20220505Petition to Intervene.pdf

Peter J. Richardson ISB No. 3195
Richardson Adams, PLLC
5 l5 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
BEFOR.E THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY TO ACQUIRE
RESOURCES TO BE ONLINE BY 2023 TO
SECURE ADEQUATE AND RELIABLE
SERVICE TO ITS CUSTOMERS.
CASE NO. IPC-E-22-13
PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
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COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"lntervenor," andpursuant 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 rs:
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St
Boise, Idaho 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:
il
il
RECEIVED
2022 MAY-5 PM 1:03
IDAHO PUBLIC
UTILITIES COMMISSION
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreadinq@,mindsprins. com
2. This Intervenor, the Industrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule l9 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.
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 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 appear and participate in
2ICIP Intervention - tPC-E-22- l3
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 5th day of May 2022
Peter J
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5th day of May 2022, 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. [PC-E-22-13 was served, pursuant to
Commission Order No. 35375, exclusively via electronic mail to:
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
j an.nori)¡uki@puc. idaho. gov
geç[e-mail]. sov
Tim Tatum
Idaho Power Company
l22l West Idaho Street
Boise, Idaho 83702
ttatum@ idahopower.com
r
Peter Richardson,
Attorney for the Industrial Customers of ldaho Power
Donovan Walker
Idaho Power Company
1221 West ldaho Street
Boise, tdaho 83102
dwalker@ idahopower. com
dockets@idahopower. com
aJICIP Intervention - IPC-E-22-13