20131106Petition to Intervene.pdf

Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
gre g@richardsonadams. com
Attomeys for the J. R. Simplot Company
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CASE NO. IPC-E-13-21
PETITION TO TNTERVENE
OF THE J. R. SIMPLOT COMPANY
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
TN THE MATTER THE APPLICATION OF )IDAHO POWER COMPANY FOR )APPROVAL OF SAR METHODOLOGY )
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COMES NOW, The J. R. Simplot Company, hereinafter referred to as "Interyenor," and
pursuant to this Commission's Rule of Procedure, Rule 07 I , IDAPA 3 I . l0 .0107 4, 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:
l. The name and address of this Intervenor is:
J. R. Simplot Company
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N.27ft Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
J.R. SIMPLOT CO. INTERVENTION
CASE NO. IPC-E-13-21
PAGE I
2. This Intervenor will be represented herein by:
Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
fuchardson Adams, PLLC
515 N. 27ft Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(@:ichardsonadams. com
gre g@richardsonadams. com
3. 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
[phone]
dreadin g@mindspring. com
4. 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 PURPA contract providing for Idaho Power to
purchase the output of that plant. That contract that is due to expire in 2015. The J.R. Simplot
Company plans to obtain a new PURPA 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 ldaho with the goal of obtaining PURPA contracts with Idaho Power
and possibly other utilities. The J.R. Simplot Company therefore claims a direct and substantial
interest in this proceeding because its ability to make such sales will be affected by the outcome
of this proceeding.
J.R. SIMPLOT CO. INTERVENTION
CASE NO. IPC.E.13-21
PAGE 2
5. 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
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.
6. 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 ability to enter
into PURPA contracts in the State of Idaho.
7. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
WIIEREFORE, 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 present evidence, call and examine witnesses, present
argument and to otherwise fully participate in these proceedings.
DATED this 6th day of November, 2013.
RICHARDSON ADAMS, PLLC
J.R. SIMPLOT CO. INTERVENTION
CASE NO. IPC-E-13.21
PAGE 3
Of Attorneys for the J.R. Simplot Co.
CERTIF'ICATE OX' SERVICE
I HEREBY CERTIFY that on the 6th day of November,2013, a true and correct copy of
the within and foregoing PETITION TO INTERVENE BY THE J. R. SIMPLOT COMPANY ,
Case No. IPC-E-13-21, was served by electronic mail and U.S. Mail, postage prepaid, to:
Donovan Walker
Idaho Power Company
l22l West Idaho Street (83702)
PO Box 70
Boise, Idatro 837 07 -007 0
E-mail: [e-mail]
dockets@ idahopower. com
Randy Allphin
Tess Park
Idaho Power Company
1221 West Idatro Street (83702)
PO Box 70
Boise, Idatro 83707 -0070
E-mail : [e-mail]
tpark2 @ idahopower. com
Jean Jewell, Secretary
Idaho Public Utilities Commission
472West Washington
Boise, lD 83702
Jeanj [e-mail]. gov
C}'.r..^Nrano,t
Nina Curtis
Legal Assistant
J.R. SIMPLOT CO. INTERVENTION
CASE NO. IPC-E-13.21
PAGE 4