20220128Petition to Intervene.pdf

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Peter J. Richardson ISB No. 3195
Richardson Adams, PLLC
515 N.27th Strpet
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]M
pgter@richardsonadams. com
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Attorneys for the Industrial Customers of ldaho Power
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 2OI2 INTEGRATED
RESOURCES PLAN
CASE NO. IPC-E-21-43
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of ldatro Power, hereinafter referred to as
"[ntervenor," and pursuant to this Commission's Rules of Procedure, Rule 7l IDAPA
31.01.01.7t, 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 lntervenor is:
Industrial Customers of ldaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N.27m St
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone]
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
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Boise, tdaho 83703
(2oB)342-t700 Tel
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2. This lntervenor, the Industrial Customers of Idaho Power, ("lClP") is an
unincorporated association of Schedule l9 customers of ldaho Power. All ICIP members receive
elechic 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 [ntervenor, 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 inhoduce 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.
WHEREFOR"E, the Industrial Customers of ldaho Power respectfully requests that this
Commission grant its Petition to lntervene 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 lntervention - IPC-E-21-43
DATED this 28th day of January 2022.
f
Peter J
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28th of January 2A22,a fue and correct copy of the
within and foregoing PETITION TO TNTERVENE OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER in Docket No. IPC-E-21-43 was served, pursuant to
Commission Order No. 34602, exclusively via electronic mail to:
Idaho Public Utilities Commission
Jan Nuriyuki, Secretary
ian.nurivuki(Oouc.idaho. sov
secretary@puc. idaho. gov
Idatro Power Company
Lisa Nordstrom
Tim Tatum
Allison Williams
[e-mail]
[e-mail]
[e-mail]
awi I I iams@ idahooower.com
Idaho Conservation League
Benjamin J. Otto
Emma E. Sperry
botto@ idahoconservation.org
esperry@ idahoconservation.org
and exclusively via U.S. Mail, Postage prepaid to:
Kiki Leslie A. Tidwell
704 N. River Sreet, #l
Peter Richardson,
Attorney for the Industrial Customers of Idatro Power
3ICIP Intervention - IPC-E-21-43