20211216Petition to Intervene.pdf

r: r- ftr1.,:i jlVLiJ
Peter J. Richardson ISB No. 3195
Richardson Adams, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]M
[e-mail]
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO EXPAND
OPTIONAL CUSTOMER CLEAN ENERGY
OFFERINGS THROUGH THE CLEAN
ENERGY YOUR WAY PROGRAM
i::;. i; PI"i 2: 25
CASE NO. IPC.E.2I-40
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF TDAHO POWER
Attomeys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"Intervenor," and purcuant to this Commission's Rules of Procedure, Rule 7l IDAPA
3 I .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:
Industrial Customers of ldaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
oeter@richardsonadam s.com
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter Nchardson as noted above and to:
Dr. Don Reading
6070 Hill Road
Boise,Idaho 83703
[phone] Tel
[phone] Fax
dreadin g@mindsprin g.com
2. This Intervenor, the Industrial Customers of ldaho Power, ('ICIP") is an
unincorporated association of Schedule 19 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 in the future may be
affected by the outcome of this proceeding as well as their ability to participate in the Company's
clean energy offerings to its customers, including its industrial customers.
3. This Intervenor, in its capacity as a representative of indusffial customers intends
to participate herein as a party, and if necessary, to introduce evidence, cross-examine wittesses,
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 Intervenor 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.
WHEREI'ORE, 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
2ICIP Intervention - IPC-E-21-40
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 l6th day of December 2021p#
Peter J
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the l6th of December 2D2l,a true 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-2140 was served, pursuant to
Commission Order No. 34602, exclusively via electronic mail to:
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
jan.norivuki@puc. idaho. gov
secretary@ouc. idaho. gov
Idaho Power Company
Lisa Nordstrom, Lead Counsel
Alison Williams
Regulatory Policy & Strategy Advisor
[e-mail]
docketst@ idahooower.com
awil [e-mail]
[e-mail]
Peter
Attomey forthe Industrial Customers of Idaho Power
3ICIP Intervention - IPC-E-21-40