20250220Petition to Intervene.pdf

RECEIVED
Thursday, February 20, 2025
C. Tom Arkoosh, ISB No. 2253 IDAHO PUBLIC
ARKOOSH LAW OFFICES UTILITIES COMMISSION
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: tom.arkooshkarkoosh.com
Admin copy: erin.cecil&arkoosh.com
Attorneys for IdaHydro
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER AVISTA ) Case No. AVU-E-25-02
CORPORATION'S COMPLIANCE FILING )
TO UPDATE AND ESTABLISH ITS ) IDAHYDRO'S PETITION TO
CAPACITY DEFICIENCY PERIOD TO BE ) INTERVENE
USED FOR AVOIDED COST )
CALCULATIONS )
COMES NOW the Idaho Hydroelectric Power Producers Trust, an Idaho Trust, d/b/a
IdaHydro ("IdaHydro"), by and through its counsel of record, C. Tom Arkoosh of Arkoosh Law
Offices, and pursuant to the Idaho Public Utilities Commission Rules of Procedure, IDAPA
31.01.01.071-073, hereby petitions the Commission for leave to intervene herein and to appear
and participate herein as a parry, and as grounds therefor states as follows:
1. The name and address of the intervenor is:
IdaHydro
c/o C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: tom.arkoosh(d,arkoosh.com
With an email copy to: erin.cecil&arkoosh.com
Copies of all pleadings,production requests,production responses,Commission orders and
other documents should be provided as noted above.
2. This Intervenor IdaHydro is a confederacy of Idaho small hydroelectric producers
joined in a trust for mutual benefit, consisting of approximately 100 MW of capacity produced by
IDAHYDRO'S PETITION TO INTERVENE—Page 1

31 small hydroelectric plants. All its members currently sell electric power and energy to Avista
Corporation ("Avista") pursuant to multiple contracts and have the potential to sell additional
electric power and energy at other possible cogeneration and small power production locations in
Idaho. IdaHydro members all have Surrogate Avoided Resource pricing and Schedule 72
operation and maintenance. Therefore, IdaHydro claims a direct and substantial interest in this
proceeding in that the prices it receives for electrical sales and the costs it pays to Avista may be
affected by the outcome of this proceeding.
3. IdaHydro intends to participate herein as a party and, if necessary, to introduce
evidence, call and examine witnesses, cross-examine witnesses, and be heard in argument. The
nature and quality of evidence that this Intervenor will introduce are dependent upon the nature
and effect of other evidence in this proceeding.
4. Without the opportunity to intervene herein, this Intervenor would be without any
means of participation in this proceeding, which may have a material impact on the prices it
receives for electric sales and the costs it pays to Avista.
WHEREFORE, IdaHydro respectfully requests that this Commission grant its Petition to
Intervene in these proceedings and to appear and participate in all matters as may be necessary and
appropriate and to fully participate in these proceedings.
DATED this 20th day of February 2025.
ARKOOSH LAW OFFICES
C. Tom Arkoosh
Attorney for IdaHydro
IDAHYDRO'S PETITION TO INTERVENE—Page 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 20th day of February 2025, I served a true and correct
copy of the foregoing document(s)upon the following person(s), in the manner indicated:
IDAHO PUBLIC UTILITIES U.S. Mail, Postage Prepaid
COMMISSION: Overnight Courier
Commission Secretary Hand Delivered
Idaho Public Utilities Commission Via Facsimile
11331 W. Chinden Blvd., Building 8, X_ E-mail:
Suite 201-A (83714) secretgU&puc.idaho.-og_v
P.O. Box 83720
Boise, ID 83720-0074
IDAHO PUBLIC UTILITIES U.S. Mail, Postage Prepaid
COMMISSION STAFF: Overnight Courier
Michael Duval Hand Delivered
Deputy Attorney General Via Facsimile
Idaho Public Utilities Commission X_ E-mail:
11331 W. Chinden Blvd., Building 8, michael.duvalg]2uc.idaho.gov
Suite 201-A (83714)
P.O. Box 83720
Boise, ID 83720-0074
AVISTA CORPORATION:
David Meyer U.S. Mail, Postage Prepaid
VP & Senior Counsel for Regulatory and Overnight Courier
Governmental Affairs Hand Delivered
Avista Corporation Via Facsimile
1411 East Mission Avenue, MSC-10 X E-mail:
Spokane, WA 99220 david.meyer(cr�,avistacorp.com
Shawn Bonfield U.S. Mail, Postage Prepaid
Sr. Manager, Regulatory Policy Overnight Courier
Avista Corporation Hand Delivered
1411 East Mission Avenue, MSC-27 Via Facsimile
Spokane, WA 99220 X E-mail:
shawn.bonfield&avi stacorp.com
C. Tom Arkoosh
IDAHYDRO'S PETITION TO INTERVENE—Page 3