20210517Petition to Intervene.pdf

RECEIVED
2021May17,PM 3:25
IDAIIO PUBLICPeterJ.Richardson UTILITIES COMMISSIONISBNo.3195
Richardson Adams,PLLC
515 N.27"'Street
P.O.Box 7218
Boise,Idaho 83702
Telephone:[phone]I
Fax:[phone]
[e-mail]
Attorneys for the IndustrialCustomers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR A )CASE NO.IPC-E-21-12DETERMINATIONACKNOWLEDGINGITS)NORTH VALMY POWER PLANT EXIT )PETITION TO INTERVENEDATE)OF THE INDUSTRIAL CUSTOMERS
)OF IDAHO POWER
COMES NOW,The Industrial Customers of Idaho Power,hereinafter referred to as
"Intervenor,"and pursuant to this Commission's Rules of Procedure,Rule 71 IDAPA
31.01.01.71 and pursuant to that Notice of Application and Notice of Intervention Deadline in
Order No.34986 issued on April 6,202l and 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 Intervenor is:
Industrial Customers of Idaho Power
c/o Peter J.Richardson
Richardson Adams,PLLC
515 N.27th g
P.O.Box 7218
Boise,Idaho 83702
Telephone:[phone]
Fax:[phone]
peter nchardsonadams.con;
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
dreadiag¿ì;mindspring.com
2.This Intervenor,the IndustrialCustomers of Idaho Power,("ICIP")is an
unincorporated association of Schedule 19 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 opportunityto 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'spetition to intervene will not undulybroaden the issues
nor will it prejudice any party to this case.
ICIP Intervention-IPC-E-21-12 2
WHEREFORE,the IndustrialCustomers of Idaho Power respectfullyrequests that this
Commission grant its Petition to Intervene in these proceedings 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 to otherwise fully participate in these proceedings.
DATED this 17'"day of May 2021
Peter J.Richardson
RICHARDSONADAMS,PLLC
CERTIFICATEOF SERVICE
I HEREBY CERTIFY that on the 17*day of May 2021,a true and correct copy of the withinandforegoingPETITIONTOINTERVENEBYTHEINDUSTRIALCUSTOMERSOFIDAHOPOWERinDocketNo.IPC-E-21-12 was served electronicallyto:
Lisa Nordstrom Jan NoriyukiRegulatoryDocketsIdahoPublicUtilities CommissionIdahoPowerCompanyjan.norivuki puc.idaho.covinordstromidahopower.com
[e-mail]
Edward JewellMattLarkinIdahoPublicUtilities [e-mail]
Peter Richardson
ICIP Intervention-IPC-E-21-12 3