20101216Petition to Intervene.pdf

Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richardson & O'Lear, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
petercmrichardsonandolear.com
gregcmrichardsonandoleary.com
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Attorneys for the Board of Commissioners of Adams County Idaho
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION )
OF IDAHO POWER COMPANY, AVISTA )
CORPORATION, AND ROCKY MOUNTAIN )
POWER TO ADDRESS AVOIDED COST )
ISSUES AND JOINT MOTION TO ADJUST )
THE PUBLISHED AVOIDED COST RATE )ELIGIBILITY CAP. )
)
CASE NO. GNR-E-I0-04
PETITION TO INTERVENE
OF THE BOARD OF
COMMISSIONERS OF ADAMS
COUNTY, IDAHO
COMES NOW, The Board of County Commissioners of Adams County, Idaho,
hereinafter referred to as "Intervenor," or "Adams County," and pursuant 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 party, and as grounds therefore states
as follows:
1. The name and address of this Intervenor is:
Board of County Commissioners of Adams County, Idaho
c/o Peter J. Richardson
Richardson & O'Lear, PLLC
515 N. 2ih St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonandolear .com
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter J. Richardson and Gregory M. Adams as noted
above and to:
Bil Brown, Chair
Board of Commissioners of Adams County, Idaho
P. O. Box 48
Council, Idaho 83612
Telephone [phone]
Fax: [phone]
dbbrowncmfrontiernet.net
2. This Intervenor, Adams County, is a political subdivision of the State ofIdaho.
Adams County stared working on developing a woody biomass fueled power plant in 2006. The
facility is in advanced planing stages. Eighteen months ago Adams County submitted an
interconnection application with Idaho Power for a ten megawatt facility that will ru at a very
high capacity factor. The feasibility study is complete and Adams County curently has a draft
facilities study. The County has spent a considerable amount of fuds developing this project
and is very close to being ready to execute a final power purchase agreement with Idaho Power
Company. Adams County has relied on the availability ofthe published avoided cost rates for
projects up to ten average megawatts throughout its planing and due diligence process. Adams
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Intervention Board of County Commissioners
of Adams County GNR-E-lO-04
County has plans, of which Idaho Power is aware, to obtain a PURPA contract with Idaho.Power
for sale of the electrical output of its woody biomass facility in the near futue. Adams County
therefore claims a direct and substantial interest in this proceeding because its ability to develop
its woody biomass project wil be determined by the outcome of this proceeding.
The impact Adams County's project will have on the communty canot be understated.
Adams County has an unemployment rate approaching 20%. The proposed plant will create 20
to 25 full-time jobs that would pay a living wage. In addition, the haresting and delivery of
woody biomass to the plant would create up to 100 new jobs. The $25 milion plant would take
up to 14 months to construct, which would create many short term constrction jobs.
3. This Intervenor intends to paricipate herein as a pary, and if necessar, 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 natue and effect of other evidence in this proceeding.
4. 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 a PURP A contract in the State of Idaho.
5. Granting this Intervenor's petition to intervene wil not unduly broaden the issues
nor will it prejudice any pary to this case.
WHEREFORE, the Board of Commissioners of Adams County, Idaho 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 and to otherwse fully paricipate in these proceedings.
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Intervention Board of County Commissioners
of Adams County GNR-E-IO-04
DATED this 15th day of December, 2010.
Intervention Board of County Commissioners
of Adams County GNR-E-lO-04
RICHASON AND O'LEARY, PLLC
~
e 1. Richardson
gory M. Adams
Attorneys fur Board of County
Commissioners of Adams County, Idaho
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 15th day of December, 2010, a true and correct
copy of the within and foregoing PETITION TO INTERVENE OF THE BOAR OF
COMMISSIONERS OF ADAMS COUNTY, IDAHO was served by ELECTRONIC
MAIL and US MAIL, to:
Donovan E. Walker
Lisa Nordstrom
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707-0070
dwalkercmidahopower.com
lnordstromcmidahopower .com
Ronald L. Wiliams
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID, 83702
roncmwiliamsbradbur.com
Danel E. Solander
Rocky Mountain Power
201 South Main
Salt Lake City, UT 84111
Daniel.solandercmpacificorp.com
Scott Montgomery
President, Cedar Creek Wind, LLC
668 Rockwood Drive
North Salt Lake, Uta 84054
scottcmwesternenergy. us
Michael G. Andrea
A vista Corporation
1411 East Mission Avenue - MSC-23
Spokane, W A 99202
Michael.andreacmavistacorp.com
Dana Zentz
Vice President, Sumit Power Group, Inc.
2006 E. Westminster
Spokane, W A 99223
dzentzcmsummitpower.com
Jean Jewell
Commission Secretary
Idaho Public Utilties Commission
472 West Washington
Boise, Idaho 83702
J ean.jeweiicmpuc.idaho. gov
Scott Woodbur
Idaho Public Utilities Commission
472 W. Washington (zip: 83702)
P.O. Box 83720
Boise, ID 83720-0074
Scott. Woodburycmipuc.idaho.gov
Don Sturevant
Energy Director
J. R. Simplot Company
ONE CAPITAL CENTER
999 Main Street, P.O. Box 27
Boise, Idaho 83707-0027
Don.sturevantcmsimplot.com
Robert A. Paul
Grand View Solar
15960 Vista Circle
Desert Hot Springs, CA
robertpauicmgmail.com
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Intervention Board of County Commissioners
of Adams County GNR-E-lO-04
Thomas H. Nelson
Renewable Energy Coalition
PO Box 1211
Welches, OR 97067
nelsoncmthnelson.com
James Carkulis
Managing Member
EXERGY DEVELOPMENT GROUP OF
IDAHO,LLC
802 West Banock Street, Ste. 1200
Boise, Idaho 83702
jcarkuliscmexergydevelopment.com
Glenn Ikemoto
Margaret Rueger
Idaho Windfars, LLC
glenn~Envision Wind. com
MargaretcmEnvision Wind. com
R. Greg Ferney
Mimura Law Offices, PLLC
2176 E. Franlin Rd., Suite 120
Meridian, ID 83642
gregcmmimuralaw.com
By:O). ~ Cw\-JC
Nin~ M. Curis
Intervention Board of County Commissioners
of Adams County GNR-E-IO-04
Bil Piske, Manager
Interconnect Solar Development, LLC
1303 E. Carer
Boise, ID 83706
billpiskecmcableone.net
Dean J. Miler, Esq.
McDEVITT & MILLER LLP
P.O. BOX 2564-83701
Boise, Idaho 83702
j oecmmcdevitt -miler .com
Paul Marin
Intermountain Wind LLC
P.O. Box 353
Boulder, Colorado
paulmartincmintermountainwind.com
Wade Thomas
General Counsel, Dynamis Energy
776 E. Riverside Drive, Suite 15
Eagle, ID 83616
Telephone [phone]
wthomascmdynamisenerg.com
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