20210419Petition 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]M
peier@richardsonadams. com
Attomeys for the Industrial Customers of ldaho Power
-- "*.r-r! !" f*rrt--. .-l\-rf!JL. ! t-_t E ur+
i;.i rl:1 19 Pi{ 'q: i3
_. +: ,r,: '-' ....: :,-.,l"r,llflSt0N
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E-?I-M
TN THE MATTER OF IDAHO POWER
COMPANY'S APPLTCATION FOR A
DETERMINATION OF 2O2O DEMAND-SIDE
MANAGEMENT EXPENSES AS
PRI.JDENTLY INCURRED
)
)
)
)
)
)
)
PETTTION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"Interyenor," and pursuant to this Commission's Rules of Procedure, Rule 7l IDAPA
3 I .0 I .0 I .7 I and pursuant to that Notice of Application and Notice of Intervention Deadline in
Order No. 34986 issued on April 6,2021and hereby petitions the Commission for leave to
intervene herein and to appeax and participate herein as a party, and as grounds therefore states
as follows:
1. The name and address of this lntervenor is
Industrial Customers of tdaho 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(g) ric h ardsonadams. 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
dreadi ng@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 ldaho 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 pafty, 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.
2ICIP lntervention - IPC-E-2 I -04
WHEREFORE, the Industrial Customers of ldaho Power respectfully requests that this
Commission grant its Petition to lntervene in these proceedings and io appear and participate in
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 lgth day of April202l
Peter J
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the lgth day of April2O2l,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-21-04 was served electronically to:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
I [e-mail]
dockets@ idahopower.com
Connie Aschenbrenner
Idaho Power Company
caschenbrenner@idahooower. com
Adam Lowney
McDowell Rackner Gibson PC
Richardson
Jan Noriyuki
Idaho Public Utilities Commission
ian.noriyuki@f uc. idaho. gov
Edward Jewell
Idaho Public Utilities Commission
edward jewel l@puc. idaho. gov
3lClP Intervention - [PC-E-21-M