20140121Petition to Intervene.pdf

Deborah E. Nelson, ISB # 5711
Preston N. Carter, ISB # 8462
GIVENS PURSLEY LLP
601 W. Bannock St.
Post Office Box2720
Boise, Idaho 83701-2720
Telephone: [phone]
Facsimile: 208-388- 1300
11488-0005 1983100 2
Attorneys for Rockland Wind Farm, LLC
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO
UPDATE ITS WIND INTEGRATION
RATES AND CHARGES
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-13-22
ROCKLAND WIND FARM, LLC'S
PETITION TO INTERVENE
Rockland Wind Farm, LLC ("Rockland") petitions the Idaho Public Utilities Commission
("Commission") intervene in the above-entitled matter pursuant to Rule 7l through 75 of the
Commission's Rules of Practice and Procedure, Idaho Administrative Rules 31.01.01 .071 - 075,
In support of this Petition, Rockland states as follows:
1. The name and address of Rockland is:
Rockland Wind Farm, LLC
1300 N. Northlake Way, 2nd Floor
Seattle, WA 98103
ROCKLAND WIND FARM, LLC,S PETITION TO INTERVENE _ Page
Case No. IPC-E-13-22
2. Rockland'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@ givenspursl e)r. com
3. Rockland owns and operates a wind farm development with a nameplate capacity
of 80 MW located in Power County, Idaho ("Project"). The Project is a Qualifying Facility
("QF") under the Public Utility Regulatory Policies Act of 1978 ("PURPA"). The Project is
subject to an existing Firm Energy Sales Agreement, as amended ("FESA") with Idaho Power.
The Commission approved the FESA in Case No. IPC-E-10-24.
4. Rockland 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 Project.
5. To protect its interests, Rockland requests an opportunity to fully participate as a
party 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, 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, Rockland requests that the Commission schedule a technical hearing, preceded by
an appropriate period during which discovery may be conducted.
ROCKLAND WIND FARM, LLC'S PETITION TO INTERVENE - Page2
Case No. IPC-E-13-22
6. Rockland's participation in this case will not unduly expand the issues or
prejudice any party.
Accordingly, Rockland respectfully requests that the Commission grant this Petition to
Intervene and authorize Rockland to participate in the above-entitled proceeding with full rights
as a formal party.
DATED this 2l't day of January 2014.
ROCKLAND WIND FARM, LLC'S PETITION TO INTERVENE - Page 3
Case No. IPC-E-13-22
GIVENS PURSLEY LLP
Attorneys for Rockland Wind Farm, LLL
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have on this 2l'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
l22lW. Idaho St.
P.O. Box 70
Boise,ID 83702
Dean J. Miller
McDEVITT & MILLER LLP
P.O. Box 2564-83701
Boise, ID 83702
Rick Koebbe, President
Idaho Winds LLC
5420 W. Wicher Rd.
Glenns Ferry, ID 83623
ROCKLAND WIND FARM, LLC'S PETITION TO INTERVENE - Page 4
Case No. IPC-E-13-22
Deborah E. Nelson