20150202Petition to Intervene.pdf

Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (tSB No. 7454)
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
gr e g@richardsonadam s. c om
Attorneys for the J. R. Simplot Company
ru [:f [: l',, '' i ,
?0i5 FEB -2 Pli 3: L9
It-,,';ri-rl ,
l-t.i I LlTl i: ii {"lCiir, i.i I li li r r.;i ;
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITTON TO MODIFY
TERMS AND CONDITIONS OF
PROSPECTIVE PURPA ENERGY SALES
AGREEMENTS.)
)
)
)
CASE NO. IPC-E-I5-OI
PETITION TO INTERVENE
OF THE J. R. SIMPLOT COMPANY
COMES NOW, The J. R. Simplot Company, hereinafter referred to as "lntervenor," 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:
l. The name and address of this Intervenor is:
J. R. Simplot Company
Attn: Don Sturtevant
P.O. Box 27
Boise, ID 83707
PETITION TO INTERVENE OF J.R. SIMPLOT CO.
CASE NO. IPC-E-I5-OI
PAGE I
)
)
)
)
2. This Intervenor 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
gr e g@ichardsonadams. com
3. Copies of all pleadings, production requests, production responses, Commission
orders and other documents should be provided to:
Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27s Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise,Idaho 83703
[phone]
dreading@mindspring. com
4. This Intervenor, the J. R. Simplot Company is a corporation duly qualified to do
business in the State of ldaho.
5. The J. R. Simplot Company currently operates a qualifring facility ("QF") at its
operations in Pocatello, Idaho, which utilizes waste heat in an industrial cogeneration process
and has a nameplate capacity of 15.9 megawatts ("MW"). It has a PURPA contract providing
PETITION TO INTERVENE OF J.R. SIMPLOT CO.
CASE NO. TPC.E.I5.OI
PAGE 2
for Idaho Power to purchase the output of that plant and recently into a one-year
replacement contract for that PURPA facility.
6. In addition, J.R. Simplot Company is pursuing other energy projects on its
properties in Idaho with the goal of obtaining PURPA contracts with ldaho Power and possibly
other utilities. J.R. Simplot Company recently contacted Idaho Power to request indicative
pricing for a 25-MW cogeneration QF to be developed at the new Idaho Project potato
processing facility in Caldwell, Idaho.
7. 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 where ldaho Power proposes to modifu the terms and conditions of prospective
energy sales agreements for facilities that are ineligible for standard avoided cost rates.
8. This lntervenor 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.
9. 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 ldaho.
10. 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
PETITION TO INTERVENE OF J.R. SIMPLOT CO.
CASE NO. IPC-E-I5.OI
PAGE 3
may be necessary and appropriate; and to present evidence, call and examine witnesses, present
argument and to otherwise fully participate in these proceedings.
1
DATED this 2I day of February, 2015.
zuCHARDSON ADAMS, PLLC
By
Of Attomeys for the J.R. Simplot Co.
PETITION TO INTERVENE OF J.R. SIMPLOT CO.
CASE NO. IPC.E.I5.O1
PAGE 4
CERTIF'ICATE OX' SERVICE
I HEREBY CERTIFY that on tfreAA day of February, 2015,a true and correct copy of
the within and foregoing PETITION TO INTERVENE OF THE J. R. SIMPLOT COMPANY,
Case No. IPC-E-15-0lo was served by U.S. Mail, postage prepaid, to:
Donovan Walker
Idaho Power Company
1221 West Idatro Street (83702)
PO Box 70
Boise, Idalro 83707 -0070
dwalker@idatropower. com
(-),r., r-f''n{hs
Nina Curtis
Legal Assistant
PETITION TO INTERVENE OF J.R. SIMPLOT CO.
CASE NO. IPC-E-I5.OI
PAGE 5