20220506Petition to Intervene.pdf

Peter J. Richardson ISB No. 3195
Richardson Adams, PLLC
515 N. 271h Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
oeter@ri chardsonadams.com
Attorneys for the lndustrial Customers of ldaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF A REPLACEMENT SPECIAL
CONTRACT WITH MTCRON TECHNOLOGY,
TNC. AND A POWER PURCHASE
AGREEMENT WITH BLACK MESA
ENERGY, LLC.
CASE NO. IPC.E-22-06
PETTTION TO TNTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
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COMES NOW, The [ndustrial Customers of ldaho Power, hereinafter referred to as
"lnteryenor," and pursuant to this Commission's Rules of Procedure, Rule 7l TDAPA
3 I .0 I .0 I .7 I , 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 ldaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St
Boise, tdaho 83702
Telephone: [phone] I
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:
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/t
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreading@m indsprinq. com
2. This Intervenor, the lndustrial Customers of tdaho Power, ("[ClP") is an
unincorporated association of Schedule l9 customers of ldaho 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.
3. This lntervenor, 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 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 Industrial Customers of ldaho Power respectfully requests that this
Commission grant its Petition to lntervene in these proceedings and to appeilr and participate in
2ICIP lntervention - IPC-E-22-06
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.
DA D this day of May 2022
J
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of May 2022, a true and correct copy of the
within and foregoing PETITION TO INTERVENE OF THE INDUSTRLAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER in Docket No. IPC-E-22-06 was served, pursuant to
Commission Order No. 35375, exclusively via electronic mail to:
Idatro Public Utilities Commission
Jan Noriyuki, Secretary
ian. noriyu ki@.Ir uc. idaho. gov
secretarv@nuc. idaho. gov
Timothy Tatum
Connie Aschenbrenner
Idaho Power Company
l22l West Idaho Street
Boise,Idatro 83702
ttatum@ idahopower.com
caschenbrenner@ idahopower.coru
Donovan Walker
Idaho Power Company
l22l West Idaho Sheet
Boise, tdaho 83702
dwalker@ idahopower. com
doc kets@ idahopower.com
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Peter
Attorney for the Industrial Customers of ldaho Power
3ICIP lntervention - IPC-E-22-06