20130729Petition to Intervene.pdf

Peter J. Richardson
ISB No. 3195
Gregory M. Adams
ISB No. 7454
Richardson Adams
515 N.27th Street
Boise,Idatro 83616
Telephone: [phone]
Fax: [phone]
Attorneys for the J. R. Simplot Company
BEFORE THE
IDAHO PUBLIC UTILITIES COMMTSSION
IN THE MATTER OF IDAHO POWER )
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COMPANY'S 2OI 3 INTEGRATED
RESOURCE PLAN
) cnsp No. IPC-E-I3-Is
)) psrnroN To INTERVENE) or rHE J. R. srMPLor coMPANY
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COMES NOW, The J. R. Simplot Company, hereinafter referred to as "Intervenor," and
pursuant to this Commission's Rule of Procedure, Rule 071, IDAPA 31.10.01074, 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:
The name of this Intervenor is:
J. R. Simplot Company
Simplot lntervention - IPC-E-13-l 5
This Intervenor will be represented herein by:
Peter J. Richardson, Esq.
515 N. 27ft Street
Boise, Idaho 83616
Telephone: [phone]
Fax: [phone]
peter@ richardsonadams. com
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-t700
dreading@mindspring. com
This Intervenor, the J. R. Simplot Company, is a large consumer of electricity in the State
of Idaho. The J. R. Simplot Company receives electric utility services from the Applicant under
multiple tariff schedules including as an irrigator, at its commercial enterprises, and as large
power service customers under Schedule 19. In addition the J. R. Simplot Company is a special
contract customer at its Don Plant in Pocatello, Idaho. As such, the J. R. Simplot Company
claims a direct and substantial interest in this proceeding.
This Intervenor, in its capacity as a multi-faceted electrical customer, 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 of other evidence in this
proceeding.
Simplot Intervention - trC-E-13-15
Without the opportunity to intervene herein, this Intervenor would be without any means
of participation in this proceeding which may have a material impact on its electric rates. No
other party represents this Intervenor's interests herein.
WHEREFORE, the J. R. Simplot Company 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 participate in these proceedings.
DATED this 29th day of July,20l3.
Richardson Adams, P LLC
By
Attorneys for the J. R. Simplot Company
Simplot Intervention - trC-E-13-15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th day of July , 2013, a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY THE J. R. SIMPLOT COMPANY, Case
No. IPC-E-13-15, was served by electronic mail and U.S. Mail, postage prepaid, to:
Lisa D. Nordstrom
Idaho Power Company
1221 West Idaho Street (83702)
PO Box 70
Boise, Idaho 83707 -0070
E-mail: [e-mail]
Jennifer Reinhardt-Tessmer
Idaho Power Company
1221 West Idaho Street (83702)
PO Box 70
Boise, Idaho 83707 -0070
E-mail : ireinhardt@idahopower. com
Ken Miller
Snake River Alliance
PO Box 1731
Boise,Idaho 83701
kmiller@ snakeriveralliance. or g
Ben Otto
Idaho Conservation League
710 N. 6n Street
Boise,Idaho 83701
botto @ idaho conservation. org
QrL /YV"' ,
Nina Curtis
Simplot lntervention - IPC-E-13-l 5
Legal Assistant