20180417Petition to Intervene - PAC.pdf

WILLIAMS BRADBURY
ATTORNEYSATLAW
April 17,2018
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
412W. Washington
Boise,ID 83702
Re: GNR-U-18-01
Dear Ms. Hanian:
Please find enclosed for filing in the above referenced case the original and seven
copies of PacifiCorp Idaho Industrial Customers' Petition for Leave to Intervene.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerely,( ftz+
Michelle E. Williams
Law Clerk
P.O. Box 388 - Boise, ID 83701
Phone: [phone] - www.williamsbradbury.com
k
MEW
Enclosures
Ronald L. Williams,ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
Telephone: [phone]
Fax: [phone]
ron @ williamsbradbury.com
Attorneys for PIIC
IN THE MATTER OF THE APPLICATION )
REQUESTING AUTHORITY TO REDUCE )
RETATL RATES BY $2.8 MILLION TO )
PASS A PORTION OF THE20L7 FEDERAL)
TAX REFORM ACT COST SAVINGS )
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BEFORE THE IDAHO PUBLIC UTILITES COMMISSION C)
Case No. GNR-U-18-01
PETITION OF PACIFICORP IDAHO
INDUSTRIAL CUSTOMERS
FOR LEAVE TO INTERVENE
ONTO CUSTOMERS )
Pursuant to Rules 7l through 73 of the Idaho Public Utilities Commission's Rules
of Practice and Procedure, PacifiCorp Idaho 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. PIIC recognizes that Commission Order No. 33991 established March 6, 2018 as
the date for interventions to be filed in this case, and that this Petition for Intervention is late.
lntervenor believes the following reasons establish good cause as to why this late filed Petition
should be granted:
a. Intervenor regularly monitors PacifiCorp electric rate cases filed with the
Commission on the Commission's website under the "Electric Cases" category.
Intervenor was expecting to see this tax related case for PacifiCorp/Rocky
Mountain Power (PAC/RMP) filed as an "Open Case" under "Electric" utilities.
Unexpectedly [from this Intervenor's point of view], the case was logged as a
GNR case and also not listed as an "Open Case" for PAC/RMP, or for any utility
PIIC PETITION TO INTERVENE Page 1
for that matter, and was not noticed by this Intervenor in the course of regular
monitoring.
b. This Intervenor has no knowledge of receiving the Commission's official notice
of this case, Order No. 33991 dated February 22,2018.If the Order was in fact
received, Intervenor failed to note that this GNR case would impact PAC/RMP
and its electric rates charged PIIC members.
c. To date the Commission has not given notice of PAC/RMP's Application filed
March 30, 2018 and the Company did not serve the Application on this lntervenor
as it does in most rate cases as a courtesy.
d. There are no known active settlement discussions between the Company and Staff
with respect to the Company's Application by reason of which there would be no
delay or prejudice to either by the granting of this late filed Petition to Intervene.
The name and address of PIIC is:
PacifiCorp Idaho Industrial Customers
c/o Williams Bradbury, P.C.
P.O. Box 388
Boise, ID 83701
3. PIIC will be represented in this proceeding by Williams Bradbury, P.C. A11
documents relating to these proceedings should be served on the following persons at the
addresses listed:
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
Telephone: [phone]
Facsimile : 208 -3 43 -5 456
E-mail: ron @ will iamsbradbury.com
In addition, all pleadings, papers, orders and notices should be served upon the following persons
at the addresses listed below:
Bradley G. Mullins
1750 SW Harbor Way, Suite 450
Portland, OR 97201
Phone: [phone]
hrrnLr I I ins @' nrwanirlytics.conr
2
PIIC PETITION TO INTERVENE Page2
IELECTRONIC COPIES ONLY TO:l
Jim Duke
Idahoan Foods
E-mail: j duke @ idahoan.com
Kyle Williams
BYU Idaho
Email: [e-mail]
Val Steiner
Nu-West Industries, Inc.
Email: val.steiner@ agrium.com
PIIC has a direct and substantial interest in this proceeding that will not be
adequately represented by any other party. PIIC intends to participate in all respects of this
proceeding and will not unreasonably broaden the issues, burden the record, or delay this
proceeding. 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.
5. PIIC recognizes this is a multi-utility docket and wishes only to participate in the portion
of this case as it relates to PAC/RMP. In the interest of efficiency and to avoid unnecessary
filings and mailings, PIIC hereby waives services of all process, including pleadings, documents,
disks and electronic files in this matter that are not relevant to PAC/RMP.
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
that may be necessary and appropriate; and to present evidence, call and examine witnesses,
4
PIIC PETITION TO INTERVENE Page 3
cross-examine witnesses, present argument, and to otherwise fully participate in the proceedings.
Dated this I 7 day of April, 2018.
submitted,
L\
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for PIIC
PIIC PETITION TO INTERVENE Page 4
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on tfri. ShV of April, 2018, I caused to be served a
true and correct copy of the foregoing document upon the following individuals in the
manner indicated below:
Diane M. Hanian, Secretary
Idaho Puhlic Utilities Commission
P.O. Box 83702
472 W . Washington Street
Boise, lD 83702-0074
E-Mail: [e-mail]
xtr Hand Delivery
US Mail (postage prepaid)
! FacsimileTransmission
! Federal Express
! Electronic Transmission
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
salt Lake ciry, uT 84116
E-Mail: [e-mail]
Yvonne R. Hogle
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake Ciry, UT 84116
E-Mail: [e-mail]
Randall C. Budge
Racine, Olson, Nye & Budge, Chtd.
2Ol E. Center
PO Box 1391
Pocatello, ID 83204-1391
E-Mail: rcb @racinelaw.net
Attorney for Monsanto Company
Brubaker & Associates
16690 Swingley Ridge Road, #140
Chesterfield, Mo 63017
E-Mail: [e-mail]
kiverson @ consultbai.com
Monsanto Company
Jim Duke
Idahoan Foods
357 Constitution Way
Idaho Falls,ID 83742
E-Mail : [e-mail]
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
! Federal Express
I Electronic Transmission
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US Mail (postage prepaid)
Facsimile Transmission
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I Electronic Transmission
Hand Delivery
US Mail (postage prepaid)
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PIIC PETITION TO INTERVENE, Page 5
PIIC
Kyle Williams
BYU Idaho
Email: [e-mail]
PIIC
Val Steiner
Nu-West Industries, Inc.
Email: [e-mail]
PIIC
Bradley G. Mullins
1750 SW Harbor Way, Suite 450
Portland, OR 97201
Phone: [phone]
brnr u I I i ns @ mwanalytics.corn
! Hand Delivery
E US Mail (postage prepaid)
! Facsimile TransmissiontrxFederal Express
Electronic Transmission
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
[l Electronic Transmission
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US Mail (postage prepaid)
Facsimile Transmission
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I Electronic Transmission
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Mictfelle E. Williams
PIIC PETITION TO INTERVENE, Page 6