20210621Petition to Intervene.pdf

r ll l-.: l/'-i!. ul t q-sPeter J. Richardson
ISB No.3l95
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, ldaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadams. com
Attomeys for the Industrial Customers of tdaho Power
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORTTY TO INCREASE ITS RATES
FOR ELECTRIC SERVTCE TO RECOVER
COSTS ASSOCIATED WITH THE JIM
BRIDGER POWER PLANT
CASE NO. IPC-E-21-17
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
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COMES NOW, The lndustrial Customers of [daho Power, hereinafter referred to as
"lntervenor" or the *ICIP" and pursuant to the Rules of Procedure, Rule 7 l IDAPA 3 l .01 .01.71
of the ldaho Public Utilities Commission ("Commission") and hereby petitions the Commission
for leave to intervene herein and to appear and participate herein as a party. In support of said
Petition to Intervene the ICIP says as follows:
I
INTRODUCTION _ BACKGROTIND
ldaho Power Company ("[daho PoweC') initiated this docket on June 3,2021, for the
purposes of, inter alia, seeking authorization to, ( 1) accelerate its depreciation schedule for the
Jim Bridger Power Plant, (2) create a balancing account to track incremental costs associated
with the early termination of ldaho Power's participation in that power plant, and to (3) increase
annual rates it charges by approximately 2.5oh or thirty-one million dollars.
II.
PETITION TO TNTERVENE
The name and address of this Intervenor is:
lndustrial Customers of [daho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27Ih St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] I
Fax: [phone]
peter(Erichardsonadams. 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
dreadin [e-mail]
This Intervenor, the Industrial Customers of Idaho Power, (*[CIP") 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.
This lntervenor, in its capacity as a representative of industrial customers intends to
participate herein as a party, and if necessary, to introduce evidence, cross-exalnine witnesses,
ICIP Intervention
- tPC-E-2r-r7
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call and examine witnesses, and be heard in argument. The nature and quality of evidence which
this Intervenor will introduce is dependent upon the natur and effect of other evidence in this
proceeding.
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.
Granting this Intervenor's petition to intervene will not unduly broaden the issues nor
will it prejudice any party to this case.
WHEREFORE, the Industrial Customers of Idatro Power respectfully requests that this
Commission grant its Petition to Intervene in these proceedings and to appear and participate in
all matters alr 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 l8th day of June 2021
I
Peter J. Richardson
RICHARDSON ADAMS, PLLC
ICIP Intervention
- IPC-E-2t-17
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on thd l8th day of June 2D2l,a tnre and correct copy of the within
and foregoing PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER in Docket No. IPC-E-21-017 was served electronically to:
Lisa Nordstrom
Regulatory Dockets
Idatro Power Company
lnordstrom@ idahopower.com
dockets@idahooower. com
Matt Larkin
Idatro Power Company
Idatp Power Company
m larkin@idahopower. com
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
i an. nori vuk i@n uc. idaho. eov
Commission Secretary
Idatro Public Utilities Commission
secretary(@nuc. idaho. sov
Karl Klein
Idaho Public Utilities Commission
karl.kl ien@nuc. idaho. gov
t
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Peter Richardson
RICHARDSON ADAMS, PLLC
lClP lntervention
- IPC-E-2t-17
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