County, maryland

BEFORE THE PUBLIC SERVICE COMMISSION

OF MARYLAND

IN THE MATTER OF THE APPLICATION *

OF DUKE ENERGY FREDERICK, LLC FOR *

A CERTIFICATE OF PUBLIC CONVENIENCE * CASE NO. 8891

AND NECESSITY TO CONSTRUCT A 640-MW *

GENERATING FACILITY IN FREDERICK *

COUNTY, MARYLAND

MOTION TO INTERVENE OF JODYE L. ROEBUCK

Pursuant to the Rules of the Public Service Commission of Maryland (“Commission” or “PSC”), Jodye L. Roebuck hereby files this Motion To Intervene in the above-captioned matter. In support of this Motion, Jodye L. Roebuck states:

1. 
   On June 18, 2001, Duke Energy Frederick, LLC filed an application for a Certificate of Public Convenience and Necessity (“CPCN”) to construct a 640 MW generating facility of electricity. The Facility’s primary power generation equipment will consist of two F-Class advanced combustion turbines, two heat recovery steam generators equipped with duct firing capabilities, and one steam turbine arranged in a combined-cycle configuration to maximize plant efficiency (a “two-on-one” configuration). According to Duke Energy Frederick, LLC’s application (‘description of the facility and the project’ section), “Current design plans call for clean-burning natural gas to serve as the Facility’s generation fuel source, although the possibility of adding oil-backup capability is under consideration. “
   
2. 
   By its CPCN application, Duke Energy proposes that electricity produced by the generating station would be delivered into PJM West through the generating station’s interconnection facilities to the Doubs Substation, which is owned by Allegheny Power (The Potomac Edison Company).
   
3. 
   Jodye L. Roebuck, the undersigned, is the owner of property at 1603 Gibbons Road, Point of Rocks, Maryland; property which would be adversely effected by the site location of a power plant. Accordingly, Jodye L. Roebuck wishes to be an interested party to this proceeding. Jodye L. Roebuck, as a property owner in the Adamstown Region and west of the proposed facility site, is concerned about property values, air quality (and health related issues), water quality and conservation, visual impacts as well as community characteristics that would effect the entire region.
   
4. 
   Jodye L. Roebuck can be contacted by mail at 1603 Gibbons Road, Point of Rocks, Maryland, 21777.
   
5. 
   Because her property at 1603 Gibbons Road, Point of Rocks, Maryland, comprises her single most valuable asset, Jodye L. Roebuck has substantial interests that are effected by Duke Energy Frederick, LLC’s proposed project.
   

WHEREFORE, Jodye L. Roebuck respectfully prays that she be permitted by order of this Commission to intervene in and be admitted as a party in this proceeding, with all the rights of a party as set forth in Sections 3-106 and 3-107 of the Public Utility Companies Code of Maryland.

Respectfully Submitted,
Jodye L. Roebuck