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Home My WebLink About20070313Petition to Intervene.pdf~ ~~;oo ~OUNTAIN r~:'C(' ,.:;::i'0 ,.- f ' :.. "~;? I.' . I) ao . ,, - .Jo 201 South Main, Suite 2300 Salt lake City, Utah 84111 March 13 , 2007 VIA OVERNIGHT DELIVERY ID,\hO i'UULiC UT!i~TIES CCi..::vi!SSiCJ Ms. Jean D. Jewell Commission Secretary Idaho Public Utilities Commission PO Box 83720 Boise, ID 83720-0074 Re:Petition of Rocky Mountain Power to Intervene in Case No. IPC-O7- Dear Ms. Jewell: Rocky Mountain Power , (" RMP" or the "Company ), hereby submits for filing an original and seven copies of a Petition to Intervene in Case No. IPC-07-03. Communications relating to this proceeding should be served on the following: Dean Brockbank Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Dean.Brockbank~Pacifi Corp. com Brian Dickman Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, UT 84111 Brian.Dickman~Pacifi Corp. com In addition, it is respectfully requested that all formal correspondence and Staff requests regarding this material be addressed to: By E-mail (preferred):datareq uest~pac ifi corp. com By Fax:(503) 813-6060 By Regular mail:Data Request Response Center PacifiCorp 825 NE Multnomah, Suite 2000 Portland, OR 97232 Sincerely, ~-(( ~I~. Jeffrey K. Larsen Vice President, Regulation Enclosure Dean Brockbank PacifiCorp 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Telephone: (801) 220-4568 FAX: (801) 220-3299 Dean.Brockbank~Pacifi Corp. com F~ i- : ::': :. 2007 11i\R I 3 I;/J 9: I 6 !1)'\:10 1~"Ul i.. l~TILiri~S CCi";iSSIU, Attorney for Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY'S PETITION TO INCREASE THE PUBLISHED RATE ELIGIBILITY CAP FOR WIND POWERED SMALL POWER PRODUCTION FACILITIES; AND) CASE NO. IPC-07- PETITION OF ROCKY MOUNTAIN POWER TO INTERVENE TO ELIMINATE THE 90%/110% PERFORMANCE BAND FOR WIND POWERED SMALL POWER PRODUCTION FACILITIES Pursuant to Rules of Procedure 53 and 71 through 73, Rocky Mountain Power, a division ofPacifiCorp ("RMP" or the "Company ), by and through its attorneys of record, respectfully petitions the Idaho Public Utilities Commission ("Commission ) for leave to intervene in the above captioned proceeding. In support ofthis Petition, Rocky Mountain Power states: Rocky Mountain Power does business as a public utility in the state of Idaho and is subject to the jurisdiction ofthe Commission with regard to its public utility operations. PacifiCorp also provides retail electric service as Rocky Mountain Power in the states of Utah and Wyoming, and as Pacific Power in the states of Oregon, Washington, and California. PacifiCorp s principal place of business is 825 NE Multnomah, Portland, OR 97272. PETITION TO INTERVENE ROCKY MOUNTAIN POWER II. Communications relating to this proceeding should be served on the following: Dean Brockbank Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Dean.Brockbank~Pacifi Corp. com Brian Dickman Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, UT 84111 Brian.Dickman~Pacifi Corp .com In addition, it is respectfully requested that all formal correspondence and data requests regarding this matter be addressed to: By email (preferred) By regular mail By facsimile datareq uest~pac ifi corp. com Data Request Response Center PacifiCorp 825 NE Multnomah, Suite 2000 Portland, OR 97232 (503) 813-6060 III. As an electric utility with a legal obligation to purchase power from Idaho qualifying facilities ("QFs ), Rocky Mountain Power has a direct and substantial interest in the outcome of this proceeding. Idaho Power Company s Petition in this proceeding seeks to remove the temporary reduction in the cap on entitlement to published avoided cost rates for intermittent wind powered QFs and address certain performance guarantees included in contracts to purchase energy from wind powered QFs. The Commission has applied the temporary entitlement cap published avoided cost rates for Rocky Mountain Power as well as Idaho Power, and RMP views this proceeding as having consequences for all investor owned utilities in Idaho IV. Rocky Mountain Power 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 PETITION TO INTERVENE ROCKY MOUNTAIN POWER delay the proceedings.No other party can adequately represent RMP's interests in this proceeding. WHEREFORE, Rocky Mountain Power respectfully requests that the Commission grant this petition to intervene. Respectfully submitted this 13 th day of March 2007. ~~~ Dean Brockbank Attorney for Rocky Mountain Power PETITION TO INTERVENE ROCKY MOUNTAIN POWER CERTIFICATE OF MAILING I HEREBY CERTIFY that on the 13th day of March 2007, I served a true and correct copy ofthe foregoing PETITION upon the following named parties by the method indicated below, and addressed to the following: Barton Kline Monica Moen Idaho Power Company PO Box 70 Boise, ID 83707 Jean Jewell Commission Secretary Idaho Public Utilities Commission 472 West Washington Boise, ID 83702 Peter J. Richardson Richardson & O'Leary PLLC 515 N. 2ib Street PO Box 7218 Boise, ID 83702 Dr. Don Reading 6070 Hill Road Boise, ID 83703 William M. Eddie Advocates for the West 610 SW Alder St., Suite 910 Portland, OR 97205 PETITION TO INTERVENE ROCKY MOUNTAIN POWER Hand Delivered S. Mail Overnight Mail FAX Hand Delivered S. Mail Overnight Mail FAX Hand Delivered S. Mail Overnight Mail FAX Hand Delivered S. Mail Overnight Mail FAX Hand Delivered S. Mail Overnight Mail FAX Natalie McIntire Renewable Northwest Project 917 SW Oak St., Suite 303 Portland, OR 97205 PETITION TO INTERVENE ROCKY MOUNTAIN POWER Hand Delivered s. Mail Overnight Mail FAX x.. Supervisor, Regulatory Administration