20170407Petition to Intervene.pdf

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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-16-24
Peter J. Richardson
ISB No. 3195
Gregory M. Adams
ISB No. 7454
Richardson Adams, PLLC
515 N. 27ft Street
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone] Tel
Fax: [phone]Fax
peter@richardsonadams. com
Attorneys for the Industrial Customers of ldaho Power
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IN THE MATTER OF THE APPLICATION OF
TDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE NORTH
VALMY PLANT
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PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"Intervenor,o'and pursuant to this Commission's Rules of Procedure, Rule 7l IDAPA
3 I .01 .01 .7 I 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. 27h St
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadams. com
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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
dreading@mindspring. com
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' 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 pay for electrical services in the State of Idaho.
6. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case. The [CIP acknowledges this Petition is out of time.
However, this docket is interrelated with the general depreciation docket (IPC-E-16-23) to which
2lntervention - IPC-E-16-24
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the ICIP has been granted party status. The parties to both this and the depreciation docket are
all the szrme except for the ICIP. As these two cases have progressed, it has become apparent
that the common parties to both cases have found it economical to hold concurrent settlement
discussions to facilitate the efficient resolution of issues in both dockets. The ICIP's ability to
participle in concurrent settlement discussions is complicated and less efficient without having
status as a party in this, the Valmy docket, as well as the general depreciation docket.
The ICIP will not broaden the issues, nor will it seek to alter the schedule in this docket
and it will abide by all protective agreements and informal process guidelines heretofore adopted
by the Parties. No party will be prejudiced by the granting of the ICIP's late intervention, and it
is expected that the process going forward will be more efficient for all parties in both cases by
said intervention.
WHEREFORE, the Industrial Customers of Idaho Power respectfully requests that this
Commission grant its Petition to lntervene in these proceedings and to appear and participate in
all matters as may be necessary and appropriate and to fully participate in these proceedings.
DATED this 7rH day of Aprilz}lT
Richardson Adams, PLLC
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P*ba,MBy:
Peter J. Richardson, Attorney for
Industrial Customers of Idaho Power
JIntervention - PC-E-I 6-24
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th day of April,2ll7, atrue and correct copy of the within
and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER was served by ELECTRONIC MAIL, to:
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Diane Hanian
Commission Secretary
47 2 W est Washington Street
Boise, Idaho 83702
Diane. hanian@puc. idaho. gov
Idaho Power Company
Matt Larkin
Lisa Nordstrom
1221 West Idaho Street
Boise, Idaho 83702
lnordstrom@ idahopower.com
mlarkin@ idahopower. com
dockets@ idahopower. com
Camille Christen
Idaho Public Utilities Commission
472West Washington St.
Boise, Idaho 83702
[e-mail]. gov
Steven Porter
US Dept. of Energy
1000 Independence Ave, SW
Room 6D-033
Washington, DC 20585
[e-mail]. gov
Travis Ritchie
Sierra Club
2l0l Webster St. Ste. 1300
Oakland, CA946l2
Travis.ritchie@sierrac Iub.ors
Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
6380 Fiddlers Green Cr., Ste. 500
Greenwood Village, CO 801I I
tnel son@hollandhart. com
fschm i dt@ ho I I andhart. cot
[e-mail]
Pete Bennett
Micron Technology
8000 S. Federal Way
Boise,Idaho 83707
[e-mail]
Eric L. Olsen
Echohawk & Olsen, PLLC
505 Pershing Ave, Ste. 100
Pocatello, Idaho 83205
[e-mail]
Tony Yankel
12700 Blake Ave. Unit 2505
Lakewood, Ohio 44107
[e-mail]
Benjamin J. Otto
Idaho Conservation League
PO Box 844
Boise,ldaho 83701
botto@idahoconservatio n.org
4lntervention - IPC-E- I 6-24