20101108Petition to Intervene.pdf

r--~_:; J_lC"'~f.~~ATTORNEYS AT LAW
iuiu NO'd -8 M"\ 9: 24Peter Richardson
Tel: [phone] Fax: [phone]
pete tel t ichardsonandol eary. com
P.O. Box 7218 Boise,ID 83707 - 515 N. 27th St. Boise. ID 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
THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS
COALITION 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.Siff:£.~
Peter J. Richardson
Richardson & O'Lear PLLC
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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
zøiu NOV -8 AM 9: 24
Attorneys for Northwest and Intermountain
Power Producers Coalition
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-10-04
PETITION TO INTERVENE
OF THE NORTHWEST AND
INTERMOUNTAIN POWER
PRODUCERS COALITION
COMES NOW, The Northwest and Intermountain Power Producers Coalition,
hereinafter referred to as "Intervenor," or the "Company," 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:
Northwest and Intermountain Power Producers Coalition
c/o Robert D. Kah, Executive Director
1117 Minor Avenue, Suite 300
Seattle, Washington 98101
Telephone: [phone]
Fax: [phone]
rkahn(ßnippc.org
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter J. Richardson, Gregory M. Adams, and Robert
D. Kahn, as noted above.
2. This Intervenor, the Northwest and Intermountain Power Producers Coalition is a
trade association whose members and associate members include independent power producers
active in the Pacific Northwest and Western energy markets.! The purose of NIP PC is to
represent the interests of its members in developing rules and policies that help achieve a
competitive electric power supply market in the Pacific Northwest. NIPPC has a substantial
interest in this docket. NIPPC's members utilize the Public Utility Regulatory Policies Act of
1978 ("PURP A") as one means of securing power purchase agreements for the sale of the output
oftheir projects to electric utilities in Idaho.
3. This Intervenor intends to participate herein as a par, and if necessary, to
introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in
arguent. 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 members'
ability to enter into PURP A contracts in the State of Idaho.
NIPPC's members include Calpine, Capital Power Operations (USA) Inc., Constellation
Energy Control & Dispatch, EverPower Renewables, Exergy Development Group, First Wind,
Horizon Wind Energy, Invenergy LLC, LS Power Associates, Ridgeline Energy, Shell Energy
North America, TransAlta Energy Marketing, Inc., and TransCanada.
Intervention of NIP PC GNR-E-1O-04 2
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 Northwest and Intermountain Power Producers Coalition
respectfully requests that this Commission grant its Petition to Intervene in these proceedings
and to appear and participate in all matters as may be necessar and appropriate; and to present
evidence, call and examine witnesses, present argument and to otherwse fully paricipate in
these proceedings.
DATED this 8th day of November, 2010.
RICHARDSON AND O'LEARY, PLLCKjrJ.~
Peter J. Richardson (ISB No: 3195)
Gregory M. Adams (ISB No. 7454)
Attorneys for the Northwest and
Intermountain Power Producers Coalition
Intervention of NIP PC GNR-E-IO-04 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th day of November, 2010, a tre and correct copy of
the within and foregoing PETITION TO INTERVENE BY the NORTHWEST AND
INTERMOUNTAIN POWER PRODUCERS COALITION 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
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
ov
Intervention of NIP PC GNR-E-IO-04 4