20161201Petition to Intervene.pdf

Brian T. Hansen, ISB No. 6087
HOLLAND & HART LLP
800 W. Main Street, Suite 1750
Boise, Idaho 83 702
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
HOLLAND & HART LLP
6380 South Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
1 ::CE IVED
2016 or:c -I PM 3: OB
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-16-23
OF IDAHO POWER COMPANY )
FOR AUTHORITY TO INCREASE ITS ) PETITION TO INTERVENE
RATES DUE TO REVISED DEPRECIATION ) OF MICRON TECHNOLOGY, INC.
RATES FOR ELECTRIC PLANT-IN-)
SERVICE )
Micron Technology, Inc. ("Micron" or "Intervenor"), pursuant to this Commission's
Rules of Procedure, Rule 71 IDAP A 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:
1. The name and address of this Intervenor is:
MICRON'S PETITION TO INTERVENE
IPC-E-16-23
Micron Technology, Inc.
c/o Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
Holland & Hart LLP
6380 S. Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Copies of all pleadings, production requests, production responses, commission orders,
and other documents should be provided to:
Pete Bennett
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83 707
Telephone: [phone]
[e-mail]
Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
Brian T. Hansen
Holland & Hart, LLP
6380 S. Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
And, for documents served electronically, please also add:
[e-mail]
[e-mail]
[e-mail]
2. This Intervenor, Micron, is a Special Contract customer of Idaho Power
Company. Micron receives electric utility services from Idaho Power Company. Idaho Power
Company seeks authority to adjust its Idaho jurisdictional base rates due to revised depreciation
MICRON'S PETITION TO INTERVENE
IPC-E-16-23
2
rates for its electric plant-in-service. Idaho Power Company's request in this proceeding would
result in an Idaho jurisdictional revenue requirement increase of $6,672,588 to be recovered from
customers through an overall increase of 0.59 percent. Micron claims a direct and substantial
interest in this proceeding because its rates for service from Idaho Power Company may be
affected by the outcome of this proceeding.
3. This Intervenor 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
adequate means of participation in this proceeding that may have a material impact on its electric
rates and terms and conditions of service.
WHEREFORE, Micron Technology, Inc. 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.
MICRON'S PETITION TO INTERVENE
IPC-E-16-23
3
Respectfully submitted this 1st day of December, 2016.
MICRON'S PETITION TO INTERVENE
IPC-E-16-23
HOLLAND & HART, LLP
By:-~-· ---+-'-JL~-
Brian T. Hansen, ISB No. 6087
800 W. Main Street, Suite 1750
Boise, Idaho 83 702
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
6380 South Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
4
CERTIFICATE OF SERVICE
I hereby certify that on this 1st day of December, 2016, a true and correct copy of the
within and foregoing PETITION TO INTERVENE OF MICRON TECHNOLOGY, INC. IN
CASE NO. IPC-E-16-23 was served in the manner shown to:
Commission Staff
Jean D. Jewell, Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
[e-mail]
Idaho Power Company
Lisa D. Nordstrom
Matt Larkin
Idaho Power Company
P.O. Box 70
Boise, Idaho 83 707
[e-mail]
[e-mail]
[e-mail]
Echo Hawk & Olsen
Eric L. Olsen
505 Pershing Ave., Ste. I 00
P.O. Box 6119
Pocatello, ID 83205-6119
ELO@ECHOHA WK.COM
MICRON'S PETITION TO INTERVENE
IPC-E-16-23
s/
5
D
D
D
IZJ
Hand Delivery
U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Hand Delivery
U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Hand Delivery
U.S. Mail, postage pre-paid
Facsimile
Electronic Mail