20200827Petition to Intervene.pdf

Peter J. Richardson ISB No. 3195
Cregory M. Adams ISB No. 7454
Richardson Adams, PLLC
515 N. 27'h Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(rj ri c ha rdsonadams. com
s re gflu ri c hardsonad a m s. com
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Attorneys for the Industrial Customers of ldaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR
AUTHORITY TO REVISE THE ENERGY
EFFICIENCY RIDER, TARTFF SCHEDULE
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CASE NO. IPC-E-20.33
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of ldaho Power, hereinafter referred to as
"lntervenor," and pursuant to this Commission's Rules of Procedure, Rule 7l IDAPA
3 I .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:
I . The name and address of this lntervenor is:
lndustrial 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]
r2clle r(d ric hardso nadam s. 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
(208) 342-t700 Tel
[phone] Fax
dread ing(g)m i ndspri n u.com
2. This Intervenor, the Industrial Customers of ldaho Power, ("ICIP") is an
unincorporated association of Schedule [9 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 elecffic 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 argurnent" 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 lntervenor would be without any
means of participation in this proceeding which may have a material impact on their retail
electric rates.
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 ldaho Power respectfully requests that this
Commission grant its Petition to lntervene in these proceedings and to appear and participate in
ICIP Intervention - IPC-E-20-31 2
all matters as may be necessary and appropriate; and to present evidence, call and examine
witnessesn present argument and to otherwise fully participate in these proceedings.
DA this 2 of 2020.
. Richardson
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 27th of August 2020, atrue and correct copy of the
within and foregoing PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO TDAHO POWER in Docket No. IPC-E-20-33 was served, pursuant to
Commission Order No. 34602, exclusively via electronic mail to:
Idaho Public Utilities Commission
Jan Nuriyuki, Secretary
ian.nuriyuki@puc. idaho. gov
Edward jewel I @puc. idaho.gov
Idaho Power Company
lflordstrom@ idahooo wer.com
doc ketsfD i dalropo wer. com
caschenbren ner@ idahooower.com
Peter
Attorney for the Industial Customers of ldatro Power
3lClP Intervention - IPC-E-20-33