20120724Objection to Late Petition.pdf

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PIVER®
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JUL23 PM 5:01
JASON B WILLIAMS ,
Corporate Counsel JT;TiE9
jwiIliamsidahopower.com
July 23, 2012
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. GNR -ET4 I -03
PURPA SAR and IRP Methodologies - Objection to Mountain Air Project,
LLC's Petition for Late Intervention
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and seven (7) copies of Idaho
Power Company's Objection to Mountain Air Project, LLC's Petition for Late Intervention.
Very truly yours,
Jason B. Williams
JBW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS (ISB No. 8718)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwaIkeridahopower.com
iwiIIiamsidahopower.com
RE CE I V
2012J1JL23 PH 5:01
IDAHO Ub;
UTILmES COMM!5I,ftj
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
REVIEW OF PURPA QF CONTRACT
PROVISIONS INCLUDING THE
SURROGATE AVOIDED RESOURCE
(SAR) AND INTEGRATED RESOURCE
PLANNING (IRP) METHODOLOGIES FOR
CALCULATING PUBLISHED AVOIDED
COST RATES.
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY'S
OBJECTION TO MOUNTAIN AIR
PROJECTS, LLC'S PETITION
FOR LATE INTERVENTION
COMES NOW, Idaho Power Company ("Idaho Power") pursuant to Idaho Public
Utilities Commission ("Commission") Rule of Procedure 73 and hereby objects to
Mountain Air Projects, LLC's ("Petitioner" or "Mountain Air") Petition for Late intervention
filed on July 16, 2012. The basis for Idaho Power's objection is as follows:
I. BACKGROUND
The issues being addressed in this case have been developing for nearly two
years. On November 5, 2010, Idaho Power, Avista Corporation ("Avista"), and
PacifiCorp d/b/a Rocky Mountain Power ("PacifiCorp") (collectively the "Utilities") filed a
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -1
Joint Petition requesting that the Commission lower the published rate eligibility cap for
Qualifying Facilities ("QFs") and initiate an investigation to address avoided cost issues
related to the Commission's implementation of the Public Utility Regulatory Policies Act
of 1978 ("PURPA"). On February 7, 2011, the Commission issued Order No. 32176 in
Case No. GNR-E-10-04, which granted in part and denied in part the Utilities' request to
temporarily reduce the published rate eligibility cap for QFs. In addition, Order No.
32176 directed the parties to that proceeding to establish a procedural schedule to
explore the possibility of developing a published avoided rate cap structure that allowed
small wind and solar QFs to avail themselves of published avoided cost rates for
projects producing 10 average megawatts or less and that prevents large QFs from
disaggregating in order to obtain a published avoided cost rate that exceeds a utility's
avoided cost. Order No. 32176 at 11.
That proceeding became Case No. GNR-E-11-01, which the Commission
designated as 'Phase II of GNR-E-10-04." In that case, Idaho Power submitted prefiled
direct testimony which, among other things, proposed the use of the Integrated
Resource Plan ("IRP") methodology to establish the published rate for eligible QFs.
Avista and PacifiCorp submitted prefiled direct testimony in GNR-E-1 1-03 as well.
The Commission issued Order No. 32262 in Case No. GNR-E-11-01 on June 8,
2011, which, among other things, maintained the 100 kilowatt eligibility cap for
published avoided cost rates for wind and solar QFs. With Order No. 32262, the
Commission stated that is was initiating "additional proceedings to allow the parties to
investigate and analyze both the SAR Methodology and the IRP Methodology" and that
"we [the Commission] encourage a full examination of the application of the IRP
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -2
Methodology and are open to considering alternatives to the current methodologies."
Order No. 32262 at 8-9. The Commission further defined the scope of the present
proceedings, Case No. GNR-E-1 1-03, in its Notice of Review dated September 1, 2011:
"The Commission anticipates that the scope of this inquiry will also include (but is not
limited to) considerations regarding the dispatchability of varying resources, curtailment
options, integration costs, renewable energy credits, delay security and liquidated
damages, timing and schedule of negotiations, and contract milestones." Order No.
32352 at 4.
Per a requirement in Order No. 32262, the parties convened and agreed to a
procedural schedule for Case No. GNR-E-11-03. On November 2, 2011, the
Commission issued Order No. 32388, which established a procedural schedule for the
case, specifically providing deadlines for the submittal of testimony, discovery cut-offs,
the filing of legal briefs, and the date of the hearing.
