevertheless, no proceedings have yet
to occur and granting this petition will not delay the efficient prosecution of this matter.
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 6TH day of December 2016.
Richardson Adams, LLP
By 9~~
Peter J. Richardson
Industrial Customers of Idaho Power
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of December, a true and correct copy of the within and
foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER in Case No. IPC-E-16-23 was served by HAND DELIVERY, to:
Lisa Nordstrom
Matt Larkin
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83 707-0070
[e-mail]
[e-mail]
Intervention -rPC-E-16-23 3
Anthony Y ankel
12700 Blake Ave. Unit 2505
Lakewood, OH 44107
[e-mail]
Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing A venue, Suite I 00
PO Box 6119
Pocatello, ID 83205
[e-mail]
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
4 72 West Washington
Boise, Idaho 83702
Kandi Walters
Administrative Assistant
Intervention -IPC-E-16-23 4