20170606Petition to Intervene.pdf

Peter J. Richardson, tSB No. 3195
Richardson Adams, PLLC
515 N. 27tr Street
P.O. Box 7218
Boise, tdatro 83702
Telephone: [phone] Tel
peter@richardsonadams. com
Attorneys for the J. R. Simplot Company
,l. ".; -5 Pil il: ;5
0
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR.E-17-02
IN THE MATTER OF THE APPLICATION OF
THE ANNUAL UPDATE TO PUBLISHED
AVOIDED COST RATES TO REFLECT AN
UPDATED NATURAL GAS PRICE
FORECAST OF THE U.S. ENERGY
TNFORMATION AGENCY (EIA)
)
)
)
)
)
)
)
PETITION TO TNTERVENE
OF THE J. R. SIMPLOT COMPANY
COMES NOW, The J. R. Simplot Company, hereinafter referred to as "Intervenor," and
pursuant to this Commission's Rules of Procedure, Rule 7l 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 ts
J. R. Simplot Company
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27n St
P.O. Box 7218
Boise,Idatro 83702
Telephone: [phone]
Fax: [phone]
oeter@.richardsonadams. com
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter Richardson as noted above and to:
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreading@mindspring. com
2. This Intervenor, the J. R. Simplot Company is a customer of ldaho Power and
takes retail electric service under multiple Idaho Power electric rate schedules. The J. R. Simplot
Company currently sells electric power and energy to ldaho Power pursuant to two separate
PURPA contracts and has the potential to sell additional electric power and energy at other
possible cogeneration and small power production locations in Idaho. In addition, the J. R.
Simplot Company participates in various [daho Power sponsored electric demand reduction and
conservation programs. Therefore, the J. R. Simplot Company claims a direct and substantial
interest in this proceeding in that, (1) its rates for electrical service from ldaho Power, (2) the
prices it receives for electrical sales to Idaho Power and (3) the economic threshold for
participation in demand and conservation programs may all be affected by the outcome of this
proceeding.
3. The J. R. Simplot Company intends to participate herein as a party, 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 will introduce is
dependent upon the nature and effect ofother evidence in this proceeding.
4. Without the opportunity to intervene herein, this lntervenor would be without any
means of participation in this proceeding which may have a material impact on, (l) the rates it
pays for electrical services, (2) the prices it receives for electric sales to Idaho Power and (3) the
2Intervention - GNR-E-l 7-02
economic threshold for its participation in demand side management and energy conservation
programs offered by Idaho Power.
5. Granting the J. R. Simplot Company's petition to intervene will not unduly
broaden the issues nor will it prejudice any party to this case.
WHEREFORE, the J. R. Simplot Company 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 fully participate in these proceedings.
DATED this 6fr day of June 2017
Adams, PLLC
By:
Peter J. Richardson, Attorney for
J. R. Simplot Company
3Intervention - CNR-E- I 7-02
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of June 2017, a true and correct copy of the within and
foregoing PETITION TO INTERVENE BY THE J. R. SIMPLOT COMPANY in Docket No.
GNR-E-17-02 was served by electronic mail and United States Mail, postage prepaid, to:
Diane Hanian
Commission Secretary
472 W est Washington Street
Boise,Idaho 83702
Diane.hanian@puc. idaho. gov
Donovan Walker
Idaho Power Company
1221 West ldaho Street
Boise, Idatro 83702
dwalker@ idahopower. com
Daniel MacNeil
PacifiCorp
825 NE Multnomah Street
Portland, OR97232
Daniel. macnei l@ pacifi corp. com
Kandi Walters
Clint Kalich
Avista Utilities
1411 East Mission Street
Holland &Hart
POBox3727
Spokane, WA99220-3727
Clint. [e-mail]
Yvonne Hogle
Ted Weston
PacifiCorp
1407 West North Temple, Ste. 330
Salt Lake City, UT 84116
yvonne.ho gle@pacifi corp. com
ted. weston@pacifi corp.com
4Intervention - GNR-E-l 7-02