On January 31, 2012, pursuant to the procedural schedule set by Order No.
32388, Idaho Power, Avista, and PacifiCorp submitted prefiled direct testimony. Idaho
Power submitted testimony from five witnesses covering a broad array of PURPA-
related issues. Specifically, Idaho Power witness Tessia Park's testimony seeks
approval of a proposed Tariff Schedule 74 to apply a curtailment policy to "all PURPA
contracts, both existing and new, that are projects which contain generator output
control limiters ('GOCLs') and are 10 MW or larger in size." Park, Dl at 25.
Shortly thereafter, and continuing through the end of this week, Idaho Power
responded to numerous, detailed discovery questions consisting of hundreds of pages
of responsive materials. Commission Staff and numerous intervenors submitted
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -3
prefiled testimony on May 4, 2012. Discovery among all parties ensued; discovery
served on the utilities continued. On June 29, 2012, parties submitted rebuttal
testimony. The discovery cut-off on rebuttal testimony occurred on July 6, 2012. Legal
briefs in this case were due July 20, 2012. A three-day technical hearing is scheduled
for August 7-9.
Petitioner submitted its petition for late-filed intervention on July 16, 2012.
II. ARGUMENT
Idaho Public Utilities Commission Rule of Procedure 73 sets forth timeliness
requirements for petitions to intervene in a Commission proceeding. The rule states:
Petitions not timely filed must state a substantial reason for
delay. The Commission may deny or conditionally grant
petitions to intervene that are not timely filed for failure to
state good cause for untimely filing, to prevent disruption,
prejudice to existing parties or undue broadening of the
issues, or for other reasons. Intervenors who do not file
timely petitions are bound by orders and notices earlier
entered as a condition of granting the untimely petition.
Idaho Power objects to the Petition for Late Intervention filed by Mountain Air for failure
to state good cause for its untimely filing, disruption of the proceedings, prejudice to
existing parties, and unduly broadening of the issues in the case. In the alternative,
should the Commission be inclined to grant Mountain Air's Petition in the case, the
Commission should substantially limit the Petitioner's participation to that of an
Interested Person and Public Witness as defined by RP 39 and RP 76.
A. The Petition to Intervene Should be Denied for Failure to State Good Cause
for the Untimely Filing.
In this case, the time for which petitions to intervene must be filed was set by
Order No. 32352 as September 8, 2011—more than 10 months ago. Pursuant to RP
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -4
73, petitions filed after that date must state a substantial reason for delay. Petitioner
states that it "only became aware that Schedule 74 might be applied to existing
contracts following May 4, 2012, when Commission Staff witness Rick Sterling
submitted prefiled direct testimony" and that it was not until Mr. Sterling's June 29,
2012, rebuttal testimony that "it became clear. . . that the issue of whether Schedule 74
will apply to existing QF contracts will continue to be a major issue in this proceeding."
Pet. for Late Intervention at 4.
In its prefiled, direct testimony filed on January 31, 2012, Idaho Power submitted
the Direct Testimony of Tessia Park sponsoring its proposed Schedule 74 and
proposing that Schedule 74 apply to both current and future Us. Specifically, Ms.
Park's Direct Testimony states that the Company was proposing that Schedule 74 apply
to all contracts Idaho Power had with QFs, not just new contracts:
Q. Is the Company proposing to implement this policy
[Schedule 74] to only new PURPA contracts or to all current
and new PURPA contracts?
A. The Company is proposing to apply this policy to all
PURPA contracts, both existing and new, that are projects
which contain generator output limiters ("GOLC5") and are
10 MW or large in size.
Park, DI at 25. Thus, Idaho Power's proposal that its proposed Schedule 74 would
apply to both existing and new QF contracts has been publicly available for nearly six
months. To suggest that it was not "clear" to Petitioner regarding whether Idaho
Power's proposed Schedule 74 would impact it until June 29, five months after Idaho
Power submitted its direct testimony, is disingenuous and not a valid ground to grant
late-filed intervention.
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -5
Notably, Petitioner concedes that it "had previously been aware that there was
an ongoing avoided cost proceeding at the Commission." Petition for Late Intervention
at 5. In spite of Petitioner's admission that it was aware of the proceeding, Petitioner
offers no reasonable explanation as to why it only recently became aware that these
proposals may have an impact on it even though several hundred pages of testimony
and supporting documents describing these proposals were filed in January 2012.
