20120914Petition to Intervene.pdf

Williams • Bradbury
ATTORNEYS AT LAW REc-
2O2SEP it. PM 2U8
Iff
September 14, 2012
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Re: PAC-E-12-12
Dear Ms. Jewell:
Please find enclosed an original and seven copies of Petition of PacifiCorp Idaho
Industrial Customers for Leave to Intervene for filing in the above referenced case.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerely,
Ronald L. Williams
RLW/jr
Enclosures
1015 W. Hays Street -Boise, ID 83702
Phone: [phone] - Fax: [phone] - www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Fax: [phone]
ISB#3034
[e-mail]
RE CE I yE r:
2012 SEP 14 PM 2.- 08
Attorneys for PIIC
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICATION ) Case No. PAC-E-12-12
OF ROCKY MOUNTAIN POWER FOR )
AUTHORITY TO CANCEL SCHEDULE ) PETITION OF PACIFICORP IDAHO
NO. 17 AND IMPLEMENT A NEW ) INDUSTRIAL CUSTOMERS
PARTIAL REQUIREMENTS TARIFF ) FOR LEAVE TO INTERVENE
)
Pursuant to Rules 71 and 73 of the Idaho Public Utilities Commission's
Rules of Practice and Procedure, PacifiCorp Idan Industrial Customers ("PIIC") petitions
the Idaho Public Utilities Commission (the "Commission") for leave to intervene. In
support of this Petition, PIIC states as follows:
1.The name and address of PIIC is:
PacifiCorp Idaho Industrial Customers
1015 W. Hays St.
Boise, ID 83702
2.PIIC will be represented in this proceeding by Williams Bradbury,
P.C. All documents relating to these proceedings should be served on the following
persons at the addresses listed:
PETITION TO INTERVENE Page 1
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Facsimile: 208-344-0077
E-mail: [e-mail]
Tim Buller
PacifiCorp Idaho Industrial Customers
Agrium Us Inc.,fNu-West Industries
3010 Conda Rd
Soda Springs, ID, 83276-5301
E-mail: TBulleragrium.com
3. PIIC is a coalition of Idaho companies that are industrial customers
of Rocky Mountain Power ("RMP"). RMP's application for implementation of proposed
Schedule 31, Partial Requirements Service, is applicable only to high voltage customers
with loads up to 15,000 kW. Many PIIC members are high voltage customers with loads
that do not exceed 15,000 kW. PIIC has a direct and substantial interest in this
proceeding that will not be adequately represented by any other party, and may be
affected by any Commission determination made in connection with these proceedings.
PIIC intends to participate in all respects of this proceeding and will not unreasonably
broaden the issues, burden the record, or delay this proceeding.
4 Without the opportunity to intervene herein, PIIC would be
without a manner or means of participating in the lawful determination of issues which
will result in affecting the rates for electric service to the PIIC members.
WHEREFORE, PIIC respectfully requests that the Commission grant its
petition to intervene with full party status in this proceeding and to appear and participate
in all matters as may be necessary and appropriate; and to present evidence, call and
PETITION TO INTERVENE Page 2
examine witnesses, cross-examine witnesses, present argument, and to otherwise fully
participate in the proceedings.
Dated this I day of September, 2012.
Respectfully submitted,
1LV
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Facsimile: 208-344-0077
ronwilliamsbradbury.com
of Attorneys for PIIC
CERTIFICATE OF MAILING
IUf I HEREBY CERTIFY that on this ' day of September 14, 2012, I caused to be
served a true and correct copy of the foregoing document upon the following individuals in
the manner indicated below:
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: [e-mail]
LI Hand Delivery
LI US Mail (postage prepaid)
LI Facsimile Transmission
LI Federal Express JR Electronic Transmission
Daniel E. Solander LI Hand Delivery
Rocky Mountain Power LI US Mail (postage prepaid)
201 South Main, Suite 2300 LI Facsimile Transmission
Salt Lake City, UT 84111 LI Federal Express
E-Mail: Daniel.solanderpacificorp.com j Electronic Transmission
4 Zv
Ronald L. Williams
PETITION TO INTERVENE Page 3