20060515Petition.pdf

WILLIAMS BRADBURY
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May 15, 2006
Idaho Public Utilities Commission
Attention: Jean Jewell, Secretary
PO Box 83720
Boise, ID 83720-0074
RE:Case #s IPC- E-06-
Dear Jean:
Enclosed please find the original and seven copies of the Petition to Intervene of
Mountain View Power, Inc. in the above-referenced case. I will appreciate it if you will file
this petition with the Commission.
Thank you for your courtesy. If you have any questions please feel free to contact me.
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Ronald L. Williams
Attorney at Law
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1015 W. Hays Street - Boise, ID 83702
Phone: [phone] - Fax: [phone] - www.williamsbradbury.com
Ronald L. Williams ISB 3034
Williams Bradbury, P.
PO Box 2128
Boise, Idaho 83701-2128
Telephone: [phone]
Telecopier: [phone]
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Attorney for Mountain View Power, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR A CERTIFICATE
OF CONVENIENCE AND NECESSITY FOR THE
EV ANDER ANDREWS POWER PLANT
CASE NO. IPC-06-
PETITION TO INTERVENE OF
MOUNTAIN VIEW POWER, INC.
Mountain View Power, Inc. ("MVP" or "Intervenor ) petitions the Idaho Public Utilities
Commission for permission to intervene in this proceeding pursuant to Commission Rule
" IDAPA 31.01.01.71 as an Intervenor with full-party status.
II.
Intervenor will be represented in this proceeding by the firm Williams Bradbury, P.
All pleadings, notices, orders, productions requests, responses and communications related
to this case should be provided to the following:
Ronald L. Williams
Williams Bradbury, P.
P. 0 Box 2128
Boise ID 83701
ron(Q2wWjamsbrad bu rv. com
Robert D. Looper
President, Mountain View Power, Inc
1015 W. Hays Street
Boise, ID 83702
rlooper(Q2spellc. com
Petition to Intervene of Mountain View Power, Inc. - 1
III.
Idaho Power witness Greg Said states in his pre-filed direct testimony that the total
capital costs of the Siemens Westinghouse power plant proposal at the Evander Andrews
EA") were higher than other competitive bids. (Said , DI , p. 20). MVP has reason to believe
that it may have submitted the lowest cost bid to Idaho Power to construct the identical
Siemens Westinghouse power plant for Idaho Power at the Boise City Gateway Industrial
Park site ("Gateway ). Idaho Power witness Greg Said also testifies that the non-price
factors of "permit status, land ownership/control, location and regulatory requirements and
community support" allowed the EA site to move ahead of the other, more price competitive
sites - i.e., the Gateway site.
IV.
Intervenor has a direct and substantial interest in this proceeding for the reason that
MVP believes the non-price scoring attributes in the Idaho Power bid process may have
been inappropriately biased against MVP. Intervenor believes there are important ratepayer
ramifications to explore concerning Idaho Power s selection of a higher cost power plant site
that it owns -- based on "non-price" factors -- when compared to potentially lower cost sites
proposed to the Company by a third party.
Intervenor requests that it be allowed to participate in these proceedings as a party;
that it be allowed to introduce evidence , cross examine witnesses , call and examine
witnesses, and be heard in argument on all issues that may come before the Commission in
this proceeding.
WHEREFORE , Intervenor respectfully requests that the Commission grant this
Petition to Intervene in these proceedings and to allow MVP to appear and participate in all
Petition to Intervene of Mountain View Power, Inc. - 2
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 day of May, 2006.
Mountain View Power, Inc.
By euJJ L.4/
Ronald L. Williams
Williams Bradbury, P.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the day of May, 2006, I served a true and correct
copy of the within and foregoing document, via U.S. Mail , postage prepaid , upon all parties
of record , and addressed to the following:
Barton L. Kline
Monica B. Moen
Attorneys for Idaho Power Company
O. Box 70
Boise Idaho 83707-0070
James C. Miller
Sr. Vice President, Generation
Idaho Power Company
O. Box 70
Boise Idaho 83707 X~ilJ~
Ronald L. Williams
Williams Bradbury, P.
Petition to Intervene of Mountain View Power, Inc. - 3