Petitioner asserts that it was not until Staff raised this issue on May 4, 2012, that it
"became aware" of the issue, and that it was not until Staff reasserted its position on
June 29, 2012, that it "became clear" to Petitioner that this was an issue in the case.
Petitioner's failure to read and comprehend the issues raised in the Company's
January 2012 testimony, and its failure to understand the impacts of the issues filed in
Staffs May 2012 testimony, is not a substantial reason for delay under Rule 73.
Petitioner has had notice of the issues in this case for at least six months and, by its
own admission, has had notice of Staff's May testimony addressing the curtailment
issue. The Petition for Late Intervention fails to describe why it then had to wait until
one week before legal briefs were to be filed in this case and only a little more than
three weeks before the hearing in this case is to be held to become aware of the
potential impacts of this case.
Petitioner has had ample time to review the testimony and make a determination
regarding whether the case will impact them. Instead, Petitioner put off filing for
intervention until one week prior to the date on which briefs were due by the parties.
Petitioner's failure to adequately assess the issues and make a timely determination,
even though all information needed to make such an assessment was publicly available
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -6
for nearly six months previous, does not constitute good cause for delay. The
Commission should deny the Petition to Intervene because a potential party's inability to
ascertain whether issues will impact them is not a substantial reason for untimely filing.
B. The Commission Should Deny the Petition for Late Intervention Because It
Will Disrupt the Case, Prejudice the Parties, and Unduly Broaden the
Issues.
Petitioner's significant delay in filing for intervention will disrupt the proceedings,
prejudice existing parties, and unduly broaden the issues in the case.
Petitioner has chosen to intervene so late in the proceedings that such
intervention cannot be accommodated without considerable disruption in the case.
Notably, this very objection to their late-filed Petition is due one business day following
the due date for legal briefs in the case. Idaho Power devoted significant time and
energy toward preparing its legal brief (as well as all other aspects of this case) and this
filing diverted its attention from that important pleading in order to object to Mountain
Air's untimely Petition. This alone is a substantial disruption and hardship to Idaho
Power.
Additionally, due to the proximity of the Petition seeking late intervention filing to
the deadline for filing of briefs in the case, the Commission Staff Attorney directed that
even potential parties should file legal briefs by the current schedule's July 20 deadline,
and that the Commission would make subsequent determination as to the admissibility
of such legal briefs at its July 30 decision meeting.' The fact that non-parties to the
case have an opportunity to submit legal briefs for subsequent evidentiary determination
by the Commission is a disruption to this proceeding, and in-and-of itself has broadened
1 E-mail from Kristine Sasser, Deputy Attorney General, to parties of record in Case No. GNR-E-1 1-03.
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -7
the proceedings and issues with its own consideration. Specifically, the Commission
has to engage in special procedure to allow this to occur. In addition, Petitioner's late
request will also disrupt the case as, if granted, Petitioner's attorney will need to be
afforded the opportunity to participate in the hearing, including cross examining the
Utilities' witnesses. This will require additional time at the technical hearing; thus,
disrupting the case. The Commission should not disrupt these proceedings simply to
accommodate the Petitioner's untimely request and should deny Petitioner's request for
intervention.
Similarly, this extremely late filing prevents the opportunity for discovery and
timely assessment of issues as they may relate to Petitioner and the impact its
intervention could have on the pending case. At this point in the case, when discovery
is complete and the parties are wrapping up their issues for Commission decision, it is
highly prejudicial to allow a new potential party to join. The hearing in this case set for
August 7-9 is effectively the culmination of close to two years of pleadings, Commission
decisions, discovery, prefiled testimony, legal briefs, and other efforts. It is the tail end
of a very involved case and is detrimental to current parties in the case to allow an
extremely late filed intervenor to enter the fray.
Furthermore, the inclusion of the Petitioner is likely to unduly broaden the issues
in the case. Petitioner sates that its intervention will not broaden the scope of the
proceeding and that it does not seek to introduce new issues. However, one of the
Petition's stated issues is to "conduct cross examination" and "protect its interest in the
proceeding." Petition at 6. It is unclear how the Petitioner can maintain that its interests
are not protected and yet it will protect those interests without introducing new issues in
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -8
the case. Because the discovery cut-off in this proceeding has already occurred, the
parties have no opportunity to submit discovery requests to Petitioner to determine the
scope of the issues which Petitioner seeks to address.
