20200410Petition 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@richardsonadams. com
Attorneys for the Industrial Customers of ldaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER'S
APPLICATION FOR A DETERMINATION OF
2OI9 DEMAND SIDE MANAGEMENT
EXPENSES AS PRUDENTLY INCURRED.
CASE NO. IPC-E-20-15
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"lntervenor," 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 rs
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] I
Fax: [phone]
peter@richardsonadams. com
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Copies of all pleadings, production requests, production responses, Commission orders
RECEIVED
2020 April 10,PM9:43
IDAHO PUBLIC
UTILITIES COMMISSION
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@mindsprin g. com
2. This Intervenor, the Industrial Customers of ldaho Power, ("ICIP") is an
unincorporated association of Schedule l9 customers of ldaho 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 their ability to net
meter electrical production.
6. Granting the ICIP intervenor status will not result in disruption of this proceeding,
prejudice existing parties, nor unduly broaden the issues.
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-20- I 5
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 I of April2020
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Peter J. Richardson
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the lOth of April 2020, a true and correct copy of the within
and foregoing PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER TO IDAHO POWER in Docket No. IPC-E-20-15 was served, pursuant to Commission
Order No. 34602, exclusively via electronic mail to:
Idaho Public Utilities Commission
Diane Hanian, Secretary
Diane. hanian(dpuc. idaho. gov
Edward.i .idaho.sov
Idaho Power Company
lnordstrom@idahopower. com
dockets@ idahopower.com
caschen .com
Idaho Irrigation Pumpers Association, Inc
[e-mail]
[e-mail]
\
Rv'
Peter Richardson,
Attorney for the Industrial Customers of ldaho Power
aJICIP lntervention - IPC-E-20-15