20100621Petition to Intervene.pdf

Peter J. Richardson
ISB No. 3195
Greg Adams
ISB NO. 7454
Richardson & O'Lear
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(qrichardsonandoleary.com
RECEiVED
iom JUN 21 l\liU:l¡'
Attorneys for Exergy Development Group of Idaho
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF A REVIEW OF THE )
SUROGATE AVOIDABLE RESOURCE ~
(SAR) METHODOLOGY FOR )
CALCULATING PUBLISHED AVOIDED )
COST RATES )
)
)
)
)
CASE NO. GRN-E-09-03
PETITION TO INTERVENE
OF EXERGY DEVELOPMENT
GROUP OF IDAHO
COMES NOW, Exergy Development Group ofIdaho, LLC, hereinafter referred to as
"Intervenor," and pursuat to this Commission's Rules of Procedure, Rule 71 IDAPA
31.01.01.71 hereby petitions the Commission for leave to intervene herein and to appear and
paricipate herein as a par, and as grounds therefore states as follows:
1. The name and address of this Intervenor is:
Exergy Development Group of Idaho
c/o Peter J. Richardson
Richardson & O'Lear
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Intervention - GNR-E-09-03 i
Fax: [phone]
peter(qrichardsonandolear .com
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 Hil Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreading(qmindspring.com
2. This Intervenor, Exergy Development Group of Idaho, LLC ("Exergy") is an
Idaho limited liability company in the business, inter alia, of development wind energy projects.
Many of the wind energy projects developed by Exergy are so-called PURP A projects. Exergy
claims a direct and substatial interest in this proceeding in that the outcome will affect the rates
investor-owned utilities subject to this Commission's jurisdiction offer to purchase the output
from Exergy-developed wind projects.
3. This Intervenor, in its capacity intends to participate herein as a pary, and if
necessar, to introduce evidence, submit comments, and fully participate in any hearng that may
occur including the callng and cross examination of witnesses. The natue and quality of
evidence which this Intervenor will introduce is dependent upon the natue and effect of other
evidence in this proceeding.
Intervention - GNR-E-09-03 2
5. Without the opportunity to intervene herein, this Intervenor would be without any
effective means of paricipation in this proceeding which may have a material impact on its
abilty to continue doing business in Idaho.
6. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor wil it prejudice any pary to this case.
WHEREFORE, Exergy Development Group of Idaho, LLC respectfully requests that
this Commission grant its Petition to Intervene in these proceedings and to appear and paricipate
in all matters as may be necessar and appropriate; and to present evidence, call and examine
witnesses, present arguent at any hearing that may occur, and to otherwse fully paricipate in
these proceedings.
DATED this 21 st day of June 2010.
Richardson & O'Lear, LLP
ByrPJ(~
Peter J. Richarason
Richardson & O'Leary, PLLC
J
Interention - GNR-E-09-03 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 21st day of June, 2010, a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY EXERGY DEVELOPMENT GROUP
OF IDAHO, PLLC, was served by the method indicated below, and addressed to the following:
Jean Jewell
Commission Secreta
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
Hand Delivery
Scott Woodbur
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington St.
Boise, Idaho 83702
Hand Delivery
Michael Andrea
A vista Corporation
1411 East Mission Ave.
P.O. Box 3727
Spokane, Washington 99220
U.S. Mail
Daniel E. Solander
Rocky Mountan Power
201 South Main St.
Salt Lake City, UT 84111
U.S. Mail
Idaho Wind Fars, LLC
Glenn Ikemoto
672 Blair Ave.
Piedmont, CA 94611
U.S. Mail
Sagebrush Energy, LLC and
Idaho Forest Group, LLC
Dean 1. Miler
PO Box 2564
Boise, Idaho 83701
U.S. Mail
Renewable Energy Coalition
Thomas H. Nelson
PO Box 1211
Welches, OR 97067
Idaho Power Company
Donovan Walker
POBox 70
Boise, ID 83702
C& ~ \i(\ \
Nina Curis
Administrative Assistat
Intervention - GNR-E-09-03 4