Idaho Power believes that the Petitioner's interests may already be represented
by other parties to the case. It is possible Petitioner is a member of the Northwest
Intermountain Power Producers Coalition, the Renewable Energy Coalition, and/or
another industry organization that is already a party to this case and that those
organizations will adequately represent its interests. Again, because the time for
discovery has passed, it is impossible for Idaho Power or this Commission to know
whether this is the case.
Petitioner is a large wind developer. Several other wind developers have already
timely intervened in this proceeding, submitted testimony, and will participate at the
hearing. Since Petitioner is similarly situated to several other parties in this proceeding,
it is likely that Petitioner's interests will be adequately represented by other parties to
this proceeding. Petitioner purports to present evidence and argument in opposition to
Idaho Power's proposed Tariff Schedule 74. Several of the other intervening parties
have presented testimony and argument in opposition to Schedule 74, as well as filing
the same, or similar, objections to Schedule 74 with the Federal Energy Regulatory
Commission. Petitioner has failed to demonstrate how its interests in opposing the
proposed Schedule 74 are not all ready adequately represented before this
Commission.
In light of the burdensome nature of the request, its disruption of proceedings,
prejudice to other parties, and expansion of issues, the Petitioner's failure to promptly
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -9
address an issue that was raised on January 31, 2012, and again on May 4, 2012, is
not an adequate, much less a substantial, reason for delay that justifies granting the
Petition for Late Intervention. Accordingly, the Commission should deny Petitioner's
request for intervention.
C. If the Commission is Inclined to Grant the Petition to Intervene, Petitioner
Should be Granted the Status of "Interested Person" and "Public Witness"
Rather than that of a "Party."
In the alternative, if the Commission is inclined to grant the Petition for Late
Intervention, in order to mitigate the adverse effects on existing parties to the case, the
Commission should limit Petitioner's involvement to that of an "Interested Person" and a
"Public Witness" pursuant to the Commission Rules of Procedure 39 and 76. RP 39,
RP 76. RP 39 allows for the participation, and the receipt of Notice, in administrative
proceedings by entities that are not parties to the case but are "interested persons." RP
39. RP 76 provides that persons that are not parties and not called by a party to testify
can participate in a Commission proceeding and have a right to introduce evidence at
hearing by their written or oral statements and exhibits introduced at hearing, but
otherwise do not have parties' rights to examine witnesses or otherwise participate in
the proceedings. Public Witnesses' written or oral statements and exhibits are subject
to examination and objection. If the Commission is inclined to allow Petitioner to
participate in this proceeding, it should grant Petitioner "interested person" status to
allow Notice and Service upon Petitioner—and grant "public witness" status to
Petitioner, allowing Petitioner to submit written comments prior to the completion of the
technical hearing, the anticipated time when the evidentiary record in this case will
close. Allowing participation as an "interested person" and "public witness" strikes an
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -10
appropriate balance from a due process standpoint as it will allow Petitioner an
opportunity to provide evidentiary submissions into the record without unduly prejudicing
other parties and disrupting the case.
III. CONCLUSION
Because the Petitioner has not shown good cause or a substantial reason for the
untimely filing of the Petition to Intervene, and because granting the Petition at this late
date would create disruption, prejudice, and unduly expand the issues, Idaho Power
respectfully requests that the Commission deny the Petition to Intervene. In the
alternative, if the Commission is inclined to grant the Petition, Idaho Power respectfully
requests that the Commission substantially limit the Petitioner's participation to that of
an Interested Person and Public Witness as defined by RP 39 and RP 76.
DATED at Boise, Idaho, this 23rd day of July 2012.
