20110324Petition to Intervene.pdf

,
If
Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No: 7454)
Richardson & O'Lear, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
petercmrichardsonandoleary.com
gregcmrichardsonandoleary .com
Attorneys for Grouse Creek Wind Park LLC
RECEIVF.. n.....
'.. ..,~.
2011 MAR 24 PM i: 57
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR A DETERMINATION
REGARDING THE FIRM ENERGY
SALES AGREEMENT FOR THE SALE
AND PURCHASE OF ELECTRIC
ENERGY BETWEEN IDAHO POWER
COMPANY AND GROUSE CREEK
WIND PARK, LLC
) CASE NO. IPC-E-I0-61
)
) PETITION TO INTERVENE OF
) GROUSE CREEK WIND PARK, LLC
)
)
)
)
COMES NOW, Grouse Creek Wind Park, LLC, hereinafter referred to as "Intervenor,"
and pursuat 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:
PETITION TO INTERVENE
IPC-E-I0-51
1
1. The name and address of this Intervenor is:
Grouse Creek Wind Park, LLC
c/o Wasatch Wind Intermountain, LLC
2700 Homestead Road, Suite 210
Park City, Utah 84098
Copies of all filings, commission orders, and other documents should be provided to:
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]
petercmrichardsonandoleary.com
gregcmrichardsonandolear .com
2. This Intervenor, Grouse Creek Wind Park, LLC is a Delaware limited liability
company, duly registered to conduct business in the State ofIdaho. Grouse Creek Wind Park,
LLC has the rights to develop and dispose of the output of the Grouse Creek Wind Park, LLC
wind project, which is a qualifying facility under the Public Utility Regulatory Policies Act of
1978 ("PURP A").
3. This Intervenor 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 quality of evidence which this Intervenor will introduce is dependent
upon the nature 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
ability to exercise its rights under PURP A to contract with an electric utility, and to sell the
2
PETITION TO INTERVENE
IPC- E-l 0-61
output of its qualifying facility.
WHEREFORE, Grouse Creek Wind Park, 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 necessar and appropriate; and to present evidence, call and examine
witnesses, present arguent and to otherwise fully paricipate in these proceedings.
DATED this 24th day of March, 2011.
RICHARSON AND O'LEARY, PLLC
By:~
eter J. Richardson
Gregory M. Adams
Attorneys for Grouse Creek Wind
Park, LLC
3
PETITION TO INTERVENE
IPC- E-l 0-61
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 24th day of March, 2011, a tre and correct copy of the
within and foregoing PETITION TO INTERVENE was served as shown to the following
paries:
Lisa Nordstrom
Donovan Walker
Idaho Power Company
POBox 70
Boise, Idaho 83707
dwalkercmidahopower.com
lnordstromcmidahopower .com
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(x) Electronic Mail
Randy Allphin
Idaho Power Company
PO Box 70
Boise, ID 83707
rallphincmidahopower .com
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
" (x) Electronic Mail
Signed
4
PETITION TO INTERVENE
IPC- E-l 0-61