20101220Petition to Intervene.pdf

CE
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11th East
Idaho Falls, Idaho 83404
Telephone: [phone]
Fax: [phone]
ted~tsorenson.net
lOin DEC 20 Pl; 3: 45
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION )
OF IDAHO POWER COMPANY, AVISTA )
CORPORATION, AND ROCKY MOUNTAI )
POWER TO ADDRESS A VOIDED COST )
ISSUES AND JOINT MOTION TO ADJUST )
THE PUBLISHED AVOIDED COST RATE )
ELIGIBILITY CAP. )
)
CASE NO. GNR-E-IO-04
PETITION OT INTERVENE
OF BIRCH POWER
COMPANY
COMES NOW, Birch Power Company hereinafer referred to as II Intervenor, " or
the "Company," and pursuant to this Commssion's Rules of Procedure, Rule 71 IDA)A
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:
Ted S. Sorenson, P.E.
Birch Power Company
5203 South i i th East
Idaho Falls, Idaho 83404
Telephone: [phone]
Fax: [phone]
ted~tsorenson.net
Copies of all pleadings, production requests, production responses, Commission
orders and other docunents should be provided to Ted S. Sorenson as noted above.
2. This Intervenor, the Birch Power Company is an independent power
producer operating 5 small hydropower plants. The purose of Birch Power Company is
to represent the interest of its power plants and others in the state who operate small
hydropower plants or who are planing to build small hydro power plants. We utilize the
Public Utilty Regulatory Policies Act of 1978 ("PURP A") as one means of securng
power purchase agreements for the sale of the output of their projects to electric utilities
in Idaho.
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 ths Interventor wil introduce is
dependent upon the natue and effect of other evidence in ths proceeding.
4. Without the opportity to intervene herein, this Intervenor would be
without any means of paricipation in this proceeding which may have a material impact
on its members; abilty to enter into PURP A contracts in the State ofIdaho.
5. Granting this Intervenor's petition to intervene will not unduly broaden the
issues nor will it prejudice any pary to ths case.
WHEREFORE, Birch Power Company respectflly 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 argument,and to otherwse fuly paricipte in these
proceedings.
DATED this 16th day of December, 2010
BIRCH POWER COMPANY$/
Ted S Sorenson P E
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16th day of December 2010, a tre and correct
coy of the within and foregoing PETITION TO INTERVENE BY the BIRCH POWER
COMPANY was served by ELECTRONIC MAIL and US MAIL, to:
Donovan E. Walker
Lisa Nordstrom
Idaho Power company
i 221 West Idaho Street
Boise ID 83707-0070
dwalker(ßidahopower .com
InordstromCiidahpower .com
Daniel E. Solander
Rocky Mountan Power
201 South main
Salt Lake City, UT 8411 1
Danel.solander(ipacificorp.com
Michael G. Andrea
A vista Corporation
141 1 East mission Avenue - MSC -23
Spokane W A 99202
Michael.andrea(ßavistacorp.com
Jean Jewell
Commission Secretay
Idaho Power Utilities Commission
472 West Washigton
Boise ID 83702
J ean.jewell(êuc.idaho.gov
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