20130125Petition to Intervene.pdf

Peter J. Richardson
ISB No. 3195
Richardson & O'Leary
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
[e-mail]
Attorneys Pioneer Power, LLC
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
IDAHO POWER COMPANY FOR )
AUTHORITY TO MODIFY ITS NET ) METERING SERVICE AND TO INCREASE )
THE GENERATION CAPACITY LIMIT )
)
CASE NO. IPC-E-12-27
PETITION TO INTERVENE
OF PIONEER POWER, LLC
COMES NOW, Pioneer Power, 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 participate herein as a party, and as
grounds therefore states as follows:
The name and address of this Intervenor is:
Pioneer Power, LLC
do Peter J. Richardson
Richardson & O'Leary
515 N. 27' St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peterrichardsonandoleary.com
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter J. Richardson as noted above and to:
John Steiner
24597 Collett RD
Oreana, Idaho 83650-5070
[phone]
[e-mail]
2.This Intervenor, the Pioneer Power, LLC ("Pioneer") is Nevada limited liability
company duly qualified to conduct business in the State of Idaho. Pioneer owns and operates a
40 kw wind turbine that is providing net metering services to Idaho Power. Pioneer claims a
direct and substantial interest in this proceeding in that the terms and conditions of its net
metering service it provides to Idaho Power Company may be affected by the outcome of this
proceeding.
3.This Intervenor, in its capacity as a provider of net metering services to Idaho
Power intends to participate herein as a party, 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.
5.Without the opportunity to intervene herein, this Intervenor would be without any
means of participation in this proceeding which may have a material impact on its net metering
service electric rates and terms and conditions of service.
6.Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
Intervention - IPC-E-12-27 2
WHEREFORE, Pioneer Power, 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 necessary and appropriate; and to present evidence, call and examine witnesses, present
argument and to otherwise fully participate in these proceedings.
Q DATED this day of January 2013.
Richardson & O'Leary, LLP
By pa~10~ ,
P er J. Richardson
Pioneer Power, LLC
Intervention - WC-E- 12-27 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25th day of January 2013, a true and correct copy of
the within and foregoing PETITION TO INTERVENE OF PIONEER POWER, LLC was served
by U.S. Postal Service and electronic delivery to:
Matt Larkin
Greg Said
Idaho Power Company
P0 Box 70
Boise, Idaho 83707-0070
[e-mail]
gsaididahopower.com
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707-0070
[e-mail]
[e-mail]
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
Jean. iewellruc.idaho.gov
PowerWorks, LLC
do Chris Aepelbacher, Project Engineer
5420 W. Wicher Road
Glenns Ferry, Idaho 83623
[e-mail]
Nina Curtis
Administrative Assistant
Ben Otto
Idaho Conservation League
710 N. 6' Street
Boise, Idaho 83701
bouocidahoconservation.org
Intervention - IPC-E-12-27 4