LAW OFFICES DYKEMA GOSSETT PROFESSIONAL l_lMrTED LlABlLrrY COMPANY

800 M ICHIGAN N ATIONAL T OWER

L ANSING . M ICHIGAN 48933 742 Detroit, Michigan Ann Arbor, Michigan I Bloomfleld Hills, Michigan Grand Rapids, Michigan Washington, DC Chicago, Illinois T ELEPHONE (5 I 7) 374-9 100

F ACSIMILE (5 I 7) 374-9 I9 I WWW.DYKEMA.COM

CHRISTINE M ASON SONERAL DIRECT DIAL: (512) 374-9184 E-&IAIL: [email protected]

April 30,200l

Ms. Dorothy Wideman Executive Secretary Michigan Public Service Commission 6545 Mercantile Way, Ste. 7 Lansing, MI 48911

Re: Case No. U-12129-R WVPA 2000 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,

DYKEMA GOSSETT PLLC

Christine Mason Soneral

CMS/jmb Enclosure cc: Jon Bellgowan Mark Stallons John Miner

LANO1\78400.1 ID\CMA 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-12129-R month period ending December 31,200O. ) II ) I

PETITION TO INTERVENE OF MIDWEST ENERGY COOPERATIVE

;rCI 2 NOW COMES Midwest Energy Cooperative (“Midwest”), by and through its *% i attorneys, DYKEMA GOSSETT PLLC, and petitions to intervene in the above-entitled matter. I f In support thereof, Midwest states as follows: . 4 5 21 1. Midwest is a Michigan non-profit corporation engaged in the distribution I ; 2 and sale of electric energy to member-customers in portions of Cass, Kalamazoo, Lenawee, 2 5 E Monroe, St. Joseph, Van Buren and Berrien Counties in Michigan, Fulton and Williams Counties _. s r in Ohio and St. Joseph, LaGrange and Elkhart Counties in Indiana. Midwest has approximately

i 27,300 member-customers, consisting ofresidential, farm residential, seasonal, small commercial, e ; 2$ outdoor lighting and large power accounts. ez : 2. Midwest owns no electric generating facilities. It purchases all of its %:: 3 2 wrholesale electric power and energy requirements from Wabash Valley Power Association, Inc., BY (“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

; Honorable Commission grant the requested intervention, and that Midwest be treated as a full : ‘g $ party to these proceedings for all purposes. 2 4 m: Respectfully submitted, g DYKEMA GOSSETT PLLC

i Date: April 30, 2001 By: _ 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

**Jr**

In the matter of WABASH VALLEY POWER ) ilSSOCIATION, INC.‘S Power Supply Cost ) Reconciliation Proceeding for the twelve- ) Case No. U-12129-R month period ending December 31,200O. ) )

PROOF OF SERVICE

r/ STATE OF MICHIGAN ) z ; ) ss. [ COUNTY OF JNGHAM ) 0 E r Jeanne M. Beachnau, being first duly sworn, deposes and says that on May 1,2001, she zti r i caused to be served upon those persons on the attached Service List a copy of the Petition to & 2 Intervene ofMidwest Electric Cooperative in the above-entitled case by United States First Class F I 3 Mail and electronic mail. Y

Subscribed and sworn to before me on May 1,200l.

Shiawassee, Acting in 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 & Gotting 232 S. Capitol Ave., Suite 1000 Lansing, Michigan 48933

Mr. David M. Gadaleto Assistant Attorney General Michigan Public Service Commission 6545 Mercantile Way, Ste. 15 Lansing, MI 489 11

; Hon. James N. Rigas ! Administrative Law Judge g Utilities and Finance Services Division ; Ottawa State Office Bldg., 2”d Floor $ Lansing MI 48933 I