The URL can be used to link to this page

Home My WebLink About20110815Petition to Intervene.pdfPeter J. FUchardson ISB No. 3195 Gregory Adams ISB No. 7454 FUchardson & O'Leary 515 N. 27th Street P.O. Box 7218 Boise, Idaho 83702 Telephone: (208) 938-7901 Tel Fax: (208) 938-7904 Fax petercmrichardsonandolear .com gregcmrichardsonandolear.com Attorneys for Grand View PV Solar Two RECEIVED 2011 AUG i 5 Pt1 3: 32 UTI BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF) IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E- 11 - 10 DETERMINATION REGARDING THE FIRM ) ENERGY SALES AGREEMENT WITH ) PETITION TO INTERVENE INTERCONNECT SOLAR DEVELOPMENT,) OF GRAND VIEW PV SOLAR TWO LLC, FOR THE SALE AND PURCHASE OF )ELECTRIC ENERGY ) ) COMES NOW, Grand View PV Solar Two, hereinafer 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 as follows: 1. The name and address of this Intervenor is: Grand View PV Solar Two, LLC Peter FUchardson 515 N. 27th Street Boise, Idaho 83702 peter(frichardsonandoleary.com Copies of all pleadings, production requests, production responses, Commission orders and other documents should be provided to Peter FUchardson as noted above and to: Dr. Don Reading 6070 Hil Road Boise, Idaho 83703 (208) 348- 1 700 Tel (208) 383-0401 Fax dreadingcmmindspring.com If the paries utilize electronic service of document please then also include Mr. Robert Paul on the e-mail list at robertpau108cmgmaiL.com. 1. This Intervenor understads that discovery is curently taing place between the Staff of the Commission and Idaho Power that indicates changes in the maner in which Idaho Power calculates avoided cost rates for solar projects that are larger than 100 kw may be considered. Grand View PV Solar Two has a draft contract offer from Idaho Power with similar rates to those found in Interconnect Solar's pending contract for approval before this Commission 2. This Intervenor, Grand View Solar PV Two, LLC claims a direct and substantial interest in ths proceeding in that it is also a developer of solar QF projects in Idaho and is interested and directly affected by the methodology used by Idao Power in the determination of avoided cost rates for solar QFs larger than 100. 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 argument. The nature and quality of evidence which ths Intervenor will introduce is dependent upon the nature and effect of other evidence in this proceeding. Intervention - IPC-E-II-IO 2 5. Without the opportity to intervene herein, this Intervenor would be without any means of paricipation in this proceeding which may have a material impact on the avoided cost rates contaned in its proffered contract by Idaho Power. 6. Granting this Intervenor's petition to intervene will not unduly broaden the issues nor wil it prejudice any par to this case. 7. Grand View PV Solar Two recognizes that the Commission has issued a Notice of Modified Procedure that did not invite petitions for intervention to be fied. The Commission subsequently modified the deadline in the Notice of Modified Procedure for comments to accommodate Staff s need for additional time to review the rates contained in Interconnect Solar's power purchase agreement. The new dates are September 29 for initial comments and October 6 for reply comments. Grand View Solar may fie comments; however, without status as a pary, Grand View Solar will not have access to, or rights of, discovery, including access to confdential Idaho Power models. Grand View PV Solar Two will adhere to the existing schedule and its paricipation as a pary wil not delay this proceeding nor broaden the issues herein. WHEREFORE, Grand View PV Solar Two respectfully requests that this Commission grant its Petition to Intervene in these proceedings and to appear and paricipate in all matters as may be necessar and appropriate; and to present evidence, call and examine witnesses, present arguent and to otherwse fully paricipate in these proceedings. Intervention - IPC-E.ll-l 0 3 DATED ths 1 Sth day of August, 2011. Intervention - IPC-E-ll-lO Peter FUchardson By_rrA.~ Peter FUchardson Grand View PV Solar Two 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the15th day of August, 2011, a tre and correct copy of the withn and foregoing PETITION TO INTERVENE BY GRAND VIEW PV SOLAR TWI was served in the maner shown to: Ms. Jean Jewell Commission Secreta Idaho Public Utilities Commission 472 W. Washington (83702) PO Box 83720 Boise, ID 83720-0074 2L Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail Lisa Nordstrom Donovan Walker Idaho Power Company PO Box 70 Boise, Idaho 83707-0070 lnordstromcmidahopower.com bklinecmidahopower.com 2L Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail Kriss Sasser Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington Boise ID 83702 Scott. woodburycmpuc.idaho.gov L Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail Ronald Wiliams Wiliams Bradbur P.C. 1015 W. Hays St Boise ID 83702 roncmwiliamsbradbur.com .- Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail ~ÚMo\~Nina urtis Administrative Assistat Intervention - IPC-E-ll-l 0 5