20211215Petition to Intervene.pdf

Peter J. Richardson ISB No. 3195
Richardson Adams, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]o4
nercr@richardsonadams. com
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH A NEW
SCHEDULE TO SERVE SPECTILATIVE
HIGH.DENSITY LOAD CUSTOMERS
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Afforneys for the Industrial Customers of ldaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.2I-37
PETITION TO INTERVENE
OF THE INDUSTRI,AL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industial Customers of ldatro Power, hereinafter referred to as
"Intervenor," and pursuant to this Commission's Rules of Procedure, Rule 7l IDAPA
31.01.01.71, 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:
l. The name and address of this Intervenor is:
lndustrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St
P.O. Box 7218
Boise,ldaho 83702
Telephone: [phone] I
Fax: [phone]M
peter@richardsonadam s. 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 g@mindspri ng.com
2. This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule l9 customers of ldaho 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 seryice in the future 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 opportunity to intervene herein, this lntervenor would be without any
means of participation in this proceeding which may have a material impact on their retail
electric rates.
6. Granting the ICIP intervenor status will not result in disruption of this proceeding,
prejudice existing parties, nor unduly broaden the issues.
WHEREFORE, the lndustrial 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.
2ICIP Intervention - IPC-E-21-37
DATED this 15ft day of December202l
i
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RJCHAR"DSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the l5th of Dece,nrber 202l,a fiuc and correct copy of the
within and foregoing PETITION TO INTERVENE OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER in Docket No. IPC-E-21-37 was scrved pursuant to
Commission OrderNo. 3m2,exclusively via electonic mail to:
Idaho Public Utilities Commission
Jan Nuriyuki, Secretary
[e-mail]. gov
secrctarv@nuc. idaho. eov
Idaho PowerCompany
[e-mail]
dockets@ idahooower. com
caschenbren ner@ idahopower.com
Peter Richardson,
Attorney forthe lndustid Custurcrs of ldaho Power
3ICIP Intervention - IFC-E-21-37