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Home My WebLink About20050715Petition to intervene.pdf,);~ j: " f :". '4.. Lisa Nordstrom (ISB # 5733) Dean Brockbank PacifiCorp 825 NE Multnomah, Suite 1800 Portland, OR 97232 Telephone: (503) 813-6221 Fax: (503) 813-7252 E- mail: lisa.nordstrom~pacificorp .com dean. brockbank~pacifcorp .com Attorneys for Pacifi Corp rt~ ."'....~..,", 2B35 JUt Arlfl: 35 :T UJt\HO j)UBL/Ci It/TIES COf1t11SSJON BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION OF IDAHO POWER COMPANY FOR AN ORDER TEMPORARILY SUSPENDING IDAHO POWER'S PURP A OBLIGATION TO ENTER INTO CONTRACTS TO PURCHASE ENERGY GENERATED BY WIND-POWERED SMALL POWER PRODUCTION FACILITIES. CASE NO. IPC-O5- PETITION OF P ACIFICORP TO INTERVENE PacifiCorp dba Utah Power & Light ("PacifiCorp ), by and through its attorneys of record, respectfully petitions the Idaho Public Utilities Commission ("Commission ) for leave to intervene in the above captioned proceeding pursuant to the Commission s Rules of Practice and Procedure. In support of this Petition, PacifiCorp states: PacifiCorp is an electric utility in the state of Idaho and is subject to the supervision and regulation of the Commission. The address ofPacifiCorp s principal place of business is 825 NE Multnomah, Portland, OR 97272. PETITION OF P ACIFICORP TO INTERVENE Page 1 Communications to PacifiCorp concerning this proceeding should be addressed to: Bob Lively and Lisa NordstromPacifiCorp PacifiCorp One Utah Center, 23rd Floor 825 NE Multnomah, Suite 1800 201 S. Main Street Portland, OR 97232Salt Lake City, UT 84140 Telephone: (503) 813-6227 Telephone: (801) 220-4052 Fax: (503) 813-7252 Fax: (801) 220-2798 lisa.nordstorm~pacificorp.com bob .livel y~pacifcorp. com PacifiCorp requests that all data requests regarding this matter be addressed to: By E-mail (preferred): datarequest~pacificorp.comBy Fax: (503) 813-6060 By regular mail:Data Request Response Center PacifiCorp 825 N.E. Multnomah, Suite 800 Portland, OR 97232 Idaho Power Company s Petition in this proceeding seeks temporary suspension of a utility s PURP A obligation to enter into new contracts to purchase energy generated from qualifying wind facilities ("QFs ) in Idaho. During the requested suspension, Idaho Power asks the Commission to investigate impacts on its customers arising out of the addition of substantial amounts of wind-powered QFs, including the avoided cost methodology and the effects of intermittent wind resources on total power supply costs and reliability. As an electric utility with a legal obligation to purchase power from Idaho QFs, PacifiCorp has a direct and substantial interest in the outcome of this proceeding. While PacifiCorp agrees that the issues Idaho Power has identified should be investigated, PacifiCorp believes that the PURP A obligations to enter into new contracts with wind-powered QFs should be suspended for ALL Idaho electric utilities. Because of the small load PacifiCorp serves in Idaho and the time constraints of state and federal tax incentives, PacifiCorp is particularly concerned that it will be unable to effectively integrate large numbers of new QF developments that may seek to sell to PacifiCorp during the period of Idaho Power s stay (if granted). As PacifiCorp has PETITION OF P ACIFICORP TO INTERVENE Page 2 received a request to purchase from a wind QF to be built within its service territory, PacifiCorp now and in the future will be affected by the Commission s decisions on the matters at issue in this proceeding. Therefore, PacifiCorp has a direct and substantial interest with respect to both the impact of a temporary stay for Idaho Power alone and the matters Idaho Power has requested the Commission to investigate. PacifiCorp s participation in this proceeding will assist the Commission in resolving the issues before it and will not unreasonably broaden the issues, burden the record or delay the proceedings. No other party can adequately represent PacifiCorp s interests in this proceeding. PacifiCorp will accept the procedural schedules set forth in the Commission s Notice issued on July 1 , 2005. PacifiCorp has filed direct testimony and a legal brief simultaneously with this Petition to Intervene. WHEREFORE, PacifiCorp respectfully requests that the Commission grant this petition to intervene. DATED: July 14, 2005. Lisa N ordstro Attorney for Pa ifiCorp PETITION OF P ACIFICORP TO INTERVENE Page 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 14th day of July, 2005, I served a true and correct copy ofPacifiCorp s Petition to Intervene, Brief on Requested Temporary Suspension, and the Direct Testimony of Bruce W. Griswold upon the following named parties by the method indicated below, and addressed to the following: Barton L. Kline Monica B. Moen Idaho Power Company o. Box 70 Boise, ill 83707-0070 Hand Delivered S. Mail Overnight Mail FAX Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Street O. Bopx 83720 Boise, ill 83720-0074 Hand Delivered S. Mail Overnight Mail FAX Peter J. Richardson Richardson & 0 'Leary PLLC 515 N. 27th Street O. Box 7218 Boise, ill 83707 Hand Delivered S. Mail Overnight Mail FAX Hand Delivered S. Mail Overnight Mail FAX Mr. James T. Carkulis Exergy Development Group of Idaho LLC 1424 Dodge Avenue O. Box 5212 Helena, MT 59604 Hand Delivered S. Mail Overnight Mail FAX Richard L. Storro Director, Power Supply A vista Corporation 1411 E. Mission Avenue O. Box 3727, MSC- Spokane, W A 99220-3727 Hand Delivered S. Mail Overnight Mail FAX R. Blair Strong Paine, Hamblen, Coffin, Brooke & Miller 717 West Sprague Avenue, Suite 1200 Spokane, W A 99201-3505 J~ ~OYtbh~l?: LisaD. Nordstrom CERTIFICATE OF SERVICE