20170410Petition to Intervene.pdf

Peter Richardson (ISB # 3195)
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise,Idaho 83702
Tel. [phone]
peter@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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TN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR A DETERMTNATION
OF 2016 DEMAND-SIDE
MANAGEMENT EXPENDITURES AS
PRUDENTLY INCURRED
CASE NO. IPC-E-17-03
PETITION TO TNTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
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COMES NOW, The Industrial Customers of ldaho Power, hereinafter referred to
as "Intervenor," and pursuant to this Commission's Rules of Procedure, Rule 7l 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:
l. The name and address of this Intervenor is:
Industrial Customers of ldaho Power
c/o Peter J. Richardson
fuchardson Adams, PLLC
515 N. 27h St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadams. com
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter Richardson as noted above and to
Petition to Intervene
Industrial Customers of ldaho Power
IPC-E-17-03
I
Dr. Don Reading
6070 Hill Road
Boise,Idaho 83703
[phone] Tel
[phone] Fax
dreading@mindspring. com
2. This lntervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule l9 customers of Idaho Power. All ICIP members receive
electric utility services from ldaho 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 it.
6. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
Petition to Intervene
Industrial Customers of Idaho Power
IPC-E-17-03
2
WHEREFORE, the Industrial Customers of ldaho 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 10s day of Aprilz}l7
Richardson Adams, PLLC
By:
Peter J. Richardson, Attorney for
Industrial Customers of Idaho Power
CERTIFICATE OF SERVICE
I hereby certify that on this 1Oft day of April2017 ,I delivered true and correct copies of
the enclosed PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER in this Docket No. IPC-E- 17-03 to the following persons via electronic delivery and
United States Mail, postage prepaid:
Diane Hanian (E, H)
Commission Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise,Idaho 83702
Diane.hanian@nuc. idaho. eov
Lisa D. Nordstrom
Idaho Power Company
PO Box 70
Boise, Idaho 83707 -0070
lnorsdstrom@ idahooower. com
[e-mail]
Petition to Intervene
Industrial Customers of Idaho Power
IPC-E-17-03
3
Connie Aschenbrenner
Idaho Power Company
PO Box 70
Boise, Idalro 83707 -0070
caschenbrenner@ idahopwer. com