20050713Petition to intervene.pdf

\!~.,..;
\lJ
William J. Batt
John R. Hammond, Jr.
BA TT & FISHER, LLP
U S Bank Plaza, 5th Floor
101 South Capitol Boulevard
O. Box 1308
Boise, Idaho 83701
[phone]
[phone] facsimile
\'L.
eM 4~ 2.3
""'
tine. H\ ,tuuv
.., ~
ii"~ puBLiC
I \l\~\ESJ COf~1~\SS\Oh
Attorneys for Windland Incorporated
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR AN ORDER
TEMPORARIL Y 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 TO INTERVENE
COMES NOW Windland Incorporated, herein called "Intervenor" and
pursuant to Rules 71 through 75 of the Idaho Public Utilities Commission s ("IPUC" or
Commission ) Rules of Practice and Procedure, IDAPA 31.01.01.071-075, and pursuant to that
Notice of Petition, Notice of Intervention, Notice of Scheduling, Notice of Hearing/Oral
Argument and Notice of Procedural Conference issued on July 1 , 2005 , hereby petitions the
Commission for leave to intervene herein and to appear and participate herein as a party, and as
grounds therefore states as follows:
(1)The name and address of this Intervenor is:
Windland Incorporated
7669 West Riverside Drive , Suite 102
Boise, ID 83714
Telephone: [phone]
Facsimile: [phone]
Email: wind~windland.com
ORIGINAL
PETITION TO INTERVENE, P. 1
This Intervenor will be represented by:
William J. Batt
John R. Hammond, Jr.
BA TT & FISHER, LLP
101 S. Capitol Blvd., Suite 500
O. Box 1308
Boise, ID 83701
Phone: [phone]
Fax: [phone]
Email: wib~battfisher.com
jrh~battfisher .com
and requests that copies of all pleadings, production requests and responses be sent to the
following:
William J. Batt
John R. Hammond, Jr.
BA TT & FISHER, LLP
101 S. Capitol Blvd., Suite 500
O. Box 1308
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: wib~battfisher.com
rh~ battfisher. com
Michael Heckler
Director of Marketing and Development
WIND LAND INCORPORATED
7669 West Riverside Drive, Suite 102
Boise, ID 83714
Telephone: [phone]
Facsimile: [phone]
Email: mheckler~windland.com
(2) The Intervenor owns, operates and develops wind farms and is currently in the
process of developing wind farms in the western United States, including two in Idaho. The
Intervenor, through a wholly owned subsidiary has bid the output of the wind farms it has under
development in Idaho, specifically, the Cotterel Mountain wind farm east of Burley in Cassia
PETITION TO INTERVENE, P. 2
County, Idaho in response to Idaho Power Company s 2004 RFP that was issued pursuant to its
most recently filed and Commission accepted Integrated Resource Plan.
(3) As a result, this Intervenor has a direct and substantial interest in this proceeding and
intends to participate in all respects herein as a party as may be required to represent its interests.
Intervenor s participation will also not unduly broaden the issues in this proceeding.
(4) Without the opportunity to intervene herein, this Intervenor would be without a
manner or means of participating in the lawful determination of issues which are raised by Idaho
Power in its Petition and which Commission determination of will affect directly and/or
indirectly the development of wind farms as a generating resource for utilities in Idaho.
WHEREFORE, this Intervenor requests that this Commission confirm this Intervenor
leave to intervene in these proceedings and to appear and participate in all matters as may be
necessary and appropriate; and to present evidence, call and examine witnesses, cross-examine
witnesses, present argument, and to otherwise fully participate in the proceedings.
DATED this 13th day of July, 2005.
Respectfully Submitted
Jo , Hammond, Jr.
~ & FISHER, LLP
101 South Capital Blvd., Suite 500
O. Box 1308
Boise, ID 83701
[phone]
PETITION TO INTERVENE, P. 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of July, 2005, I served the foregoing upon all
parties of record in this proceeding as indicated below.
Jean Jewell
IDAHO PUBLIC UTILITIES COMMISSION
472 W. Washington Street
O. Box 83720
Boise, ID 83702-5983
i i ewell~puc.state.id. us
) Certified Mail
) First Class Mail
( x ) Hand Delivery
) Facsimile
Barton L. Kline
Monica B. Moen
IDAHO POWER COMPANY
O. Box 70
Boise, ID 83707-0070
bk 1 ine~idahopower. com
mmoen~idahopower. com
) Certified Mail
(x) First Class Mail
) Hand Delivery
) Facsimile
John R. Gale
Vice President, Regulatory Affairs
IDAHO POWER COMPANY
O. Box 70
Boise, ID 83707-0070
rgale~idahopower .com
) Certified Mail
( x ) First Class Mail
) Hand Delivery
) Facsimile
Peter J. Richardson
RICHARDSON & O'LEARY PLLC
99 East State Street
O. Box 1849
Eagle, ID 83616
peter~ri chrdsonando I eary. com
) Certified Mail
( x ) First Class Mail
) Hand Delivery
) Facsimile
Richard L. Storro
Director, POWER SUPPLY
A VISTA CORPORATION
1411 E. Mission Ave
O. Box 3727, MSC- 7
Spokane , WA 99220-3727
di ckstorro~avis tacorp. com
) Certified Mail
( x ) First Class Mail
) Hand Delivery
) Facsimile
PETITION TO INTERVENE, P. 4
R. Blair Strong
PAINE, HAMBLEN, COFFIN
BROOKE & MILLER LLP
717 West Sprague Avenue, Suite 1200
Spokane, WA 99201-3505
r. blair .strong~painehamblen.com
Scott Woodbury
IDAHO PUBLIC UTILITIES COMMISSION
424 W. Washington Street
O. Box 83720
Boise, ID 83702-5983
PETITION TO INTERVENE, P. 5
) Certified Mail
(x) First Class Mail
) Hand Delivery
) Facsimile
) Certified Mail
) First Class Mail
(x) Hand Delivery
) Facsimile