20230206Petition to Intervene.pdf

Peter J. Richardson
ISB No. 3195
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
peter@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-OI
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE BOARDMAN TO
HEMINGWAY sOO-KV TRANSMISSION
LINE
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PETITION TO INTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"Intervenor," and pursuant to this Commission's Rules of Procedure, Rule 7l IDAPA
31.01.01 .77,and pursuant to Commission Order no.35674 (Notice of Application and Notice of
Intervention Deadline) 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 ldaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N.27th St
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone] I
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
280 S. Silverwood V/ay
Eagle, ID 83616
(208) 284-ss6s
dreading@mindspring. 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' cost of electric power and quality of service may
be affected by the outcomes of this docket.
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.
4. 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 and or the quality of electric service they receive from Idaho Power Company.
5. This intervention is timely and will not unduly broaden the issues presented for
the Commission's determination.
WHBREFORE, 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
ICIP Intervention IPC-E-23-01
IPC-E-23-01
2
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 6th day of February 2023
\
Peter J
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6th day of February 2023, I served a true correct and complete
copy of the Petition to Intervene of the Industrial Customers of Idaho Power on the following via
electronic mail only.
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
Jan.norivuki .idaho.eov
Riley Newton, Deptuty Attomey General
Idaho Public Utilities Commission
riley. newton@puc. idaho. gov
Donovan E. V/alker
Tim Tatum
Idaho Power Company
dwalker@ idahopower. com
ttatum@idahopower. com
dockets@ idahopower. com
Eric L. Olsen
Lance Kaufman, Ph.D
[e-mail]
Peter J.
lClP Intervention - IPC-E-23-01
tPC-E-23-01
J