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Home My WebLink About20050715Petition to intervene.pdfWilliam M. Eddie (ISB# 5800) ADVOCATES FOR THE WEST O. Box 1612 Boise, ID 83701 (208) 342-7024 fax: (208) 342-8286 billeddie~nl1ci.net fI- ""' !C" :"'_ vL ::" J LED (:J za05 JUt IS Pr1 ~. Hn Di;r~LI(' .lftLi TIES - CO~'~"&SION Express Mail: 1320 W. Franklin St. Boise, ID 83702 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION OF . OF IDAHO POWER COMPANY FOR AN ORDER TEMPORARILY SUSPENDING ENTER INTO CONTRACTS TO PURCHASE ENERGY GENERATED BY WIND-POWERED SMALL POWER PRODUCTION FACILITIES CASE NO.IPC-05- I1lJ .. J~/G~ /1 vn~ - ~. '. h~ PETITION TO INTERVENE Pursuant to Idaho Public Utilities Commission Rules of Procedure 53 and 71 through 73 , Renewable Northwest Project ("RNP") and NW Energy Coalition Coalition ) hereby seek intervention in the above-captioned matter. As discussed below, RNP and the Coalition have direct and substantial interests in these proceedings and therefore should be granted intervention. Established in 1994, RNP promotes the responsible expansion of solar, wind and geothenl1al energy in the Northwest. RNP works to establish policies that support renewable energy developll1ent and nurture the development of a market for renewables. RNP's unique coalition of members includes renewable energy project developers, public and consumer interest groups, turbine manufacturers, environmental organizations and others. RNP's address is 917 SW Oak St, Suite 303; Portland, Oregon, 97205. PETITION TO INTERVENE BY RNP AND NW ENERGY COALITION -- The Coalition is a non-profit regional alliance of over 100 diverse environmental civic, consumer, low-income customer advocacy groups, energy efficiency and renewable energy businesses, and progressive utilities in Idaho, Montana, Washington and Oregon. NW Energy Coalition advocates for increased energy conservation efforts sustainable and ecologically-sound management of electric generating infrastructure increased reliance on renewable sources of energy, and appropriate rate design policies consistent with these goals. In Idaho , the Coalition has numerous individual members and eleven (11) member organizations. NW Energy Coalition s address is: 219 First Ave South, Suite 100 , Seattle , W A 98104. RNP and NW Energy Coalition have direct and substantial interests in tp.is proceeding because the Comll1ission s implementation of the federal Public Utilities Regulatory Policies Act (PURP A) has significant impacts upon investment in renewable energy in Idaho. Both organizations share an interest in promoting the responsible expansion of renewable energy in the Northwest, and decisions issued in this case may ill1pact their ability to advance that interest. Moreover, NW Energy Coalition has organizational and individual members who are customers of Idaho Power; and RNP' 111ell1bers include renewable energy developers who have proposed projects within Idaho Power s service territory, and therefore may be impacted by the Commission s decisions herein. RNP and the Coalition seek intervention in order to fully participate in this matter as a party and otherwise to present such materials as may be relevant to the PETITION TO INTERVENE BY RNPAND NW ENERGY COALITION -- 2 COl11111ission s decision(s) in this matter. RNP and the Coalition intend to seek intervenor funding pursuant to RP 161 through 165. PLEASE TAKE NOTICE that RNP and NW Energy Coalition request all docull1ents in this matter be served to the following persons: William M. Eddie Advocates for the West O. Box 1612 Boise , ID 83701 Troy Gagliano 917 SW Oak St, Suite 303 Portland, Oregon, 97205 WHEREFORE, RNP and NW Energy Coalition respectfully request that the foregoing petition to intervene be granted. Dated: July 15 , 2005 RespectfJ ...- C;;X:"" f - William M. Eddie, Attorney Advocates for the West On behalf of Renewable Northwest Project and NW Energy Coalition PETITION TO INTERVENE BY RNP AND NW ENERGY COALITION -- 3 CERTIFICATE OF SERVICE I hereby certify that on this 15th day of July 2005 , true and correct copies of the foregoing PETITION TO INTERVENE and the DIRECT TESTIMONY OF TROY GAGLIANO were delivered to the following persons via the method of service noted: Via Hand-Delivery: COll1mission Secretary (Original and seven copies provided) Idaho Public Utilities Commission 427 W. Washington St. Boise , ID 83702-5983 Via U.S. Mail (and courtesy electronic copy where noted) Bart Kline Monica Moen Idaho Power Company O. Box 70 Jared Grover Cassia Wind LLC 3635 Kingswood Dr. Boise, ID 83704-4322 Richard L. Storro Director, Power Supply A vista Corp. O. Box 3727 MSC- Spokane , W A 99220-3727 Ell1ail to dick.storro~avistacorp.com Armand Eckert Magic Wind LLC 716-B East 4900 North Buhl, ID 83316 Boise, ID 83707-0070 Email to 111111oen~idahopower.com Glenn Ikemoto Energy Visio.n LLC 672 Blair Ave Piedmont, CA 94611 Email to glenni~pacbell.net R. Blair Strong Paine, Hamblen et al 717 West Sprague Ave., Suite 1200 Spokane, W A 99201-3505 Ell1ail to r. b lair.strong~ypaineha111blen.coll1 Peter Richardson O. Box 1849 Eagle, ID 83616 Email to peter~richardsonandoleary .com Dean J. Miller McDevitt and Miller O. Box 2564 Boise, ID 83701 j oe((yll1cdevi tt -n1iller.con1 PETITION TO INTERVENE BY RNP AND NW ENERGY COALITION -- 4 William J. Batt John R. Hammond Batt & Fisher O. Box 1308 Boise ID 83701 Email to wlb(ip,batt6sher.com and irh~.0battfisher.com Mike Heckler W indland 7669 West Riverside Dr.Suite 102 Boise ID 83714 Email to mheckler(fYwindland.com William M. Eddie PETITION TO INTERVENE BY RNP AND NW ENERGY COALITION -- 5