20181123Petition to Intervene.pdf

Yvonne R. Hogle,ISB #8930
Rocky Mountain Power
1407 West North Temple, Suite 320
Telephone No. [phone]
vvonne.hoqle@pacifi corp.com
Attorneyfor RoclE Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPAI\Y TO
STUDY FIXED COSTS OF PROVIDING
ELECTRIC SERVICE TO CUSTOMERS
RECEIVED
?0lB ti0y 23 pH 12: t+B
CASE NO.IPC.E.18-I6
PETITION OF ROCKY MOUNTAIN
POWER FOR LEAVE TO
INTERVENE
ili-iu
i.{F,{lSSl0N
COMES NOW, PacifiCorp, dba Rocky Mountain Power, and pursuant to Rules 71 through
73 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission"), hereby
petitions the Commission for leave to intervene and participate as a party in the maffer captioned
above.
The grounds for the petition are as follows:
l. Rocky Mountain Power is a division of PacifiCorp. PacifiCorp is an Oregon
corporation that provides electric service to retail customers through its Rocky Mountain Power
division in the states of Idaho, Utah, and Wyoming, and through its Pacific Power division in the
states of California, Oregon, and Washington.
2. Rocky Mountain Power is authorized to do business in the state of Idaho as a public
utility providing retail electric service to approximately 77,000 customers. Rocky Mountain Power
is a public utility subject to the jurisdiction of the Commission pursuant to Idaho Code $ 6l-129.
3. Rocky Mountain Power and its customers have significant interest in the above-
captioned matter and their interests may be substantially affected by the outcome of this
proceeding through the potential establishment of new policies. Without the opportunity to
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intervene herein, Rocky Mountain Power would be excluded from participating in the lawful
determination of issues related to the fixed costs of providing service to customers that could set a
precedent for its own treatment of this and related issues. In addition, Rocky Mountain Power
could also provide information that would aid the Commission in evaluating the evidence in this
proceeding.
4. Rocky Mountain Power's intervention and participation in this matter will not
materially impair the prompt and orderly conduct of this proceeding. If intervention is authorized
Rocky Mountain Power would not seek access to any confidential material Idaho Power may deem
proprietary. Rocky Mountain Power requests that copies of all notices and filings in this docket be
served on:
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake city, Utah 841l6
E-mail : ted.weston@fracifi corp.com
Yvonne R. Hogle
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
E-mail: [e-mail]
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission
approve Rocky Mountain Power's leave to intervene in this proceeding 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 otherwise fully participate in the above-captioned
docket to the full extent allowed by law.
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Dated this 23'd day of November,20l8.
Respectfully submitted,
ROCKY MOLINTAIN POWER
R. Hogle
for RoclE Mountain Power
J
CERTIFICATE OF SERVICE
I hereby certify that on this 23'd of November, 2018,I caused to be served, via e-mail, a
true and correct copy of the foregoing document in IPC-E-18-16 to the following:
Lisa D. Nordstrom
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise, ID 83707
lnordstrom@.idahooower. com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise,Idaho 83702
botto@ idahoconservation.ors
Yvonne R. Hogle
Rocky Mountain Power
1407 West North Temple, Suite 320
salt Lake city, utah 84116
E-mail: [e-mail]
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise, ID 83707
[e-mail]
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
E-mail : [e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah Street, Suite 2000
Portland, Oregon 97232
datarequest@pacifi corp.com
Ve,"
Katie Savarin
Coordinator, Regulatory Operations