LAW OFFICES DYKI%A GoSSE~ P ROFESSIONAL LHIED L IABILITY C OMPANY
800 M ICHIGAN NnnoNnL T OWER
ANSING ICHIGAN Detroit, Michigan Ann Arbor, Michigan L , M 48933- I 742 Grand Rapids, Mlchlgan Bloomfleld Hills, Michigan Washington, DC Chicago, Illinois T ELEPHONE (5 I 7) 374-Q IO0
F ACSIMILE (5 I 7) 374-Q I Q I WWW.DYKEMA.COt-4 DIRECT DIAL: (511) 324-91&k E-MAIL:[email protected]
April lo,2002
Ms. Dorothy Wideman Executive Secretary Michigan Public Service Commission 6545 Mercantile Way, Ste. 7 Lansing, MI 48911
Re: Case No. U-1261 1-R WVPA 2001 PSCR Reconciliation Midwest Petition to Intervene
Dear Ms. Wideman:
Enclosed please find original and four copies of Petition to Intervene of Midwest Energy Cooperative in the above-referenced matter. Also enclosed is Proof of Service upon the parties of record. Pursuant to the Notice of Hearing in this matter, the Petition is also being electronically filed
If there are any questions or comments, do not hesitate to contact me. Sincerely,
D-MA GOSSETT PLLC
Christine Mason Soneral
CMS/jmb Enclosure cc: Bob Hance Mark Stallons John Miner
LANO1\92305.1 ID\CMMA STATE OF MICHIGAN
BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION
*****
In the matter of WABASH VALLEY POWER ) ASSOCIATION, INC.% Power Supply Cost ) Reconciliation Proceeding for the twelve- ) Case No. U-1261 1-R month period ending December 31,200l. )
PETITION TO INTERVENE OF MIDWEST ENERGY COOPERATIVE
8 d NOW COMES Midwest Energy Cooperative (“Midwest”), by and through its 8 i attorneys, DYKEMA GOSSETT PLLC, and petitions to intervene in the above-entitled matter. z 2 In support thereof, Midwest states as follows: i 1. Midwest is a Michigan non-profit corporation engaged in the distribution 2 6 [ and sale of electric energy to member-customers in portions of Cass, Kalamazoo, Lenawee, 8 ; Monroe, St. Joseph, Van Buren and Berrien Counties in Michigan, Fulton and Williams Counties : B in Ohio and St. Joseph, LaGrange and Elkhart Counties in Indiana. Midwest has approximately : B! 27,597 member-customers, consisting ofresidential, farm residential, seasonal, small commercial,
1 outdoor lighting and large power accounts. ! 2. Midwest owns no electric generating facilities. It purchases all of its I; 8 $ wholesale electric power and energy requirements from Wabash Valley Power Association, Inc., El (“Wabash Valley”) pursuant to the terms of a Wholesale Power Supply Contract (“Contract”)
with Wabash Valley, dated March 1, 1977. Under the terms of the Contract, Wabash Valley is
the sole and exclusive supplier of electric power to Midwest at wholesale. The Contract has been approved by the Rural Electrification Administration, which provides financing to Wabash Valley
and its member systems.
3. Midwest is the only member system of Wabash Valley located in the State
of Michigan.
4. As the sole customer of Wabash Valley in Michigan, Midwest will be
affected by the outcome of this Power Supply Recovery proceeding.
5. Midwest does not yet have sufficient information to determine whether it
will support or oppose Wabash Valley’s filing. Midwest intends to engage in discovery relative
thereto and reserves the right to raise additional issues.
WHEREFORE, Midwest Energy Cooperative respectfully requests that this ‘-,8 g ; Honorable Commission grant the requested intervention, and that Midwest be treated as a full
1 party to these proceedings for all purposes. jr Respectfully submitted,
DYKEMA GOSSETT PLLC
1 Date: April lo,2002 8 Albert Ernst (P24059) Christine Mason Soneral (P58820) 800 Michigan National Tower Lansing, Michigan 48933 (517) 374-9184 STATE OF MICHIGAN
BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION
*****
In the matter of WABASH VALLEY POWER ) ASSOCIATION, INC.5 Power Supply Cost ) Reconciliation Proceeding for the twelve- ) Case No. U-12129-R month period ending December 31,200O. ) 1
PROOF OF SERVICE g/I STATE OF MICHIGAN ) f ) ss. g COUNTY OF INGHAM )
H Jeanne M. Beacbnau, being first duly sworn, deposes and says that on April 10,2002, she g ii; $ caused to be served upon those persons on the attached Service List a copy of the Petition to s $ Intervene of Midwest Electric Cooperative in the above-entitled case by United States First Class 5 f Mail and electronic mail. g H.
Subscribed and sworn to before me o
Shiawassee, Acting m Ingham Co., MI My commission expires: l/04/05 Wabash Valley Power Association Case No. U-12129-R
SERVICE LIST
Mr. Ronald W. Bloomberg Loomis, Ewert, Ederer, Parsley, Davis dz Gotting 232 S. Capitol Ave., Suite 1000 Lansing, Michigan 48933
Ms. Patricia S. Barone Assistant Attorney General Michigan Public Service Commission 6545 Mercantile Way, Ste. 15 Lansing, MI 48911
! Hon. Barbara Stump g Administrative Law Judge 85 Michigan Public Service Commission g 6545 Mercantile Way, Ste. 14 9 Lansing, MI 48911 . Be LANO1\92302.1 dDW E 2