20101108Petition to Intervene.pdf

~r.QJLJG~-.~ATTORNEYS AT LAW iotfiMOV -8 AM 9: 2'+
Peter Richardson i.=..u
L'''UTi IIITel: 208-938-7901 Fax: [phone]
peterli t ¡chardso 0 andol eary. co m
p.o. Box 1218 Boise, ID 83707 - sis N. 27th St. Boise, ID 83702
8 November 2010
Ms. Jean Jewell
Commission Secreta
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
RE: GNR-E-IO-04
Dear Ms. Jewell:
We are enclosing an original and seven copies of the PETITION TO INTERVENE OF
THE J. R. SIMPLOT COMPANY in the above case. Would you please fie the same
Than you for your attention to this matter. Please feel free to give me a call if you have
any questions.S?.:o
Peter J. Richardson
Richardson & O'Lear PLLC
Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richardson & O'Leary, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(frichardsonandoleary.com
greg(frichardsonandoleary.com
R'EC-El\!D
Z91ûNOV -8 AM 9:24
Attorneys for the J. R. Simplot Company
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION )
OF IDAHO POWER COMPANY, A VISTA ) CASE NO. GNR-E-10-04
CORPORATION, AND ROCKY MOUNTAIN )
POWER TO ADDRESS AVOIDED COST ) PETITION TO INTERVENE
ISSUES AND JOINT MOTION TO ADJUST ) OF THE J. R. SIMPLOT COMPANY
THE PUBLISHED AVOIDED COST RATE )ELIGIBILITY CAP. )
)
COMES NOW, The J. R. Simplot Company, hereinafter referred to as "Intervenor," or
the "Company," and pursuant to this Commission's Rules of Procedure, Rule 71 IDAPA
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:
1. The name and address of this Intervenor is:
J. R. Simplot Company
c/o Peter J. Richardson
Richardson & O'Leary
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peterêrichardsonandoleary.com
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter J. Richardson and Gregory M. Adams as noted
above and to:
Don Sturevant
Energy Director
J. R. Simplot Company
ONE CAPITAL CENTER
999 Main Street, P.O. Box 27
Boise, Idaho 83707-0027
Telephone [phone]
Fax: [phone]
Don. sturtevant(fsimplot.com
2. This Intervenor, the J. R. Simplot Company is a corporation duly qualified to do
business in the State of Idaho. The J. R. Simplot Company currently has a cogeneration facility
at its operations in Pocatello, Idaho. It has a PURP A contract providing for Idaho Power to
purchase the output of that plant. That contract that is due to expire soon. The Company plans
to obtain a new PURP A contract with Idaho Power for that Pocatello cogeneration facility in the
near future. In addition, the Company is pursuing other energy projects on its property in Idaho
with the goal of obtaining PURP A contracts with Idaho Power and possibly other utilities. The
Company therefore claims a direct and substatial interest in this proceeding in that its ability to
make such sales will be affected by the outcome of this proceeding.
3. This Intervenor intends to paricipate herein as a par, 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 wil introduce is dependent
upon the natue and effect of other evidence in this proceeding.
Intervention J. R. Simplot Company GNR-E-lO-04 2
4. Without the opportity to intervene herein, this Intervenor would be without any
means of paricipation in this proceeding which may have a material impact on its ability to enter
into PURP A contracts in the State of Idaho.
5. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor wil it prejudice any pary to this case.
WHEREFORE, the J. R. SimplotCompany respectfully requests that this Commission
grant its Petition 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, present
argument and to otherwise fully paricipate in these proceedings.
DATED this 8th day of November, 2010.
RICHARDSON AND O'LEARY, PLLC
~g(. ~By
Peter J. Richardson
J. R. Simplot Company
Intervention J. R. Simplot Company GNR-E- i 0-04 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th day of November, 2010, a true and correct copy of
the within and foregoing PETITION TO INTERVENE BY the J. R. SIMPLOT COMPANY was
served by ELECTRONIC MAIL and US MAIL, to:
Donovan E. Walker
Lisa Nordstrom
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707-0070
dwalker(fidahopower .com
lnordstrom(fidahopower .com
Daniel E. Solander
Rocky Mountain Power
201 South Main
Salt Lake City, UT 84111
Daniel.solander(fpacificorp.com
Michael G. Andrea
A vista Corporation
1411 East Mission Avenue - MSC-23
Spokane, W A 99202
Michael.andrea(favistacorp.com
Jean Jewell
Commission Secretar
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
Jean. j ewell(fpuc.idaho. gov
Intervention J. R. Simplot Company GNR-E-IO-04 4