20070702Petition.pdf

William M. Eddie (ISB #5800)
ADVOCATES FOR THE WEST
610 SW Alder St., Suite 910
Portland, OR 97205
Ph: [phone]
Fax: [phone]
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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 QUALIFYINGFACILITIES
CASE NO.PAC-07-
(Reference related cases nos.
IPC-07-03 and A VU-07-
02)
PETITION TO INTERVENE
Pursuant to Idaho Public Utilities Commission Rules of Procedure 53 and 71
through 73, Renewable Northwest Project ("RNP") and NW Energy Coalition ("the
Coalition ) hereby seek intervention in the above-captioned matter. As discussed below
RNP and the Coalition have direct and substantial interests in these proceedings, and
therefore should be granted intervention.
Established in 1994, RNP promotes the responsible expansion of solar, wind and
geothermal energy in the Northwest. RNP works to establish policies that support
renewable energy development and nurture the development of a market for renewables.
RNP's unique coalition of members includes renewable energy project developers, public
and consumer interest groups, turbine manufacturers, environmental organizations and
others. RNP's address is 917 SW Oak St, Suite 303; Portland, Oregon, 97205.
PETITION TO INTERVENE BY RNP AND NW ENERGY COALITION --
The Coalition is a non-profit regional alliance of over 100 diverse environmental
civic, consumer, low-income customer advocacy groups, energy efficiency and
renewable energy businesses, and progressive utilities in Idaho, Montana, Washington
and Oregon. NW Energy Coalition advocates for increased energy conservation efforts
sustainable and ecologically-sound management of electric generating infrastructure
increased reliance on renewable sources of energy, and appropriate rate design policies
consistent with these goals. In Idaho , the Coalition has numerous individual members
and eleven (11) member organizations. NW Energy Coalition s address is: 219 First Ave
South, Suite 100, Seattle, W A 98104.
RNP and NW Energy Coalition have direct and substantial interests in this
proceeding because the Commission s implementation ofthe federal Public Utilities
Regulatory Policies Act (PURP A) has significant impacts upon investment in renewable
energy in Idaho. In addition, the Commission s review of the costs of integrating wind
power, and any policies adopted pursuant to that review, also are likely to have
significant impacts upon investment in wind power generation in Idaho. Both petitioning
organizations share an interest in promoting the responsible expansion of renewable
energy in the Northwest, and decisions issued in this case may impact their ability to
advance that interest. The interests advanced by RNP and the Coalition in this case seek
to promote the acquisition of least-cost and least-risk resources, as well as rate stability
for customers.
RNP and the Coalition seek intervention in order to fully participate in this matter
as parties and otherwise to present such materials as may be relevant to the Commission
PETITION TO INTERVENE BY RNP AND NW ENERGY COALITION -- 2
decision(s) in this matter. RNP and the Coalition intend to seek intervenor funding
pursuant to RP 161 through 165.
PLEASE TAKE NOTICE that RNP and NW Energy Coalition request all
documents in this matter be served to the following persons:
William M. Eddie
Advocates for the West
610 SW Alder St., Suite 910
Portland, OR 97205
Ken Dragoon
Renewable Northwest Project
917 SW Oak St, Suite 303
Portland, Oregon, 97205
WHEREFORE, RNP and NW Energy Coalition respectfully request that the
foregoing petition to intervene be granted.
Dated: June 28, 2007 Respectfully submitted
William M. Eddie, Attorney
On behalf of Renewable Northwest
Project and NW Energy Coalition
PETITION TO INTERVENE BY RNP AND NW ENERGY COALITION -- 3
CERTIFICATE OF SERVICE
I hereby certify that on this 28th day of June 2007, true and correct copies of the
foregoing PETITION TO INTERVENE were delivered to the following persons via U.
Mail:
Jean Jewell, Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Dean Brockbank
Senior Counsel
Rocky Mountain Power
201 South Main St., Suite 2300
Salt Lake City, UT 84111
Brian Dickman
Mgr., Idaho Regulatory Affairs
Rocky Mountain Power
201 South Main St., Suite 2300
Salt Lake City, UT 84111
Peter Richardson
Richardson & O'Leary, PLLC
515 N. 27th St.
Boise, ID 83702
Dr. Don Reading
6070 Hill Road
Boise, ID 83703
Dean J. Miller
McDevitt & Miller, LLP
O. Box 2564
Boise, ID 83701
Stephen E. Martin
Intermountain Wind, LLC
O. Box 3189
Idaho Falls, ID 83403-3189
William M. Eddie
PETITION TO INTERVENE BY RNP AND NW ENERGY COALITION -- 4