20140121Petition to Intervene.pdf

Deborah E. Nelson, ISB # 5711
Preston N. Carter, ISB # 8462
GIVENS PURSLEY LLP
601 W. Bannock St.
Post Offrce Box2720
Boise, Idaho 83701-2720
Telephone: [phone]
Facsimile: 208-388-1300
I 1067-18_1981906_l
Attorneys for Idaho Wind Partners I, LLC
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO
UPDATE ITS WIND INTEGRATION
RATES AND CHARGES
{1: *1$
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-13-22
IDAHO WIND PARTNERS I, LLC'S
PETITION TO INTERYENE
Idaho Wind Partners I, LLC ("IWP") petitions the Idaho Public Utilities Commission
("Commission") to intervene in the above-entitled matter pursuant to Rule 71 through 75 of the
Commission's Rules of Practice and Procedure, Idaho Administrative Rules 31.01.01 .071-075.
In support of this Petition, IWP states as follows:
1. The name and address of IWP is:
Idaho Wind Partners I, LLC
c/o RP Wind ID, LLC, its Managing Member
82 Elm Street
PO Box 2049
Manchester Center, VT 05255
IDAHO WIND PARTNERS I, LLC'S PETITION TO TNTERVENE - Page I
Case No. IPC-E-13-22
2. IWP's representatives for the purpose of service of pleadings and other written
materials are:
Deborah E. Nelson
Preston N. Carter
GIVENS PURSLEY LLP
601 W. Bannock Street
P.O.Box2720
Boise, ID 83701-2720
Telephone No. [phone]
Fax No. [phone]
Email address: den@ givenspursley.com
prestoncarter@ givenspursley. com
3. IWP owns and operates eleven wind farm developments, with a combined
capacity of 183 MW, in the Magic Valley of Idaho. IWP's project portfolio in Idaho consists of
the following projects: Burley Butte, Golden Valley, and Milner Dam in Cassia County; Camp
Reed in Elmore County; and Oregon Trail, Payne's Ferry, Pilgrim Stage Station, Salmon Falls,
Thousand Springs, Tuana Gulch, and Yahoo Creek in Twin Falls County (collectively, the
"Projects"). The Projects are Qualifying Facilities ("QFs") pursuant to the Public Utility
Regulatory Policies Act of 1978 ("PURPA"). The Projects are subject to existing Firm Energy
Sales Agreements ("FESAs") with Idaho Power, each of which has been approved by the
Commission.
4. IWP claims a direct and substantial interest in this proceeding because if
accepted, some or all the proposals in Idaho Power's Application, including the proposal to
impose new wind integration charges on projects with existing FESAs, could have a material
adverse economic impact on the Projects.
5. To protect its interests, IWP requests an opportunity to fully participate as aparty
in this proceeding and in any hearing, including, as necessary, to submit legal briefing, conduct
discovery, file motions and pleadings, provide written and oral argument, introduce evidence,
IDAHO WIND PARTNERS I, LLC'S PETITION TO INTERVENE - Page2
Case No. IPC-E-13-22
call and examine witnesses, and cross-examine witnesses, on the issues raised by Idaho Power's
Application. Given the nature and complexity of issues presented by Idaho Power's Application,
IWP requests that the Commission schedule a technical hearing, preceded by an appropriate
period during which discovery may be conducted.
6. IWP's participation in this case will not unduly expand the issues or prejudice any
party.
Accordingly, IWP respectfully requests that the Commission grant this Petition to
Intervene and authorize IWP to participate in the above-entitled proceeding with full rights as a
formal party.
DATED this 2l't day of January 2014.
GIVENS PURSLEY LLP
Deborah E. Nelson
Attorneys for ldaho Wind Partners I, LLC
IDAHO WIND PARTNERS I, LLC,S PETITION TO INTERVENE - Page 3
Case No. IPC-E-13-22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have on this 21't day of January 2014, served the foregoing
upon all parties of record in this proceeding, by delivering an original and seven copies upon:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702
And by mailing a copy thereof, properly addressed with postage prepaid, to:
Donovan E. Walker
Julia A. Hilton
Idaho Power Company
l22l W.Idaho St.
P.O. Box 70
Boise, lD 83702
Dean J. Miller
MoDEVITT & MILLER LLP
P.O. Box 2564-83701
Boise, ID 83702
Rick Koebbe, President
Idaho Winds LLC
5420 W. Wicher Rd.
Glenns Ferry, ID 83623
IDAHO WIND PARTNERS I, LLC,S PETITION TO INTERVENE - Page 4
Case No. IPC-E-13-22