20220422Petition to Intervene.pdf

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., :i:'r i- ;f
Peter J. Richardson ISB No. 3195
Richardson Adams, PLLC
515 N.27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@ri c hardsoqadams. com
Attorneys for the Industrial Customers of ldaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER
cosT ADJUSTMENT (*PCA") RATES FOR
ELECTRIC SERVICE FROM JUNE 1,2922,
THROUGH MAY 31,2023
CASE NO. IPC-E-Z?-II
PETITION TO INTERVENE
OF THE INDUSTRI,AL CUSTOMERS
OF IDAHO POWER
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COMES NOW, The Industrial Customers of ldaho Power, hereinafter referred to as
"lntervenor," and pursuant 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 lntervenor is:
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St
Boise,ldaho 83702
Telephone: [phone] I
Fax: [phone]
neter(@.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:
t/
il
Dr. Don Reading
6070 Hill Road
Boise,ldaho 83703
[phone] Tel
[phone] Fax
dreadine(am indsori nc.com
2. This Intervenor, the Industrial Customers of [daho Power, ("ICIP") is an
unincorporated association of Schedule 19 customers of Idaho Power. All ICIP members receive
electric utility services from [daho 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-exlmine 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 Idaho Power respectfully requests that this
Commission grant its Petition to Intervene in these proceedings and to appear and participate in
2lClP lntervention - IPC-E-22-l I
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.
D this 22nd day of April2022
Peter J
RTCHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the22nd of April 2022,atrue 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-22-I I was served, pursuant to
Commission Order No. 35375, exclusively via electronic mail to:
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
ian. nori)ruki@Ouc. idaho. gov
secretary@p uc. idaho. gov
Matthew T. Larkin
Timothy E. Tatum
Jessi Brady
ldaho Power Company
l22l West tdaho Street
Boise,ldatro 83702
m larki n@- idahonower.com
ttatum@ idahopower.com
ibradv@ idahooower.com
Lisa Nordstom
Idaho Power Company
l22l West Idaho Street
Boise,ldaho 83702
lnordstrom@ idahooower.com
dockets@ idahopower.com
hardson.
Attomey for the Industrial Customers of ldaho Power
3lClP lntervention - IPC-E-22-ll