20180319Petition to Intervene - Avista.pdf

WILLIAMS BRADBI]RY
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March 19,2018
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washinglon
Boise, ID 83702
Re: GNR-U-I8-01
Dear Ms. Hanian:
Please find enclosed the original and seven copies of the petition of Idaho Forest
Group for leave to intervene and notice of partial waiver of service in the above referenced
case.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Ronald L. Williams
RLW
Enclosures
P.O. Box 388 - Boise, ID 83701
Phone: [phone] - www.williamsbradbury.com
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Ronald L. Williams,ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
Telephone: [phone]
ron@williamsbradbury. com
RECEIVED
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Attorneys for Idaho Forest Group
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE
INVESTIGATION INTO THE IMPACT OF
FEDERAL TAX CODE REVISIONS ON
UTTLITY COSTS AND RATEMAKING
Case No. GNR-U-I8-01
LATE FILED
PETITION OF IDAHO FOREST GROUP
FOR LEAVE TO INTERVENE AND
NOTICE OF PARTIAL WAIVER OF
SERVICE
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, IFG states as
follows:
l. Idaho Forest recognizes that Commission Order No. 33991 established March 6
as the date for interventions to be filed in this case, and that this Petition for Intervention is
approximately two weeks late. However, this late filed intervention comes before the March 30th,
2018, date for utilities to file reports on the effect of tax changes on proposed tariffs. As of the
date of this Petition, no substantive pleadings have been filed and no substantive positions have
been taken by any party in this case, and Idaho Forest does not believe it's late filed intervention
at this early stage ofthe case prejudices any other party in the case.
2. 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:
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IFG PETITION TO INTERVENE Page 1
Idaho Forest Group
687 Canfield Ave, Suite 100
Coeur d' Alene, ID 83815
3. Idaho Forest will be represented by, and all pleadings, papers, orders and notices
should be served upon the following persons at the addresses listed:
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
Boise,ID 83701
Telephone: [phone]
ron@wil I iamsbradbury 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
com
4. Idaho Forest is an electric service customer of the Avista Corporation (Avista),
taking service under Avista's Schedule 2l-ExtraLarge 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.
5. 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.
IFG PETITION TO INTERVENE Page 2
6. 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.
1. Idaho Forest recognizes this is a multi-utility docket and wishes only to
participate in the portion of this case as it relates to Avista. In the interest of efficiency and to
avoid unnecessary filings and mailings, Idaho Forest hereby waives services of all process,
including pleadings, documents, disks and electronic files in this matter that are not relevant to
Avista or that do not impact Avista.
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 l9th day of March 2018.
Respectfully submitted,
fl"-
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Idaho Forest Group LLC
IFG PETITION TO INTERVENE Page 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this l9th day of March,20l8, I 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
! Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission
David J. Meyer
Avista Corporation P.O. Box3727
1411 East Mission Avenue
Spokane, WA99220-3727
david.meyer@avistacorp. com
Kelly Norwood
Avista Corporation P.O. Box3727
1411 East Mission Avenue Spokane,
w499220-3727
[e-mail]
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, ID 83702 peter@richardsonadam s.com
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dreading@mindspring. com
Dean J. Miller
36208 Warm Springs Ave.
Boise, ID 83716
deanj [e-mail]
Hand Delivery
US Mail (postage prepaid)
E Facsimile Transmission
! Federal Express
I Electronic Transmission
! Uand Delivery
E US Mail (postage prepaid)
E Facsimile Transmission
Federal Express
Electronic Transmission
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
! Federal Express
I Electronic Transmission
! Uand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
IFG PETITION TO INTERVENE, Page 4
I Electronic Transmission
trtrT
Lany A. Crowley, Director
The Energy Strategies Institute, Inc.
5549 S. Cliffsedge Ave.
Boise,ID 83716
[e-mail]
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission
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Ronald L. Williams
IFG PETITION TO INTERVENE, Page 5