20020405J.R. Simplot's Petition to Intervene.pdf

J.R.SIMPLOTCOMPANY ONE CAPITAÚÙEÑÍÉ 9 MAIN STÑÔEÍT SUITE1300
P.O.BOX 27 BOISE,IDAHO 83707-0027 {208/336-2110 FAX (ÖË)389-7515
CORPORATE HEADQUARTERS
April 4,2002
Jean D.Jewel
Idaho Public Utilities Commission
472 W.Washington
PO Box 83720
Boise,ID 83720-0074
Re:Case Nos.IPC-E-02-2 and IPC-E-02-3
Dear Ms.Jewel:
Enclosed for filing is the original and seven (7)copies of the Petition of J.R.Simplot CompanyforLeavetoInterveneintheabove-referenced cases.
Sincerely,
R.SCOTT PASLE o
Assistant General Counsel
RSP:jd/7062z
Enclosures
OR G NAL
R.SCOTT PASLEY p.oASSISTANTGENTERALCOUNSEL
J.R.SIMPLOT COMPANY
999 Main Street
P.O.Box 27
Boise,Idaho 83707
[phone]
[e-mail]
Attorneyfor J.R.Simplot Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )CASE NOS.IPC-E-02-2IDAHOPOWERCOMPANYFORANENERGY)IPC-E-02-3
COST FINANCING ORDER AND AUTHORITY )TO INSTITUTE AN ENERGY COST BOND )PETITION OF
CHARGE.)J.R.SIMPLOT COMPANY
)FOR LEAVE TO
)INTERVENEINTHEMATTEROFTHEAPPLICATIONOF)IDAHO POWER COMPANY FOR AUTHORITY )TO IMPLEMENT A POWER COST )ADJUSTMENT (PCA)RATE FOR ELECTRIC )SERVICE FROM MAY 16,2002 THROUGH )MAY 15,2003.)
COMES NOW,the J.R.Simplot Company,a corporation duly authorized
to conduct business in the state of Idaho,hereinafter referred to as "Intervenor",and
pursuant to the "Notice of Application"issued in the above captioned cases by the
Secretary of the Idaho Public Utilities Commission (Commission),and pursuant to this
Commission's Rules of Procedure,Rule 071,IDAPA 31.01.01071,petitions the
Commission for leave to intervene herein and to appear and participate herein as a party,
and as grounds therefore states as follows:
PETITION FOR LEAVE TO INTERVENE-1
1.The name and address of Intervenor is:
J.R.Simplot Company
Attn:David Hawk
Director,Energy Natural Resources
999 Main Street
P.O.Box 27
Boise,Idaho 83702
[phone]
[phone] telefax
Intervenor will be represented herein by:
R.Scott Pasley
Assistant General Counsel
J.R.Simplot Company
999 Main Street
P.O.Box 27
Boise,Idaho 83702
[phone]
[phone] telefax
Copies of all pleadings,production requests,production responses,Commission orders
and other documents should be provided to David Hawk and R.Scott Pasley as noted
above.
2.This Intervenor,the J.R.Simplot Company,is a Nevada corporation duly
authorized to conduct business in the state of Idaho.
3.This Intervenor is directly and substantially interested in the above-
captioned proceeding in that it is a both a special contract customer at its Pocatello
fertilizer facility and a Schedule 19 customer at several food processing facilities in Idaho
Power's service territory.
4.This Intervenor intends to participate herein as a party,and if necessary to
introduce evidence,cross-examine witnesses,call and examine witnesses,and be heard in
PETITION FOR LEAVE TO INTERVENE-2
argument.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 means of participation in the lawful determination of issues raised by the
Commission in its Notice of Application.
WHEREFORE,the J.R.Simplot Company requests that this Commission
grant this 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 participate in these proceedings.
DATED at Boise,Idaho this Ѿday of April,2002.
Respectfully submitted,
By:
R.Scott Pasley
Assistant General Counsël
of the J.R.Simplot Company
PETITIONFOR LEAVE TO INTERVENE-3
CERT1FICATE OF SERVICE
I HEREBY CERTIFY that I have this y day of April,2002,served the
foregoing Petition to Intervene by the J.R.Simplot Company upon all parties of record in
this proceedings,by mailing a copy thereof,properly addressed with postage prepaid,to:
Larry D.Ripley
Senior Attorney
Idaho Power Company
P.O.Box 70
Boise,Idaho 83707-0070
John R.Gale
Vice President Regulatory Affairs
Idaho Power Company
P.O.Box 70
Boise,Idaho 83707-0070
R.Scott Pasley
9076z
PETITION FOR LEAVE TO INTERVENE-4