20050714Petition to intervene.pdf

ECE\\fED IT)
r""'"1
\'=,='"
Dean J. Miller ISB #1968
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
ioe~mcdevitt - m i Her .com
tLED
tUU~ JUl \4 PM 4~ zc;
, .~.
C; pu8L\C
~S COMt1\SSiON
\.j \ \
Attorneys for Magic Wind, LLC ORIGINAL
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR AN
ORDER TEMPORARILY SUSPENDING
IDAHO POWER'S PURPA OBLIGATION TO
ENTER INTO CONTRACTS TO PURCHASE
ENERGY GENERATED BY WIND-
POWERED SMALL POWER PRODUCTION
FACILITIES.
Case No. IPC-O5-
PETITION TO INTERVENE OF
MAGIC WIND LLC
COMES NOW Magic Wind LLC, (Magic Wind) through its counsel, and
petitions to intervene in the above matter and in support thereof respectfully shows as
follows:
1. Magic Wind is a limited liability company, organized and existing under the laws
of the State of Idaho.
2. Magic Wind is the developer of a 18.9 wind power small power production
facility located in Twin Falls County, State of Idaho and within the service
territory of Idaho Power Company, the Petitioner herein.
3. Prior to the filing of the Petition herein, Magic Wind has made substantial
progress towards the completion of its project.
PETITION TO INTERVENE OF MAGIC WIND LLC -
4. Magic Wind has a direct and substantial interest in this proceeding because it
would be materially adversely affected by the issuance of an order suspending
Idaho Power Company s PURPA purchase obligation, as requested by the
Petition on file herein.
5. All pleadings, papers, notices and orders should be served upon:
Dean J. Miller
McDevitt & Miller LLP
420 W. Bannock
Boise, ID 83702
Armand Eckert
Magic Wind LLC
716-B East 4900 North
Buhl, Id 83316
WHEREFORE, Magic Wind respectfully requests that the Commission enter its
Order granting intervention with full rights as a party to Magic Wind LLC
Dated thisRday of July, 2005
Respectfully submitted
McDEVITT & MILLER LLP
Dean J. Miller
McDevitt & Miller LLP
420 W. Bannock
Boise, ID 83702
Phone: [phone]
Fax: [phone]
Counsel for Magic Wind LLC
PETITION TO INTERVENE OF MAGIC WIND LLC - 2
CERTIFICATE OF SERVICE
I hereby certify that on the ~day of July, 2005, I caused to be served, via the
methodes) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
i iewell~puc.state.id. us
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Barton L. Kline
Monica B. Moen
Idaho Power Company
1221 West Idaho Street
O. Box 70
Boise, ID 83707
BKline~idahopower. com
MMoen~idahopower .com
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Peter J. Richardson
Richardson & 0' Leary PLLC
99 East State Street
O. Box 1849
Eagle, ID 83616
peter~richardsonandoleary .com
Hand Delivered
S. Mail
Fax
Fed. Express
Email
PETITION TO INTERVENE OF MAGIC WIND LLC - 3