20110324Petition to Intervene.1.pdf

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]
petenmrichardsonandoleary.com
gregCfrichardsonandoleary.com
Attorneys for Grouse Creek Wind Park II LLC
RËCEIVËD
lOI1 MAR 24 PH 1: 58
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 II, LLC
) CASE NO. IPC-E-IO-62
)
) PETITION TO INTERVENE OF
) GROUSE CREEK WIND PARK II,
) LLC
)
)
)
COMES NOW, Grouse Creek Wind Park II, LLC, 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:
PETITION TO INTERVENE
IPC-E-1O-51
1
1. The name and address of ths Intervenor is:
Grouse Creek Wind Park II, 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]
peterCfríchardsonandoleary.com
gregCfrichardsonandoleary.com
2. This Intervenor, Grouse Creek Wind Park II, LLC is a Delaware limited liabilty
company, duly registered to conduct business in the State of Idaho. Grouse Creek Wind Park II,
LLC has the rights to develop and dispose of the output of the Grouse Creek Wind Park II, LLC
wind project, which is a qualifying facility under the Public Utility Regulatory Policies Act of
1978 ("PURP A").
3. Ths 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 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
ability to exercise its rights under PURP A to contract with an electrc utility, and to sell the
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PETITION TO INTERVENE
IPC- E-l 0-61
output of its qualifying facility.
WHEREFORE, Grpuse Creek Wind Park II, LLC respectfully requests that thiS:, ' :~,.
comJssion grant its petiti$n to Intervene in these proceedings and tó appear arid parti~i~ate in
all matters as may be necessar and appropriate; and to present evidence, call ard ex-amine
witnesses, present argument and to otherwse fully paricipate in these proceedings.
DATED this 24th day of March, 2011.
RICHARSON AND O'LEARY, PLLC
By:~~Peter J. Richardson
Gregory M. Adams
Attorneys for Grouse Creek Wind
Park II, LLC
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PETITION TO INTERVENE
IPC-E-I0-61
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 24th day of March, 2011, a true 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
dwalkerCfidahopower .com
InordstromCfidahopower .com
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(x) Electronic Mail
Randy Allphin
Idaho Power Company
POBox 70
Boise, ID 83707
rallphinCfidahopower. com
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(x) Electronic Mail
Signed GL
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PETITION TO INTERVENE
IPC- E-l 0-61