20110318Petition to Intervene.pdf

(-:
Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
RICHARDSON & O'LEARY, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
petercmrichardsonandolear .com
gregcmrichardsonandoleary .com
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Attorneys for Delta Wind LLC
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR A DETERMINATION
REGARDING A FIRM ENERGY SALES
AGREEMENT BETWEEN IDAHO
POWER AND DELTA WIND, LLC
) CASE NO. IPC-E-IO-54
)
)
)
) PETITION TO INTERVENE OF
) DELTA WIND LLC
)
)
COMES NOW, Delta Wind LLC, hereinafter referred to as "Intervenor," and puruat 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:
1. The name and address of this Intervenor is:
Delta Wind LLC
C/O Cotterel WindEnergy Center LLC
150 N. Dairy Ashford
Building C, Suite 356D
Houston, TX 77079
1
PETITION TO INTERVENE
IPC-E-I0-54
Copies of all fiings, commssion orders, and other documents should be provided to:
Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
RICHARSON & O'LEARY, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
petercmrichardsonandolear .com
greg!ßrichardsonandoleary .com
2. This Intervenor, Delta Wind LLC is a Delaware limited liability company, duly
registered to conduct business in the State of Idaho. Delta Wind LLC has the rights to develop
and dispose of the output of the Delta Wind LLC wind project, which is a quaifying facility
under the Public Utility Regulatory Policies Act of 1978.
3. This Intervenor intends to paricipate herein as a pary, and if necessar, to
introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in
arguent. The nature and quality of evidence which this Intervenor wil introduce is dependent
upon the natue and effect of other evidence in this proceeding.
4. Without the opportunity to intervene herein, this Intervenor would be without
adequate means of paricipation in this proceeding which may have a material impact on its
abilty to exercise its rights under PURP A to contract with an electric utility, and to sell the
output of its qualifying facility.
WHEREFORE, Delta Wind LLC respectfully requests that this Commission grant its
Petition to Intervene in these proceedings and to appear and paricipate in all matters as may be
necessary and appropriate; and to present evidence, call and examine witnesses, present
arguent and to otherwise fully paricipate in these proceedings.
2
PETITION TO INTERVENE
IPC-E-1O-54
DATED this 17th day of March, 2011.
PETITION TO INTERVENE
IPC-E-I0-54
RICHARDSON AND O'LEARY, PLLC
By: JJC1
Peter J. Richardson
Gregory M. Adams
Attorneys for Delta Wind LLC
3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 17th day of March, 2011, a tre and correct copy ofthe
within and foregoing PETITION TO INTERVENE was served as shown to the following
paries:
Lisa Nordstrom
Donovan Walker
Idaho Power Company
PO Box 70
Boise, Idaho 83707
dwalker!ßidahopower.com
lnordstrom!ßidahopower.com
Randy Allphin
Idaho Power Company
POBox 70
Boise, ID 83707
rallphin!ßidahopower .com
Signed~ OJ
e Adams
PETITION TO INTERVENE
IPC-E-1O-54
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(x) Electronic Mail
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnght Mail
( ) Facsimile
(x) Electronic Mail
4