20070413Petition to Intervene.pdf

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Rich Rayhill
ISB No. 3420
Ridgeline Energy, LLC
720 W Idaho, Suite 39
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone] (efax)
rrayhill~l-en.com
Attorney for Ridgeline Energy, LLC
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO REVISE THE
PUBLISHED AVOIDED COST RATES TO
INCLUDE A DAIL Y LOAD SHAPE; AND TO )
CLARIFY THE RULES GOVERNING
ENTITLEMENT TO PUBLISHED AVOIDEDCOST RATES
CASE NO. IPC-07-
PETITION TO INTERVENE
OF RIDGELINE ENERGY, LLC
COMES NOW, the Ridgeline Energy, LLC, hereinafter referred to
Intervenor " and pursuant to this Commission s Rules of Procedure, Rule 71 IDAPA
31.01.01.71 hereby petitions the Commission for leave to intervene herein and to appear
and participate herein as a party, and as grOlmds therefore states as follows:
The name and address of this Intervenor is:
Ridgeline Energy, LLC
c/o Rich Rayhill
720 W. Idaho, Suite 39
Boise, Idaho 83702
Telephone: [phone]
Fax: (208)
rrayhill~l-en.com
Copies of all pleadings, production requests, Production responses
Commission orders and other documents should be provided to Rich
PETITION TO INTERVENE
RlDGELINE ENERGY, LLC
Rayhill as noted above and to:
Robert M. Ellis, Esq.
4 Nickerson, Suite 301
Seattle, W A 98109
[phone]
[phone] (efax)
rellis(~xl-en.com.
Dennis Meany
8 Old Kings Highway
Norwalk, CT 06850
[phone]
[phone]
dmeany(~xl-en.com
This Intervenor, the Ridgeline Energy, LLC ("Ridgeline ) is a Washington
limited liability corporation registered and in good standing with the Idaho Secretary of
State and doing business in Idaho. Ridgeline claims a direct and substantial interest in
this proceeding in that it is a developer of wind powered generating projects as well
other types of renewable energy projects the output of which will be sold to the Idaho
Power Company. Ridgeline 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
PETITION TO INTERVENE
RIDGELlNE ENERGY, LLC
on its continued ability to develop wind powered electric generating projects in the State
of Idaho.
Granting this Intervenor s petition to intervene will not unduly broaden the
issues nor will it prejudice any party to this case.
WHEREFORE Ridgeline Energy, LLC, 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 13th day of April 2007.
Ridgeline Energy, LLC
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By tuB
Rich Rayhill, Vice P sident
Ridgeline Energy, LLC
PETITION TO INTERVENE
RIDGELlNE ENERGY, LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 13th day of April, a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY RIDGELINE ENERGY, 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
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Rich RaYllll
PETITION TO INTERVENE
RIDGELINE ENERGY, LLC