20170117Petition to Intervene.pdf

Peter J. Richardson
ISB No. 3195
Gregory M. Adams
ISB No. 7454
Richardson Adams, PLLC
515 N. 2?1h Street
P.O. Box 7218
Boise, Idaho 83 702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for the Industrial Customers of Idaho Power
R[:C EIVED
ZL.lJ/:.1 7 PH3:37
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
IDAHO POWER COMPANY FOR A )
DETERMINATION OF HELLS CANYON )
RELICENSING COSTS THROUGH 2015 AS )
PRUDENTLY INCURRED )
)
)
CASE NO. IPC-E-16-32
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers ofldaho 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 in
Order No. 33686 issued on January 4, 2107, 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. 27th 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 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 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.
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 lntervention -IPC-E-16-32 2
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.
DAT~7ili day of.[anuary 2017 p~~-)
Peter J. Richardson
RICHARDSON ADAMS, PLLC
ICIP intervention -IPC-E-16-32 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 17th day of January 2017, 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-16-32 was served electronically and by U.S. Mail
Postage prepaid, to:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83 707
[e-mail]
[e-mail]
Tim Tatum
Idaho Power Company
1221 West Idaho Street
Boise, ID 83 707
[e-mail]
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, ID 83 702
jean. j [e-mail]
Idaho Irrigation Pumpers Association
Lynn Tominga
PO Box 2624
Boise, ID 83701
Idaho Irrigation Pumpers Association
Eric Olsen
Echo-Hawk & Olsen, PLLC
505 Pershing Ave., Ste. 100
Pocatello, ID 83205 &~ -
Administrative Assistant
[C[P lntervention -IPC-E-16-32 4