20171005Petition to Intervene.pdf

WILLIAMS BRADBI]RY
ATTORNEYSATI-AW
October 5,2017
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702
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-!Re: AVU-E-17-09
AVU-G-17-05
Dear Ms. Hanian:
Please find enclosed the original and seven copies of petition of Idaho Forest Group
for leave to intervene in the above referenced cases.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerely.o
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Ronald L. Williams
RLW
Enclosures
P.O. Box 388 - Boise, iD 83701
Phone: [phone] - www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
802 W. Bannock St., Suite 900
Boise, ID 83702
Telephone : [phone]
ron@williamsbradbury. com
Attorneys for Idaho Forest Group
(-t
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
In the Matter of the Joint Application of
HYDRO ONE LIMITED (acting through its
indirect subsidiary Olympus Equity LLC)
And
PETITION OF IDAHO FOREST GROUP
FOR LEAVE TO INTERVENE
AVISTA CORPORATION
For an Order Authorizing Proposed
Transaction
Pursuant to Rules 72 - 75 of the Idaho Public Utilities Commission's Rules of Practice
and Procedure, Idaho Forest Group LLC ("Idaho Forest") petitions the Idaho Public Utilities
Commission ("Commission") for leave to intervene. In support of this Petition, Idaho Forest
states as follows:
l. Idaho Forrest is a limited liability company organized and existing under the laws
of Delaware and authorized to conduct business in the State of Idaho. Idaho Forest is engaged in
the business of growing, harvesting and processing trees and forest products. The name and
address ofldaho Forest is:
Idaho Forest Group
687 Canfield Ave, Suite 100
Coeur d'Alene, ID 83815
2. Idaho Forest will be represented by, and all pleadings, papers, orders and notices
should be served upon the following persons at the addresses listed:
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Case No. AVU-E-17-09
Case No. AVU-G-17-05
IFG PETITION TO INTERVENE Page I
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
802 W. Bannock St., Suite 900
Boise, ID 83702
Telephone : [phone]
ron@williamsbradbury. com
In addition, all pleadings, papers, orders and notices should be served upon the following
persons at the addresses listed below:
Dean J. Miller
36208 Warm Springs Ave.
Boise,ID 83716
deanj [e-mail]
and
Lany A. Crowley, Director
The Energy Strategies Institute, Inc
5549 S. Cliffsedge Ave.
Boise, ID 83716
[e-mail]
3. Idaho Forest is an electric service customer of the Applicant Avista Corporation,
taking service under Applicant's Schedule 25-Extra Large General Service-Idaho. Idaho Forest's
facilities are located at Grangeville, Idaho, and at Lewiston, Idaho, and consist of a lumber
milling and processing operations. Accordingly, Idaho Forest has a direct and substantial
interest in this proceeding.
4. Without the opportunity to intervene herein, Idaho Forest would be without
adequate means of participation in this proceeding that may have a material impact on its electric
rates and terms and conditions of service.
5. Idaho Forest desires to participate in this proceeding with full rights of a party to,
if necessary, introduce evidence, cross-examine and participate in hearings or oral argument. The
exact quantity of evidence to be introduced cannot be stated at this time, but Idaho Forest's
participation will not unduly broaden the issues or cause delay.
IFG PETITION TO TNTERVENE Page2
WHEREFORE, Idaho Forest respectfully requests that the Commission grant its petition
to intervene with full party status in this proceeding and to appear and participate in all matters
as may be necessary and appropriate; and to present evidence, call and examine witnesses, cross-
examine witnesses, present argument, and to otherwise fully participate in the proceedings.
Dated this 5th day of October . 2017.
Respectfully submitted,
NII L
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Idaho Forest Group LLC
IFG PE,TITION TO INTERVENE Page 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 5th day of October ,2017,1 caused to be served a
true and correct copy of the foregoing document upon the following individuals in the manner
indicated below:
Hand Deliverv: (original andT copies)
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W . Washington Street
Boise, ID 83720
David J. Meyer, Esq.
Vice President and Chief Counsel for
Regulatory & Governmental Affairs
Avista Corporation
P.O.Box3727
141I East Mission Avenue
Spokane, WA99220-3727
Telephone: [phone]
Facsimile: (509) 495-885 1
Email: [e-mail]
Patrick Ehrbar
Director of Rates
State and Federal Regulation
Avista Corporation
P.O.Box3727
141I East Mission Avenue
Spokane, WA99220-3727
Telephone: [phone]
Facsimile: (509) 495-885 1
Email: [e-mail]
Elizabeth Thomas, Partner
Kari Vander Stoep, Partner
K&L Gates LLP
925 Fourth Avenue, Suite 2900
Seattle, WA 98104-1158
Telephone: [phone]
Facsimile: [phone]
Email : [e-mail]
Email: [e-mail]
IFG PETITION TO INTERVENE
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
I Federal Express
I Electronic Transmission
! Hand Delivery
f US Mail(postage prepaid)
! Facsimile Transmission
Federal Express
Electronic Transmission
E Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
! Federal Express
I Electronic Transmission
Page 4
James Scarlett
Executive Vice President &
Chief Legal Officer
Hydro One
483 Bay Street, 8th Floor, South Tower
Toronto, Ontario, M5G 2P5
Telephone: [phone]
Facsimile: [phone]
Email: j [e-mail]
Dean J. Miller
3620 8 Warm Springs Ave.
Boise, ID 83716
deanj [e-mail]
Lany A. Crowley, Director
The Energy Strategies Institute, Inc
5549 S. Cliffsedge Ave.
Boise,ID 83716
[e-mail]
f Facsimile Transmission
! Federal Express
[] Electronic Transmission
! Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
I Electronic Transmission
Hand Delivery
US Mail (postage prepaid)
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission
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Ronald L. Williams
Attorney for Idaho Forest Group LLC
IFG PETITION TO TNTERVENE Page 5