(tteIney for Idaho Power Company
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -11
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23rd day of July 2012 I served a true and correct
copy of IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN AIR PROJECTS,
LLC'S PETITION FOR LATE INTERVENTION upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
Spokane, Washington 99202
PacifiCorp dibla Rocky Mountain Power
Daniel E. Solander
PacifiCorp d/b/a Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Exergy Development, Grand View Solar II,
J.R. Simplot, Northwest and Intermountain
Power Producers Coalition, Board of
Commissioners of Adams County, Idaho,
and Clearwater Paper Corporation
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
X Hand Delivered
U.S. Mail
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FAX
X Email kris.sassercpuc.idaho.cov
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X Email michael.andreacavistacorp.com
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X Email danieI.soIander(pacificorp.com
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X Email peterrichardsonandoIeary.com
grecrichardsonandoleary.com
Exergy Development Group of Idaho, LLC Hand Delivered
James Carkulis, Managing Member X U.S. Mail
Exergy Development Group of Idaho, LLC Overnight Mail
802 West Bannock Street, Suite 1200 FAX
Boise, Idaho 83702 X Email jcarkuliscexerqydevelopment.com
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -12
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Grand View Solar II
Robert A. Paul
Grand View Solar II
15690 Vista Circle
Desert Hot Springs, California 92241
J.R. Simplot Company
Don Sturtevant, Energy Director
J.R. Simplot Company
One Capital Center
999 Main Street
P.O. Box 27
Boise, Idaho 83707-0027
Northwest and Intermountain Power
Producers Coalition
Robert D. Kahn, Executive Director
Northwest and Intermountain Power
Producers Coalition
1117 Minor Avenue, Suite 300
Seattle, Washington 98101
Board of Commissioners of Adams
County, Idaho
Bill Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
Clearwater Paper Corporation
Mary Lewallen
Clearwater Paper Corporation
601 West Riverside Avenue, Suite 1100
Spokane, Washington 99201
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IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -13
Renewable Energy Coalition and Dynamis
Energy, LLC
Ronald L. Williams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Renewable Energy Coalition
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 150
Eagle, Idaho 83616
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Bill Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Renewable Northwest Project, Idaho
Windfarms, LLC, and Ridgeline Energy LLC
Dean J. Miller
Chas. F. McDevitt
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, Idaho 83701
Megan Walseth Decker
Senior Staff Counsel
Renewable Northwest Project
421 SW 6th Avenue, Suite 1125
Portland, Oregon 97204
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IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -14
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Twin Falls Canal Company and North Side
Canal Company
C. Thomas Arkoosh
CAPITOL LAW GROUP, PLLC
205 North I 0th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
ELECTRONIC SERVICE ONLY
Lori Thomas
CAPITOL LAW GROUP, PLLC
205 North 10th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
ELECTRONIC SERVICE ONLY
Donald W. Schoenbeck
RCS, Inc.
900 Washington Street, Suite 780
Vancouver, Washington 98660
ELECTRONIC SERVICE ONLY
Twin Falls Canal Company
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
ELECTRONIC SERVICE ONLY
North Side Canal Company
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
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marciaretenvisionwind .com
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IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -15
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11th East
Idaho Falls, Idaho 83404
Blue Ribbon Energy LLC
M.J. Humphries
Blue Ribbon Energy LLC
3470 Rich Lane
Ammon, Idaho 83406-7728
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, Idaho 83701
Snake River Alliance
Liz Woodruff, Executive Director
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
Energy Integrity Project
Tauna Christensen
Energy Integrity Project
769 North 1100 East
Shelley, Idaho 83274
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IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION - 16
Idaho Wind Partners I, LLC Hand Delivered
Deborah E. Nelson X U.S. Mail
Kelsey J. Nunez Overnight Mail
GIVENS PURSLEY LLP FAX
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P.O. Box 2720 kinqivenspursley.com
Boise, Idaho 83701-2720
Chnsta Bearry, Legal Assistant
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -17
NON-PARTY CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 23 rd day of July 2012 I served a true and correct
copy of the IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN AIR
PROJECTS, LLC'S PETITION FOR LATE INTERVENTION upon the following
individuals who are not named parties in this proceeding by the method indicated below,
and addressed to the following:
Big Wood Canal Company and American
Falls Reservoir District No. 2
C. Thomas Arkoosh
CAPITOL LAW GROUP, PLLC
205 North 10th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
Mountain Air Projects, LLC
J. Kahle Becker
The Alaska Center
1020 West Main Street, Suite 400
Boise, Idaho 83702
Michael J. Uda
UDA LAW FIRM, P.C.
7 West 6th Avenue, Suite 4E
Helena, Montana 59601
Hand Delivered
X U.S. Mail
Overnight Mail
FAX
X Email tarkooshcapitoI lam roup.com
Hand Delivered
X U.S. Mail
Overnight Mail
FAX
X Email kahle(kahlebeckerlaw.com
Hand Delivered
X U.S. Mail
Overnight Mail
FAX
X Email muda(mthelena.com
Christa Bearry, L gal Assistant (j
IDAHO POWER COMPANY'S OBJECTION TO MOUNTAIN
AIR PROJECTS, LLC'S PETITION FOR LATE INTERVENTION -18