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Home My WebLink About20090416Petition to Intervene.pdf~r-:~~~lf~infi9l\lR \6 PM 3:28 Peter Richardson Tel: 208-938-7901 Fax: 208-938-7904 pete t~ richardson an dol eary. co m P.O. Box 1218 Boise.1D 83707 - 515 N. 27th St. Boise. ID 83702 April 16, 2009 Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission 472 W. Washington Boise, ID 83702 RE: IPC-E-09-03 Dear Ms. Jewell: We are enclosing an original and seven (7) copies of the PETITION TO INTERVENE OF THE NORTHWEST & INTERMOUNTAIN POWER PRODUCERS COALITION in the above case. An additional copy is enclosed for you to stamp for our records. Sincerely,~W~.\ Nina Curtis Richardson & O'Leary PLLC Susan K. Ackerman OSB No. 831382 9883 NW Nottage Drive Portland, Oregon 97229 Telephone: (503) 297-2392 Cell: (503) 720-7571 Susan.k.ackermanrmcomcast.net CE riO) 2009 APR 16 PM 3: 28 Peter J. Richardson ISB No. 3195 Richardson & O'Lear 515 N. 27th Street P.O. Box 7218 Boise, Idaho 83702 Telephone: (208) 938-7901 Tel Fax: (208) 938-7904 Fax peterrmrichardsonandoleary.com Attorneys for the Northwest and Intermountain Power Producers Coalition BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FORA ) CERTIFICATE OF PUBLIC CONVENIENCE ) AND NECESSITY FOR THE LANGLEY )GULCH POWER PLANT ) ) ) ) CASE NO. IPC-E-09-03 PETITION TO INTERVENE OF THE NORTHWEST & INTERMOUNTAIN POWER PRODUCERS COALITION COMES NOW, The Northwest & Intermountain Power Producers Coalition, hereinafter referred to as "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 paricipate herein as a pary, and as grounds therefore states as follows: 1. The name and address of this Intervenor is: Northwest & Intermountain Power Producers Coalition c/o Susan K. Ackerman 9883 NW Nottge Drive Portland, Oregon 97229 S usan.k.ackermanrmcomcast.net Copies of all pleadings, production requests, production responses, Commission orders and other documents should be provided to Susan K. Ackerman as noted above and to: Dr. Don Reading 6070 Hil Road Boise, Idaho 83703 (208) 348-1700 Tel (208) 383-0401 Fax dreadingrmmindspring.com Ifthe paries utilize electronic service of document please then also include Mr. Robert Kah on the e-mail list at rkah(ßnippc.org . 2. This Intervenor, the Northwest & Intermountain Power Producers Coalition, ("NIPPC") is a coalition of independent energy producers. NIPPC claims a direct and substatial interest in this proceeding in that NIP PC' s members are independent power producers, some of whom actively paricipated in the bidding process that is the subject of this docket. NIPPC's members are interested and directly affected by the methodology used by Idaho Power in the selection of successful bidders in this docket. 3. This Intervenor, in its capacity as a representative of independent energy producers intends to paricipate herein as a pary, and if necessary, to introduce evidence, cross- examine witnesses, call and examine witnesses, and be heard in argument. The nature and Intervention - IPC-E-09-03 2 Apr 16 09 10: 56a Susan K. Ackerman 503-297-2398 p.2 quality of evidence which ths Intervenor will introduce is dependent upon the nature and effect of other evidence in this proceeing. 5. Without the opportnity to intervene herein. this Intervenor would be without any means of paricipation in ths proceeing which may have a material impact on its members' abilty to succssfully paricipate in RFs offer by Idaho Power in the future. 6. Granting this Intervenor's petition to intervene wil not unduly broaden the issues nor will it prejudice any pary to this case. 7. NlPC recgnizes that its Pettion to Interene is filed out of time. However, at the prehearing conference in this docket al paries were informed ofNIPCs intention to fie and were notified of the scope of the issues NIPC intends to address. All paries were offered an opportty to object. No par objected. WHEREFORE, the Nortwest & Intermountan Power Producers Coalition respelly requests that this Commission grant its out of time Pettion to Interene in these proceedings and to appear and paricipate in all matters as may be necsar and appropriate; and to present evidence. call and exane witnesses. present argument and to otherwse fully paricipate in these proceedingso DATED this 16th day of April, 2009. Susa K ACker~;A · By Sft1-n- \C. lÌ1.tt/i;° /I\../': Susa K. Ackermn Northwest & Intermountan Power Produces Coalition InCCntion -1PCE-09-o3 ~ CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the16th day of April, 2009, a true and correct copy of the within and foregoing PETITION TO INTERVENE BY THE NORTHWST AND INTER- MOUNTAIN POWER PRODUCERS COALITION was served in the maner shown to: Ms. Jean Jewell Commission Secretar Idaho Public Utilities Commission 472 W. Washington (83702) PO Box 83720 Boise, ID 83720-0074 x. Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail Lisa Nordstrom Baron L. Kline Idaho Power Company PO Box 70 Boise, Idaho 83707-0070 Inordstrom(ßidahopower .com bklinermidahopower .com x. Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail Scott Woodbur Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington Boise ID 83702 Scott. woodburrmpuc.idaho.gov L Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail Dean J. Miler McDevitt & Miler LLP 420 W. Banock St (83702) PO Box 2564 Boise ID 83701 joe(ßmcdevittmiler .com _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile Electronic Mail Wiliam Borders Assistat General Counsel Invenergy Thermal Development LLC One South Wacker Dr., Suite 1900 Chicago, IL 60606 wbordersliinvenergyllc.com _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile Electronic Mail Intervention - IPC-E-09-03 4 Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Chtd. 201 E. Center PO Box 1391 Pocatello, ID 83204-1391 elo(ßracinelaw.net Anthony Yane 1 29814 Lake Road Bay Vilage, OH 44140 tonyrmyankel.net Ken Miler Clean Energy Program Director Snake River Alliance PO Box 1731 Boise, ID 83701 kmiler(ßsnakeriveralliance.org Betsy Bridge Idaho Conservation League 710 North Sixth Street (83702) POBox 844 Boise, ID 83701 bbridgermwildidaho.org ~Cu\h\ Nina Curis Administrative Assistat Intervention - IPC-E-09-03 _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile Electronic Mail _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile Electronic Mail _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile Electronic Mail _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile Electronic Mail 5