20050124Petition to Intervene.pdf

Eric L. Olsen, ISB No. 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
RECEIVED
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26U5JAN21+ AM ~': 11
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UTiLItiES COr;lr1iSStON
Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ACIFICORP DBA UTAH POWER & LIGHT
COMP ANY FOR APPROV AL OF CHANGES
TO ITS ELECTRIC SERVICE SCHEDULES
Case No. PAC-O5-
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION.. INC...
FOR LEAVE TO INTERVENE
COMES NOW Idaho Irrigation Pumpers Association, Inc., herein called "this Intervenor
and pursuant to Rule 72 of the rules of Procedure of the Idaho Public Utility Commission, and by
this Petition asks leave to intervene herein and to appear and participate as a party herein, and as
basis therefor states as follows:
(1)The name and address of this Intervenor is:
Idaho Irrigation Pumpers Association, Inc.
c/o Lynn T ominaga
O. Box 2624
Boise, Idaho 83701-2624
This Intervenor will be represented by:
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chartered
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. FOR LEAVE TO INTERVENE - 1
and requests that copies of all pleadings and production requests and responses should be provided
to the following:
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chartered
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
E-mail: elo~racinelaw .net
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
Fax: [phone]
E-mail: yankel~attbi.com
(2)This Intervenor and its members have a direct and substantial interest in this
proceeding and intend to participate in all respects herein as a party as may be required to represent
its interests.
(3)Without the opportunity to intervene herein, this Intervenor would be without a
manner or means of participating in the lawful determination of issues which will result in affecting
its rates for electric service.
WHEREFORE, this Intervenor requests that this Commission confirm this Intervenor s leave
to intervene 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, cross-examine witnesses, present
argument, and to otherwise fully participate in the proceedings.
DATED this day of January, 2005.
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. FOR LEAVE TO INTERVENE - 2
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 2/daay of January, 2005 , I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
o. Box 83720
Boise, ID 83720-0074
E-mail: jjewell~puc.state.id.
John Stewart
P acifi Corp
201 South Main, Suite 2300
Salt Lake City, Utah 84140-0023
James M. Van Nostrand
Stoel Rives, LLP
900 SW Fifth Avenue, Suite 2600
Portland, Oregon 97204
Curtis D. McKenzie
Stoel Rives, LLP
101 S. Capitol Blvd.
Boise, Idaho 83702
S. Mail
S. Mail
S. Mail
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. FOR LEAVE TO INTERVENE - 3