20070220Petition to Intervene.pdf

Peter 1. Richardson
ISB No. 3195
Richardson & O'Leary PLLC
515 N. 27th Street
O. Box 7218
Boise, Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
peter~richardsonandoleary .com
Attorneys for the Exergy Development Group of Idaho, LLC
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO INCREASE THE)
PUBLISHED RATE ELIGIBILITY CAP FORWIND POWERED SMALL POWER
PRODUCTION F ACTILITIES; and TO ELIMINATE THE 90%/110%
PERFORMANCE BAND FOR WIND
POWERED SMALL POWERED SMALL
POWER PRODUCTION FACILITIES
CASE NO. IPC-07-
PETITION TO INTERVENE
OF THE EXERGY DEVELOPMENT
GROUP OF IDAHO LLC
COMES NOW, the Exergy Development Group of Idaho, LLC, hereinafter
referred to as "Intervenor " and pursuant to this Commission s Rules of Procedure, Rule
71 IDAP A 31.01.01.71 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:
The name and address of this Intervenor is:
Exergy Development Group of Idaho, LLC
c/o Peter 1. Richardson
Richardson & O'Leary, PLLC
515 N. 27th St
O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonandoleary .com
PETITION TO INTERVENE
EXERGY DEVELOPMENT GROUP, LLC
Copies of all pleadings, production requests, Production responses
Commission orders and other documents should be provided to Peter 1.
Richardson as noted above and to:
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreading~mindspring.com
This Intervenor, the Exergy Development Group of Idaho (Exergy) is an
Idaho limited liability corporation. Exergy claims a direct and substantial interest in this
proceeding in that it is a developer of wind powered generating projects as well as other
types of renewable energy projects the output of which is sold to the Idaho Power
Company. Exergy s ability to continue its business in Idaho may be affected by the
outcome of this proceeding.
This Intervenor intends to participate herein as a party, and if necessary, to
introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in
argument. The nature and quality of evidence which this Intervenor will introduce is
dependent upon the nature and effect of other evidence in this proceeding.
Without the opportunity to intervene herein, this Intervenor would be
without any means of participation in this proceeding which may have a material impact
on its continued ability to develop wind powered electric generating projects in the State
of Idaho.
PETITION TO INTERVENE
EXERGY DEVELOPMENT GROUP, LLC
Granting this Intervenor s petition to intervene will not unduly broaden the
issues nor will it prejudice any party to this case.
WHEREFORE the Exergy Development Group of Idaho respectfully requests
that this Commission grant its Petition 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, present argument and to otherwise fully participate
in these proceedings.
DATED this 20th day of February 2007.
Richardson & 0' Leary, PLLC
PETITION TO INTERVENE
EXERGY DEVELOPMENT GROUP, LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 20th day of February, a true and correct copy of
the within and foregoing PETITION TO INTERVENE BY THE EXERGY
DEVEOPMENT GROUP OF IDAHO, LLC, was served by U.S. Mail, postage prepaid
to:
Barton Kline
Monica Moen
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
And hand-delivered to:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
CuJ\~\
Nina Curtis
Administrative Assistant
PETITION TO INTERVENE
EXERGY DEVELOPMENT GROUP, LLC