20101108Petition to Intervene.pdf

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ATTORNEYS AT LAW iOIO NOV -8 AM 9= 25
Peter Richardson
Tel: [phone] Fax: [phone]
peter~ richardson .ndo) cary. com
P.O. Box 7218 Boise,1D 83707 - 515 N. 27th St. Boise.1D 83702
8 November 2010
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
RE: GNR-E-IO-04
Dear Ms. Jewell:
We are enclosing an original and seven copies ofthe PETITION TO INTERVENE OF
GRAD VIEW SOLAR in the above case. Would you please file the same?
Than you for your attention to this matter. Please feel free to give me a call if you have
any questions.
Since~,
£. Richaron
Richardson & O'Lear PLLC
Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richardson & O'Leary, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(ßrichardsonandolear.com
greg(ßrichardsonandolear .com
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Attorneys for Grand View Solar II, LLC
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION )
OF IDAHO POWER COMPANY, AVISTA ) CASE NO. GNR-E-1O-04
CORPORATION, AND ROCKY MOUNTAIN )
POWER TO ADDRESS AVOIDED COST ) PETITION TO INTERVENE
ISSUES AND JOINT MOTION TO ADJUST ) OF GRAND VIEW SOLAR II
THE PUBLISHED AVOIDED COST RATE )ELIGIBILITY CAP. )
)
COMES NOW, The Grand View Solar II, hereinafter referred to as "Intervenor," 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 pary, and
as grounds therefore states as follows:
1. The name and address of this Intervenor is:
Grand View Solar II
c/o Peter J. Richardson
Richardson & O'Leary
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonandoleary .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:
Robert A. Paul
15960 Vista Circle
Desert Hot Springs, CA
ro bertapaul(ßgmail.com
2. This Intervenor, Grand View Solar II is an Idaho limited liability company that is
curently developing a 20 MW solar PURP A project south of Boise, Idaho. Grand View is
seeking to sell the output from that project to Idaho Power under the Commission's published
avoided cost rates. Grand View therefore claims a direct and substantial interest in this
proceeding in that its ability to make such sales will be affected by the outcome of this
proceeding.
3. This Intervenor intends to paricipate herein as a pary, 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 wil introduce is dependent
upon the nature and effect of other evidence in this proceeding.
4. Without the opportunity to intervene herein, this Intervenor would be without any
means of paricipation in this proceeding which may have a material impact on its ability to
conduct business in the State of Idaho.
Intervention Grand View Solar II GNR-E-1O-04 2
5. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor wil it prejudice any pary to this case.
WHEREFORE, Grand View Solar II respectfully requests that this Commission grant
its Petition to Intervene in these proceedings and to appear and participate in all matters as may
be necessary and appropriate; and to present evidence, call and examine witnesses, present
argument and to otherwise fully paricipate in these proceedings.
DATED this 8th day of November, 2010.
RICHARSON AND O'LEARY, PLLC
By ~2&~
Peter J. Richardson
Grand View Solar II, LLC
Intervention Grand View Solar II GNR-E-IO-04 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th day of November, 2010, a true and correct copy of
the within and foregoing PETITION TO INTERVENE BY GRAND VIEW SOLAR II, LLC was
served by ELECTRONIC MAIL and US MAIL, to:
Donovan E. Walker
Lisa Nordstrom
Idaho Power Company
1221 WestIdaho Street
Boise, Idaho 83707-0070
dwalker(ßidahopower .com
Inordstrom(ßidahopower .com
Daniel E. Solander
Rocky Mountain Power
201 South Main
Salt Lake City, UT 84111
Daniel.solander(ßpacificorp.com
Michael G. Andrea
A vista Corporation
1411 East Mission Avenue - MSC-23
Spokane, W A 99202
Michael.andrea(ßavistacorp.com
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
Jean. j ewell(ßpuc. idaho . gov
Intervention Grand View Solar II GNR-E-IO-04 4