20131211Petition to Intervene.pdf

Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27th Street
Boise, tdaho 83702
Telephone: [phone]
Fax: [phone]
peter@:ichardsonadams. com
gre g@ richardsonadams. com
Attorneys for the J. R. Simplot Company
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CASE NO. IPC-E-13-25
PETITION TO INTERVENE
OF THE J. R. SIMPLOT COMPANY
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TAzuFF ADVICE NO. )
13-05 OF IDAHO POWER COMPANY FOR )
AUTHORITY TO UPDATE SCHEDULE 86. )
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COMES NOW, The J. R. Simplot Company, hereinafter referred to as'olntervenor," 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:
1. The name and address of this Intervenor is:
J. R. Simplot Company
c/o Gregory M. Adams
Richardson Adams, PLLC
515 N.27ft Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
J.R. SIMPLOT CO. INTERVENTTON
CASE NO. IPC-E.13-25
PAGE I
2. This tntervenor will be represented herein by:
Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27ft Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
gre g@rishardsonadams. com
3. Copies of all pleadings, production requests, production responses, Commission
orders and other documents should be provided to Gregory M. Adams as noted above and to:
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone]
[e-mail]
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 operates a cogeneration
facility at its operations in Pocatello, Idaho. It has a PURPA contract providing for ldatro 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 ldaho 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-13-25
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.
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 present evidence, call and examine witnesses, present
argument and to otherwise fully participate in these proceedings.
DATED this 1lth day of December, 2013.
zuCHARDSON ADAMS, PLLC
J.R. SIMPLOT CO. INTERVENTION
CASE NO. IPC-E.13-25
PAGE 3
By
Of Attorneys for the J.R. Simplot Co.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the l lth day of December, 2}l3,a true and correct copy of
the within and foregoing PETITION TO INTERVENE BY THE J. R. SIMPLOT COMPANY,
Case No. IPC-E-13-25, was served by electronic mail and U.S. Mail, postage prepaid, to:
Donovan Walker
Idaho Power Company
1221 West Idaho Street (83702)
PO Box 70
Boise, Idaho 83707 -0070
dwalker@idahopower. com
Greg Said
Idaho Power Company
1221 West Idaho Street (83702)
PO Box 70
Boise, Idaho 83707 -0070
[e-mail]
Nina Curtis
Legal Assistant
J.R. SIMPLOT CO. INTERVENTION
CASE NO.IPC-E-13-25
PAGE 4