20101108Petition to Intervene.pdf

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Peter Richardson \r'Ki\L%OOJ',f"l Ä
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P.O. Box 7218 Boi.e, 10 83707 - 515 N. 27th St. Boi.e. 10 83702
8 November 2010
Ms. Jean Jewell
Commission Secretar
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
EXERGY DEVELOPMENT GROUP in the above case. Would you please file the
same?
Thank you for your attention to this matter. Please feel free to give me a call if you have
any questions.Sin~.~
~ J. Richaon
Richardson & O'Lear PLLC
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]
peterØjrichardsonandolear .com
gregØjrichardsonandoleary .com
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ZOllNOV -8 AM 9:26
Attorneys for Exergy Development Group of Idaho, LLC
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 EXERGY DEVELOPMENT
GROUP OF IDAHO, LLC
COMES NOW, EXERGY DEVELOPMENT GROUP 0 F IDAHO, LLC, 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 party, and as grounds therefore states as follows:
1. The name and address of this Intervenor is:
EXERGY DEVELOPMENT GROUP OF IDAHO, LLC
c/o Peter 1. Richardson
Richardson & O'Lear
515 N. 27th 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:
James Carkulis
Managing Member
EXERGY DEVELOPMENT GROUP OF IDAHO, LLC
802 West Banock Street, Ste. 1200
Boise, Idaho 83702
Telephone [phone]
Fax: [phone]
j carkulisØjexergydevelopment.com
2. This Intervenor, Exergy Development Group of Idaho, LLC is a duly formed
Idaho limited liability company. Exergy Development Group of Idaho is an active developer of
renewable energy projects in Idaho It currently has development activities for renewable energy
projects in the service territories of all three of the petitioners in this docket. Exergy
Development Group therefore claims a direct and substatial interest in this proceeding in that its
ability to continue developing renewable energy projects in the State of Idaho wil 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.
Intervention Exergy Development Group ofldaho, LLC GNR-E-1O-04 2
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 enter
into PURP A contracts in the State of Idaho.
5. Granting this Intervenor's petition to intervene wil not unduly broaden the issues
nor wil it prejudice any pary to this case.
WHEREFORE, Exergy Development Group 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.
RICHARDSON AND O'LEARY, PLLC
By tA.~
Peter J. Richardson
Exergy Development Group
Intervention Exergy Development Group ofldaho, LLC 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 EXERGY DEVELOPMENT
GROUP OF IDAHO, LLC 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
dwalkerØjidahopower.com
lnordstromØjidahopower .com
Daniel E. Solander
Rocky Mountain Power
201 South Main
Salt Lake City, UT 84111
Daniel.solanderØjpacificorp.com
Michael G. Andrea
A vista Corporation
1411 East Mission Avenue - MSC-23
Spokane, W A 99202
Michael.andreaØjavistacorp.com
Jean Jewell
Commission Secretary
Idaho Public Utilties Commission
472 West Washington
Boise, Idaho 83702
Jean. jewellØjpuc.idaho. gov
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Intervention Exergy Development Group of Idaho, LLC GNR-E-IO-04 4