HomeMy WebLinkAbout20211217Petition to Intervene.pdfPeter J. Richardson ISB No. 3195
Richardson Adams, PLLC
515 N.27th Street
Boise,Idaho 83702
Telephone: (208) 938-7900
Fax: (208) 938-7904
oeter(Orichardsonadam s.com
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Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
UI.";
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO PROCEED WITH
RESOURCE PROCUREMENTS TO MEET
IDENTIFIED CAPACITY DEFICIENCIES IN
2023,2024, AND 2025 TO ENSURE
ADEQUATE, RELIABLE, AND FAIR.PRICED
SERVICE TO ITS CUSTOMERS
CASE NO. IPC-E.21-41
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"Intervenor,'o 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:
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: (208) 938-790 I
Fax: (208) 938-7904
nete r@ri chardsonadams. 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
(208) 342-1700 Tel
(208) 383-0401 Fax
dreading(@nindsprins.com
2. 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 its members' rates for electric service 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 witresses, and be heard in argument. The nature and quality of evidence which
this lntervenor will intoduce 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.
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
2ICIP Intervention - IPC-E-21-41
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.
TED this lTth day of December202l
J
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the lTth of December202l,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-21-41 was served, pursuant to
Commission Order No. 34602, exclusively via electronic mail to:
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
jan.noriyuki@nuc.idaho. gov
secrctaryfa)Fuc. i daho, Bov
Idaho Power Company
Donovan E. Walker
Lead Counsel
Idaho Power Company
dwalker@ idahopower.com
dockets@idahooower.com
Tim Tatum
Vice President, Regulatory Affairs
Idaho Power Company
ttatum@.i dahopowe r.com
Tom Arkoosh
tom. arkoosh@arkoosh.com
amber. dresslar(Oarkoosh. com
eri n.ceci l@)arkoosh.com
Peter
Attomey for the Industrial Cuslomers of ldaho Power
3ICIP Intervention - IPC-E-2141