20211006Petition to Intervene.pdf

PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FOR LEAVE TO INTERVENE– Page 1
CASE NO. IPC-E-21-32
Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION TO MODIFY ITS DEMAND RESPONSE PROGRAMS
CASE NO. IPC-E-21-32
PETITION OF IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.
FOR LEAVE TO INTERVENE
COMES NOW Idaho Irrigation Pumpers Association, Inc. herein called “this Intervenor”
and pursuant to Rules 71 through 73 of the Rules of Procedure of the Idaho Public Utility
Commission, and by this Petition asks leave to intervene and to appear and participate as a party
herein, and as basis therefor states as follows:
1)The name and address of Intervenor is:
Idaho Irrigation Pumpers Association, Inc.
c/o Amy McKoon
1222 W. 90 S.
Blackfoot, ID 83221
This Intervenor will be represented by:
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
and requests that copies of all pleadings and production requests and responses should be
provided to the following:
RECEIVED
2021 OCT -6 PM 4:17
IDAHO PUBLIC
UTILITIES COMMISSION

PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FOR LEAVE TO INTERVENE– Page 2
CASE NO. IPC-E-21-32

Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Lance Kaufman
AEGIS INSIGHT
4801 W. Yale Ave.
Denver, CO 80219
[e-mail]

2) This Intervenor and its members have a direct and substantial interest in this
proceeding. Currently over 300 MW of Irrigator interruptions participate in the peak rewards
program. Any revisions or modifications to this program directly impact the Irrigators and
therefore we intend to participate in all respects herein as a party as may be required to represent
its interests.
3) Without the opportunity to intervene herein, this Intervenor would be without a
manner or means of participating in the lawful determination of issues which will result in affecting
its rates for electric service.
WHEREFORE, this Intervenor requests that this Commission grant this Intervenor’s leave
to intervene in these proceedings and to appear and participate in all matters as may be necessary
and appropriate.
DATED this 6th day of October, 2021.
ECHO HAWK & OLSEN

_____________________________________
ERIC L. OLSEN

PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FOR LEAVE TO INTERVENE– Page 3
CASE NO. IPC-E-21-32

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 6th day of October, 2021, I served a true, correct and
complete copy of the Petition of Idaho Irrigation Pumpers Association, Inc. for Leave to Intervene
to each of the following, via U.S. Mail or private courier, email or hand delivery, as indicated
below:

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ID 83714
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Lisa D. Nordstrom
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

_____________________________________
ERIC L. OLSEN