Entry of Appearance & Motion for Full Party Status

BEFORE THE

PUBLIC SERVICE COMMISSION OF UTAH

In the Matter of The Consideration of the Amendment of 16 U.S.C. Section 2621 - Consideration and Determination Respecting Certain Ratemaking Standards for Electric Utilities by the Energy Policy Act of 2005 / Docket No. 06-999-03

ENTRY OF APPEARANCE & MOTION FOR FULL PARTY STATUS

FOR

HUNT TECHNOLOGIES, INC.

Scott H. DeBroff, Esquire
Smigel, Anderson, & Sacks
River Chase Office Center
4431 North Front Street
Harrisburg, PA 17110
Tel: (717) 234-2401
Fax: (717) 234-3611
eMail:
Dated: October 30, 2006 / Counsel for Hunt Technologies, Inc.

BEFORE THE

PUBLIC SERVICE COMMISSION OF UTAH

ENTRY OF APPEARANCE & MOTION FOR FULL PARTY STATUS

FOR

HUNT TECHNOLOGIES, INC.

INTRODUCTION

AND NOW COMES Scott H. DeBroff, Esquire of Smigel, Anderson, & Sacks LLP LLP, on behalf of his client, Hunt Technologies, Inc. ("Hunt") for the purpose of entering an appearance in the above captioned docket and to become a full participant in this rulemaking process in the above-captioned proceeding and avers the following:

1. Hunt Technologies, Inc. ("Hunt") is a party interested in the above-captioned docket as it is a meter technology provider which is interested in the efforts of the Public Utility Commission of Utah ("PSC” or "Commission") to examine Advanced Metering capabilities and potential development into the State of Utah. Hunt has a real and substantial interest in the above-captioned proceeding.

2. Hunt Technologies is the leading global provider of reliable, accurate and fully functional Advanced Meter Reading (AMR) and Advanced Metering Infrastructure (AMI) utility data systems. Hunt, with its international headquarters in Pequot Lakes, Minnesota, provides electric, water, and gas automated meter reading systems for Investor-Owned Utilities, Rural Electric Cooperatives, and Municipal Utilities.

3. The above-captioned proceeding started via a Notice of Scheduling Conference in this matter, entered on June 4 2006, such conference to address the new net metering, fuel sources, fossil fuel generation efficiency, time-based metering and communications, and interconnection standards as defined in the Energy Policy Act of 2005. The Scheduling Conference was held on Thursday, June 29, 2006 in Salt Lake City, Utah.

4. On July 17, 2006, the Staff filed two “Background” documents that summarized the requirements of this docket. One was a Background Information document that summed up the PURPA requirements in the law and the second was a document that laid out the Requirements for Evaluation of PURPA Standards Enacted by the Energy Policy Act of 2005.

5. On July 20, 2006, the Commission filed a Notice of Technical Conference for a meeting to be held on Wednesday, August 30, 2006. The purpose of this technical conference was to discuss the five new standards applicable to electric utilities enacted by the 2005 Energy Policy Act and the requirements for consideration and determination of these standards, to identify existing statutes and programs applicable electric utilities have in place which may potentially address the standards, and to set a further procedural schedule. During this conference, representatives of electric utilities were prepared to respond to the discussion items/questions and providing numerical support wherever possible.

6. On August 30, 2006, following the Technical Conference, the Commission posted a number of follow up documents from the Technical Conference to the docket, including the Commission’s Presentation, a List of Attendees, a PacifiCorp Time of Use Report and the FERC Demand Response and Smart Metering Report.

7. On October 10, 2006, the Commission filed a further Notice of Technical Conference, for a conference to be held on Tuesday, October 17, 2006, in order to address the first of the EPACT topics, Fuel Sources and Fossil Fuel Generation Efficiency Standards. Hunt would like to participate in the rulemaking and be involved primarily in the Smart Metering component.

8. Hunt wishes to participate in this docket as a full party and asks that it be granted full party status and notice of all activities related to this proceeding. Further, Hunt requests that it be placed on the Official Service List in this proceeding, and served with all pleadings, notices and orders.

9. Hunt looks forward to participating in the upcoming Technical Conference and sharing its thoughts regarding the state of the industry and the capabilities that exist to deliver smart metering to utilities. We look forward to presenting relevant technical information regarding the progress of advanced meter reading (AMR) and the creation of an advanced metering infrastructure (AMI).

10. All correspondence and pleadings in this docket should be directed to:

Scott H. DeBroff, Esquire

Smigel, Anderson, & Sacks

River Chase Office Center

4431 North Front Street

Harrisburg, PA 17110

Tel: (717) 234-2401

Fax: (717) 234-3611

eMail:

Respectfully submitted,

Dated: October 30, 2006 / By: / ______
Scott H. DeBroff, Esquire
Smigel, Anderson, & Sacks
River Chase Office Center
4431 North Front Street
Harrisburg, PA 17110
Tel: (717) 234-2401
Fax: (717) 234-3611
eMail:
Counsel for Hunt Technologies, Inc.