20070622Petition.pdf

" "~
c'
: \
Peter J. Richardson
ISB No. 319
Richar son &-O~earYPLLCn
515 N. 2ih Street
O. Box 7218
Boise, Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
peter~richardsonandoleary .com
Attorneys for the Exergy Development Group of Idaho, LLC
,- , -
, ;, \ 0:
~:)
ZIu1,:;L'
~~ - ,
C; \ "
,,,
\:3:~"1ll,
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
ROCKY MOUNTAIN POWER FOR AN ORDER REVISING CERTAIN
OBLIGATIONS TO ENTER INTO
CONTRACTS TO PURCHASE ENERGY
GENERATED BY WIND-POWERED SMALL)
POWER GENERATION QUALIFYING FACILITIES
CASE NO. PAC-07-
PETITION TO INTERVENE
OF THE EXERGY DEVELOPMENT
GROUP OF IDAHO LLC
COMES NOW, the Exergy Development Group of Idaho, 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:
Exergy Development Group of Idaho, LLC
c/o Peter J. Richardson
Richardson & O'Leary, PLLC
515 N. 2ih
O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonandoleary .com
PETITION TO INTERVENE
EXERGY DEVELOPMENT GROUP, LLC
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:
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreading~mindspring. co
This Intervenor, the Exergy Development Group ofIdaho (Exergy) is an
Idaho limited liability corporation. Exergy claims a direct and substantial interest in this
proceeding in that it is a developer of wind powered generating projects as well as other
types of renewable energy projects the output of which may be sold to Rocky Mountain
Power. Exergy s ability to continue its business in Idaho may be affected by the outcome
of this proceeding.
This Intervenor 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.
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 continued ability to develop wind powered electric generating projects in the State
of Idaho.
Granting this Intervenor s petition to intervene will not unduly broaden the
PETITION TO INTERVENE
EXERGY DEVELOPMENT GROUP, LLC
issues nor will it prejudice any party to this case.
WHEREFORE the Exergy Development Group of Idaho 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.
(\~
DATED this day of June 2007.
Richardson & O'Leary, PLLC
AJ
Peter J. Richardson
Exergy Development Group of Idaho
PETITION TO INTERVENE
EXERGY DEVELOPMENT GROUP, LLC
CERTIFICATE OF SERVICE
I\Y
I HEREBY CERTIFY that on the I'J of June, a true and correct copy ofthe
, within and foregoing PETITION TO INTERVENE BY THE EXERGY DEVEOPMENT
GROUP OF IDAHO, LLC , was served by U.s. Mail, postage prepaid, to:
Brian Dickman
Rocky Mountain Power
201 S. Main Street, Ste. 2300
Salt Lake City, UT
Data Request Response
Center
PacifiCorp
825 NE Multnomah Ste. 2000
Portland, Or 97232
Dean J. Miller
McDevitt & Miller LLP
PO Box 2564
Boise, Idaho 83701-2564
Stephen E. Martin
Intermountain Wind, LLC
425 S. Homes
Idaho Falls, Idaho 83403-3189
&(),
Peter Richardson
..J
PETITION TO INTERVENE
EXERGY DEVELOPMENT GROUP, LLC