20211105Petition 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] I
Fax: [phone]
peter@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL TO MODIFY ITS DEMAND
RESPONSE PROGRAMS
CASE NO. IPC-E-21-32
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"Intervenor" or the "ICIP" and pursuant to the Rules of Procedure, Rule 7l IDAPA 3 I .01 .01 .71
of the Idaho Public Utilities Commission ("Commission") and pursuant to Commission Order
No. 35214, and hereby petitions the Commission for leave to intervene herein and to appear and
participate herein as a party. [n support of said Petition to Intervene the ICIP says as follows:
I
INTRODUCTION - BAC KGROUND
Idaho Power Company ("Idaho Power" or the "Power Company") initiated this docket on
October 1,2021 , for the purposes of modifying its demand response programs and to revise the
cost-effectiveness methodology for evaluating those programs. The Power Company offers
demand response programs to just three of its customer classes, one of which is the industrial
class of customers.
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RECEIVED
2021 NOV -5 PM 3:20
IDAHO PUBLIC
UTILITIES COMMISSION
II.
PETITION TO INTERVENE
The name and address of this Intervenor is:
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
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 nq@mindspri ne.com
This Intervenor, the Industrial Customers 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 the nature of demand response programs offered to the industrial customers
will likely be affected by the outcome of this proceeding. In addition, the cost-effectiveness
measure of demand response programs will have an ultimate impact on the retail rates the
industrial customers end up paying the Power Company for their electric service.
ICIP Intervention
IPC-E-2t-32 2
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.
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 availability of demand
response programs offered to the industrial class of customers and may also have a material
impact on the electric rates the ICIP members pay to the power company.
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 Idaho Power respectfully requests 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 5th day of November 202t
J
RICHARDSON ADAMS, PLLC
ICIP Intervention
- !PC-E-2I-32 J
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5th day of November 2021,a true and correct copy of the
WithiN ANd fOTCgOiNg PETITION TO INTERVENE OF THE TNDUSTRIAL CUSTOMERS OFIDAHO PowER in Docket No. Ipc-E-21-32 was served electronically to:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
lnordstrom@ idahopower. com
dockets@idahopower. com
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
i an.noriyuki@puc. idaho. gov
Benjamin J. Otto
Idaho Conservation League
botto@idahoconservation. org
Eric L. Olsen
Idaho Irrigation Pumpers Association
Echo Hawk & Olsen, PLLC
[e-mail]
Peter
RICHARDSON ADAMS, PLLC
ICIP Intervention
- IPC-E-2I-32
Commission Secretary
Idaho Public Utilities Commission
[e-mail]. sov
Connie Aschenbrenner
Idaho Power Company
cashenbrenner@ idahopower. com
Emma E. Sperry
Idaho Conservation League
esperry.@ idahoconservation. org
Lance Kaufman
Idaho Irrigation Pumpers Association
AEGIS Insight
lance@ae gisinsi ght. com
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