20110407Petition to Intervene.pdf

. RECEIVED~r4RQj~Y
2011 APR - 7 PH a: 16ATTORNEYS AT LAW
Tel: [phone] Fax: [phone]
P.O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, ID 83702
April 7, 2011
Ms. Jean Jewell
Commission Secretar
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
RE: IPC-E-ll-Ol
Dear Ms. Jewell:
We are enclosing for filing in the above-referenced docket an original and seven (7)
copies of West em Desert Energy, LLC's PETITION TO INTERVENE.
An additional copy is enclosed for you to stamp for our records.
Sincerely,
Gregory M. Adams
Richardson & O'Leary PLLC
encL.
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]
peter(frichardsonandoleary.com
greg(frichardsonandoleary.com
Attorneys for Western Desert Energy, LLC
RECEIVED
201' APR -7 PH 4: , 6
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 WITH WESTERN DESERT
ENERGY, LLC FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY
) CASE NO. IPC-E-ll-Ol
)
) PETITION TO INTERVENE OF
) WESTERN DESERT ENERGY, LLC
)
)
)
)
COMES NOW, Western Desert Energy, 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-11-01
1
1. The name and address of this Intervenor is:
Western Desert Enegy, LLC
c/o Sandy Sanderson
1770 W. State Street #317
Boise, ID 83702
Copies of all fiings, 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]
peter'irichardsonando lear .com
greg'irichardsonando leary. com
2. This Intervenor, Western Desert Energy, LLC is an Oregon limited liability
company, duly registered to conduct business in the State of Idaho. Western Desert Energy,
LLC has the rights to develop and dispose of the output of the 5 megawatt ("MW") wind project
at issue in this case.
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 wil introduce is dependent
upon the natue and effect of other evidence in this proceeding.
4. Without the opportity to intervene herein, this Intervenor would be without
adequate means of paricipation in this proceeding which may have a material impact on its
2
PETITION TO INTERVENE
IPC-E-11-01
ability to exercise its rights under the Public Utility Regulatory Policies Act of 1978 ("PURPA")
to contract with an electric utility, and to sell the output of its qualifying facility.
WHEREFORE, Western Desert Energy, 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 argument and to otherwse fully paricipate in these proceedings.
DATED this 7th day of April, 2011.
RICHARDSON AND O'LEARY, PLLC
By:~Ch
Peter J. Richardson
Gregory M. Adams
Attorneys for Western Desert
Energy, LLC
3
PETITION TO INTERVENE
IPC-E-11-01
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th day of April, 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
dwalker(fidahopower .com
lnordstrom(fidahopower .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
rallphin(fidahopower.com
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(x) Electronic Mail
Signed ~¡ 02
8. Adams
4
PETITION TO INTERVENE
IPC-E-11-01