20210224Petition to Intervene.pdf

Norman M. Semanko,ISB No. 4761
Parsons Behle &Latimer
800 West Main Street, Suite 1300
Boise,Idaho 83702
Telephone: [phone]
Vicki M. Baldwin, pro hac vice pending
Parsons Behle & Latimer
201 South Main Street, Suite 1800
Salt Lake City, UT 841l l
Telephone: [phone]
Attomeys for Walmart Inc.
IN THE MATTER OF THE
APPLICATOIN OF AVISTA
CORPORATION FOR THE
AUTHORITY TO TNCREASE ITS
RATES AND CHARGES FOR
ELECTRIC CUSTOMERS IN THE
STATE OF IDAHO
BEFORE TIIE PUBLIC UTILITIES COMMISSION OF IDAHO
Case No. AW-E-21-01
PETITION TO INTERVENE OF WALMART
INC.
Pursuant to Rules 72-75 of the Idaho Public Utilities Commission's Rules of Practice and
Procedure, Walmart Inc. ("Walmart") petitions the ldaho Public Utilities Commission
("Commission" or "IPUC') for leave to intervene in the above-captioned matter. In support of
this petition, Walmart states as follows:
1. The names and addresses of the representatives of Walmart are:
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise,Idaho 83702
Telephone: [phone]
[e-mail]
Vicki M. Baldwin, pro hac vice pending
Parsons Behle & Latimer
201 South Main Street, Suite 1800
Salt Lake city, uT 8411I
Telephone: [phone]
vbaldwin@parsonsbehle. com
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I
Steve W. Chriss
Director, Energy Services
Walmart [nc.
2608 Southeast J Street
Bentonville, Arkansas 72716
Telephone: [phone]
Stephen. C hri ss@walmart. com
Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the names and addresses above. In the interest of
conservation and cost reduction, please provide hard copies of pleadings, testimony, and briefs
only. All other documents may be provided via electronic mail in accordance with IPUC Rules
31.01.01.063.02-.03.
2. Walmart is an American multinational retail corporation with stores in all fifty (50)
states and Puerto Rico. Walmart has 27 facilities in Idaho with over 8,000 associates. Six ofthose
facilities take electric service from Avista Corporation ("Avista").
3. Walmart has a direct, immediate, diverse and substantial interest in the outcome of
this case, and the interests of Walmart will not be adequately represented by any other party to this
proceeding. A Commission decision in this proceeding will have a direct, material impact on the
electric rates and terms and conditions of service Walmart will be subject to as a result of this case.
4. Walmart anticipates participating in this matter to the extent necessary to ensure its
interests in ldaho are protected, with full rights of a parly to perform discovery, submit testimony,
examine witnesses, participate in hearings and present evidence on any issues raised in this matter.
5. Walmart has not yet determined the extent of its participation or the precise nature
of the relief it will request but the interests of justice and the orderly and prompt conduct of this
proceeding will not be impaired by the grant of Walmart's petition to intervene. Neither will
Walmart's participation unnecessarily broaden the issues or burden the record in this proceeding.
WHEREFORE, Walmart respectfully requests that the Commission grant its Petition to
Intervene in this matter with full party status.
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DATED this 23rd day of February 2021
/s/ Vicki M. Baldwin /s/Norman M. Semanko
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CERTIFICATE OF SERVICE
(CaseNo. AVU-E-21-01)
I hereby certify that on this 23rd day of February 202L,I caused to be served by e-mail, a
true and correct copy of this PETITION TO INTER\IENE OF WALMART INC. to:
AVISTA CORPORATION
David J. Meyer, Esq.
Dav i d. Meyer@av istacorp.com
Patrick D. Ehrbar
[e-mail]
A v i stadockets@av i stacorp.com
IoeHo ColrlspRveuoN LEAGI.JE
Benjamin J. Otto
botto@ idahoconservation.org
Dainee Gibson -Webb
D [e-mail]
Ioeuo Pust.rc Urn rrms CouprssroN
Jan Noriyuki
[e-mail]. gov
i an.noriyuki@ouc. idaho. gov
Dppurv ArroRNrv GpusRAL
John Hammond
John.hammond@nuc. idaho. gov
/s/ Madeline Malmsuist
4
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