20060926Petition to intervene.pdf

Peter Richardson
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O. Box 1849 99 EaSt Stare Street, Eagle, Idaho 83616
September 26, 2006
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
Boise 10 83720-0074
RE: Case No. IPC-O6-
Dear Ms. Jewell:
Enclosed please find an original and seven (7) copies of the PETITION OF
EXERGY DEVELOPMENT GROUP OF IDAHO TO INTERVENE AND FOR LEAVE
TO FILE REPLY COMMENTS in the above case.
I have also enclosed an extra copy to be service-dated and returned to us for
our files. Thank you.
Sincerely,~Cus\~\
Nina Curtis
Administrative Assistant
end.
RECEIVED
Peter 1. Richardson
Mark Thompson
RICHARDSON & O'LEARYPLLC
515 N. 2ih Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(~,richardsonandoleary .com
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UTILItIES. COMMISSION
Attorneys for Exergy Development Group of Idaho LLC
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASSIA WIND FARM LLC ET AL.
PETITION OF EXERGY
DEVELOPMENT GROUP OF IDAHO
TO INTERVENE AND FOR LEAVE
TO FILE REPL Y COMMENTS
CASE NO. IPC-06-
IDAHO POWER COMPANY
COMES NOW, Exergy Development Group ofIdaho LLC, hereinafter referred to as
Exergy," and pursuant to Rules 71 and 72 of this Commission s Rules of Procedure (IDAPA
31.01.01.71- 72) hereby petitions the Commission for leave to intervene in the above-captioned
case, and to appear and participate herein as a party, including the right to file reply comments.
As grounds therefore, Exergy states as follows:
The name and address of this Intervenor is:
Exergy Development Group of Idaho LLC
c/o Peter J. Richardson
Richardson & O'Leary
515 N. 27th St
O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
PETITION TO INTERVENE OF EXERGY DEVELOPMENT GROUP
OF IDAHO -
peter(~,richardsonandoleary .com
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter J. Richardson as noted above and to:
Lawrence R. Lieb
Exergy Development Group of Idaho LLC
910 W. Main Street, Ste. 310
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
lr llal(ills bc glo bal.net
Exergy is an Idaho limited liability company that develops and owns QF projects, which
like Cassia Gulch Wind Park ("Cassia ), are among those requesting interconnection to Idaho
Power s transmission system in the Twin Falls, Idaho, area
The outcome of this proceeding may have a direct and material impact on the
costs that Exergy is responsible for when selling power to Idaho Power as a Qualifying Facility
QF"
Without the opportunity to intervene herein, Exergy would be without any means
of participation in this proceeding.
Granting Exergy s petition to intervene will not unduly broaden the issues in this
proceeding nor will it prejudice any party to this case.
Exergy understands that Cassia has requested that this proceeding be conducted
under the Commission s Rules of Modified Procedure, and that Cassia has proposed a schedule
under which Idaho Power (and possibly other utilities) will have a 30-day comment period to file
a responsive pleading, followed by a 14-day comment period for reply brief or memorandum.
Exergy also understands that the Commission has determined to adopt Cassia s proposed
schedule, as well as its request that the proceeding be conducted pursuant to Modified
Procedures.
PETITION TO INTERVENE OF EXERGY DEVELOPMENT GROUP
OF IDAHO - 2
Exergy supports Cassia s proposed schedule.
Exergy desires the opportunity to file reply brief or memorandum as set forth in
the schedule adopted by the Commission and otherwise participate as a party.
WHEREFORE Exergy respectfully requests that this Commission grant its Petition to
Intervene in this proceeding, and its request to appear and participate in all matters as may be
necessary and appropriate, including the opportunity to file reply comments in accordance with
the schedule in this proceeding.
Peter Richardson
Attorneys for Exergy Development Group of Idaho LLC
I HEREBY CERTIFY that on the ih day of May, a true and correct copy of the within and
foregoing PETITION TO INTERVENE BY THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER, was served by U.S. Mail, postage prepaid, to:
Barton Kline
Monica Moen
Idaho Power Company
PO Box 70
Boise, Idaho 80707-0070
Cassia Wind Gulch Park LLC
Joe Miller
McDevitt & Miller
420 West Bannock
Boise, Idaho 83702
And hand-delivered to:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
~Qu~
Nina Curtis
Administrative Assistan
PETITION TO INTERVENE OF EXERGY DEVELOPMENT GROUP
OF IDAHO - 3