20150106Petition to Intervene.pdf

Peter J. Richardson (ISB No. 3195)
Greg Adams (ISB 7454)
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise,Idatro 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonandoleary. com
Attorneys for the Industrial Customers of tdaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DIBI AROCKY
MOUNTAIN POWER AND IDAHO
POWER COMPANY FOR AN ORDER
AUTHORIZING THE EXCHANGE OF
CERTAIN TRANSMISSION ASSETS.
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CASE NO. IPC-E-14-41
CASE NO. PAC-E-I4-I1
PETTTION TO TNTERVENE
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
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COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as
"lntervenor," and pursuant to this Commission's Rules of Procedure, Rule 7l TDAPA
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:
lndustrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson & O'Leary
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonandoleary. c om
Intervention - IPC-E- 14-41: PAC-E- 14-l I
Copies of all pleadings, production requests, production
responses, Commission orders and other documents should be
provided to Peter J. Richardson as noted above and to:
Dr. Don Reading
6070 Hill Road
Boise,Idaho 83703
(208) 342-t700Tel
(208) 384-151 1 Fax
dr eading@mi ndspri n g. co m
2. This Intervenor, the lndustrial Customers of Idaho Power, ("ICIP") is an
unincorporated association of Schedule 19 customers of ldaho 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 the outcome will affect the company's electric rates for its
industrial customers.
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, submit comments, and
fully participate in any hearing that may occur including the calling and cross examination of
witnesses. 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
effective means of participation in this proceeding which may have a material impact on its
members' electric rates and/or service.
lntervention - IPC-E-08-13: PAC-E-14-l I
6. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
WIIEREFORE, the Industrial Customers of Idaho Power respectfully requests that this
Commission grant its Petition to lntervene 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, present argument at any hearing that may occur, and to otherwise fully participate in
these proceedings.
DATED this 6th day of January 2015.
Richardson Adams, PLLC
Peter J. Richardson
Industrial Customers of Idaho Power
Intervention - IPC-E-08-13; PAC-E-I4-I I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of January,20l5, a true and correct copy of the
within and foregoing PETITION TO TNTERVENE BY THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER, was served as indicated below to:
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
P O Box 83720
Boise ID 83720-0074
Julia A. Hilton
Regulatory Dockets
Idaho Power Company
l22l West Idaho Street
Boise, Idaho 837 07 -007 0
j hilton@ idahopower.com
dockets@ idahopower.com
Daniel Solander
Rocky Mountain Power
201 South Main Street, Ste. 2300
Salt Lake City, UT 841I I
Daniel. solander@pacifi corp. com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Ste. 2000
Portland, OR97232
datareq uest@pacifi corp. com
Nina Curtis
Administrative Assistant
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Intervention - trC-E-08-l3t PAC-E-14-l I