20180808JR Simplot Unopposed Motion to Stay.pdf

Peter J. Richardson, ISB No. 3195
Gregory M. Adams, ISB No. 7454
RICHARDSON ADAMS, P.L.L.C.
515 N.27th Street
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
Email : p eter @ichardsonadams. com
Email : gre [e-mail]
IN THE MATTER OF PETITION OF
IDAHYDRO, SHOROCK HYDRO, INC.,
J.R. SIMPLOT COMPANY, AND
RENEWABLE ENERGY COALITION FOR
MODIFICATION OF THE 9OlI IO
PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MATNTENANCE CHARGES FOR PURPA
QUALIFYTNG FACILITIES
REC E IV ED
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CaseNo. tPC -E- t8-o1
J.R. SIMPLOT COMPANY'S
UNOPPOSED MOTION TO STAY
PROCEEDINGS
Attorneys for Petitioner J.R. Simplot Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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Petitioner J.R. Simplot Company ("Simplot") hereby respectfully moves the the Idaho
Public Utilities Commission ("Commission") to stay all pending deadlines and proceedings in this
matter for 28 days or until such time before 28 days that any party moves to lift the stay, for the
reasons explained herein.
On April 16,2018, Petitioners ldaho Hydroelectric Power Producers Trust, an ldaho Trust,
d/bla ldahydro ("Idahydro"), Shorock Hydro, Inc. ("Shorock"), Simplot, and the Renewable
Energy Coalition ("REC") filed the petition initiating this proceeding. On July 25,2018, Idaho
Power Company ("Idaho Power") filed its cross-petition and/or petition in this proceeding. The
parties have engaged in several rounds of discovery since the filing of the initial petition, but no
procedural schedule has been established yet in this proceeding. By rule, there may be a 2l-day
J.R. SIMPLOT COMPANY'S UNOPPOSED MOTION TO STAY PROCEEDINGS
IPC-E-18-07
PAGE I
period to file an answer or motion to dismiss Idaho Power's cross-petition and/or petition, which
makes that deadline August 15,2018, absent an order by the Commission altering the deadline.
See RP 57.02. If the cross-petition is itself deemed a late answer, no response is necessary.
Since the filing of Idaho Power's cross-petition and/or petition, the original petitioners
(ldahydro, Shorock, Simplot, and REC) and Idaho Power have engaged in discussions as to
procedural and substantive matters related to the issues in dispute, and wish to complete those
discussion prior to the next procedural steps occur in this proceeding. Therefore, Simplot requests
that the Commission issue an order staying all pending deadlines and proceedings in this matter
for 28 days or until such time before 28 days that any party moves to lift the stay, and tolling
pending deadlines beginning on the date of this filing.
Counsel for Simplot has contacted all other parties to this proceeding, and no party opposes
the proposed stay of pending deadlines and proceedings.
*l'hDATED this0 ' day of August, 2018.
HARDSON ADAMS, P.L.L.C.
M. Adams
Peter J. Richardson
Attorneys for Petitioner J.R. Simplot
Company
J.R. SIMPLOT COMPANY'S UNOPPOSED MOTION TO STAY PROCEEDINGS
IPC-E-18-07
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th day of August 2018, I served a true and correct
copy of the foregoing document(s) upon the following person(s), in the matter indicated:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W Washington
Boise, Idaho 83702
Edith Pacillo
Deputy Attorney General
Idaho Public Utilities Commission
472W Washington
Boise, Idaho 83702
Donovan Walker
Idaho Power Company
l22l W Idaho Street
Boise, Idaho 83702
C. Tom Arkoosh
Idahydro
P.O. Box 2900
Boise, Idaho 83701
J. Kahle Becker
Renewable Energy Coalition
233 North 6th Street, #325
Boise, Idaho 83702
Irion Sanger
Renewable Energy Coalition
1l l7 SE 53'd Avenue
Portland, Oregon 97215
Michael C. Creamer
Preston N. Carter
Tamarack Energy Partnerships
P.O.Box2720
Boise, Idaho 83701
U.S. Mail, Postage Prepaid
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E-mail [e-mail]. gov
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x E-mail dwalker@rdahqpawel, c!M
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X E-mail tom.arkoos-h@,arkoosh.com
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pnc@ givenspursley. com
J.R. SIMPLOT COMPANY'S UNOPPOSED MOTION TO STAY PROCEEDINGS
IPC-E-18-07
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Michael G. Andrea
Avista Corporation
l4l1 E Mission Ave, MSC-23
Spokane, Washington 99202
X U.S. Mail, Postage Prepaid
Hand Delivered
X E-mail UOtshael.andrea@avis
Clint Kalich
Avista Corporation
l4l I E Mission Ave, MSC-7
Spokane, Washington 99202
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X E-mail [e-mail]
Kandi Walters
J.R. SIMPLOT COMPANY'S UNOPPOSED MOTION TO STAY PROCEEDINGS
IPC-E-18-07
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