20210329Petition to Intervene.pdf

Gregory M. Adams (ISB No. 7454)
Peter J. Richardson (ISB No. 3195)
Richardson Adams, PLLC
515 N. 27ft Street
Boise,Idaho 83702
Telephone: [phone]
Fax [phone]
greg@richardsonadams. c om
p eter@richardsonadams. com
Attorneys for Fall River Rural Electric Cooperative, Inc.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
PACIFICORP FOR APPROVAL OR
REJECTION OF THE PURCHASE POWER
AGREEMENT WITH CHESTER DTVERSION
HYDRO PROJECT
CASE NO. PAC-E-21-06
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PETITION TO INTERVENE OF FALL
RIVER RURAL ELECTRIC
COOPERATIVE, INC.
Fall River Rural Electric Cooperative, Inc. ("Fall River") hereby petitions to intervene in
this proceeding under the Idaho Public Utilities Commission ("Commission") Rule of Procedure,
Rule 71 IDAPA 31.01.01.71, and as grounds therefore states as follows:
I. The name and address of this Intervenor is:
Fall River Rural Electric Cooperative, Inc.
c/o Bryan Case, CEO/General Manager
1150N 3400E
Ashton, D 83420
Bryan. C [e-mail]
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Gregory M. Adams at the address noted above.
2. Fall River is the owner and operator of the hydroelectric facility, known as the
"Chester Diversion Hydro Project," that is the subject of the power purchase agreement ("PPA")
PETITION TO INTERVENE OF FALL RTVER RURAL ELECTRIC COOPERATIVE, INC
PAC-E-21-06
PAGE 1
submitted for approval in this proceeding, and Fall River is the counter party to Rocky Mountain
Power in that PPA.
3. As the counter party to Rocky Mountain Power and owner and operator of the
facility, Fall River possesses information that may assist the Commission in its consideration of
the application in this proceeding. Additionally, Fall River has a direct and substantial interest in
this proceeding as a party to the PPA at issue whose rights and obligations to operate and sell the
output of its hydroelectric facility will be impacted by the outcome of this proceeding.
4. Fall River, through legal counsel, intends to participate herein as a party. Without
the opportunity to intervene herein, Fall River would be without any means of participation in
this proceeding which may have a material impact on its legal rights and obligations.
5. Granting Fall River's Petition to Intervene will not unduly broaden the issues
beyond their proper scope, nor will it unduly prejudice any party to this case.
WHEREFORE, Fall River respectfully requests that this Commission grant this Petition
to Intervene in these proceedings and to appear and participate in all matters as may be necessary
and appropriate.
DATED: March 29,2021.
RICHARDSON ADAMS, PLLC
By ls/ Gresor)) M. Adams
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27ft Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
PETITION TO INTERVENE OF FALL RTVER RURAL ELECTRIC COOPERATIVE, INC.
PAC-E-21-06
PAGE 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 29th day of March202I,I delivered true and correct
copies of the foregoing PETITION TO INTERVENE to the following parties via electronic mail:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
j an. noriyuki@puc. idaho. gov
Edward Jewell
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
edward j ewell@puc. idaho. gov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake city, uT 84116
ted.weston@pacifi corp.com
[e-mail]
Emily Wegener
Counsel
Rocky Mountain Power
1407 WestNorth Temple, Suite 320
Salt Lake city, uT 84116
emily. wegen er @pacifrcorp. com
Dated: March 29,2021
/s/ Gresory M. Adams
Gregory M. Adams (ISB No. 7454)
PETITION TO INTERVENE OF FALL RTVER RURAL ELECTRIC COOPERATIVE, INC.
PAC-E-21-06
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