20180516Petition to Intervene.pdf

Peter J. Richardson, ISB No. 3195
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@ri chardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
RECEIVED
2010 t{AY l6 PH 3: 29
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E-I8-03
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2OI7 DEMAND-SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED
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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
"lnteryenor," 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 Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
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:
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreadin g@mindsprin g. com
2. This Intervenor, 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 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.
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
2ICIP Intervention IPC-E-18-03
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-l6th day of May 2018(&ltu^
Peter J. Richardson
RICHARDSON ADAMS, PLLC
JICIP Intervention - IPC-E-18-03
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16th day of May, 2018, 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-I8-03 was served electronically and US Mail, to:
Diane Hanian, Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise, Idaho 83702
[e-mail]. gov
Connie Aschenbrenner
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
caschenbrenner@idahopower. com
Idaho Irrigation Pumpers Association
c/o Lynn Tominga
P.O.Box2624
Boise, Idaho 83701-2624
Walters
Administrative Assistant
Julia Hilton
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
jhilton@idahopower. com
[e-mail]
Eric L. Olsen
Echo Hawk & Olsen, PLLC
P.O. Box 6119
Pocatello, Idaho 83205
elo(@echohawk.com
Anthony Yankel
l27OO Lake Avenue, Unit 2505
Lakewood, OH 44107
[e-mail]
4ICIP Intervention - IPC-E-18-03