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Home My WebLink About20250523Petition to Intervene.pdf RECEIVED May 23, 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: (208) 343-5105 Facsimile: (208) 343-5456 Email: tom.arkoosh(a,arkoosh.com Admin copy: erin.cecilkarkoosh.com Attorneys for IdaHydro BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) Case No. IPC-E-25-22 OF IDAHO POWER COMPANY FOR ) AUTHORITY TO UPDATE ITS ) IDAHYDRO'S PETITION TO OPERATION AND MAINTENANCE ) INTERVENE AND REQUEST FOR CHARGES APPLICABLE TO SCHEDULE ) HEARING 72, GENERATOR INTERCONNECTIONS ) TO PURPA QUALIFYING FACILITY ) SELLERS. ) 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 party, and as grounds therefor states as follows: I. 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: (208) 343-5105 Facsimile: (208) 343-5456 Email: tom.arkoosh(d,arkoosh.com With an email copy to: erin.cecil(a,arkoosh.com Copies of all pleadings,production requests,production responses,Commission orders and other documents should be provided as noted above. IDAHYDRO'S PETITION TO INTERVENE AND REQUEST FOR HEARING—Page 1 2. This Intervenor IdaHydro is a confederacy of Idaho small hydroelectric producers joined in a trust for mutual benefit, consisting of approximately 72 MW of capacity produced by 27 small hydroelectric plants. All its members currently sell electric power and energy to Idaho Power 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 Idaho Power 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 Idaho Power. 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. REQUEST FOR HEARING Proposed Intervenor objects to use of the Modified Procedure in processing the pending Application and requests a full hearing process. This matter, as reflected by the pre-filing of testimony by the Applicant, is fact-specific and thus deserving of the development of a full record to assist the Commission in accurate resolution. Further, the magnitude of both the requested increase in the operation and maintenance charges proposed to be levied against the Public Utility Regulatory Policy Act of 1978 on the Applicant's Schedule 72 was,as explained in the Application, originally a rate case component, which necessitates a hearing pursuant to Commission rules. DATED this 23rd day of May 2025. ARKOOSH LAW OFFICES C. Tom Arkoosh Attorney for IdaHydro IDAHYDRO'S PETITION TO INTERVENE AND REQUEST FOR HEARING—Page 2 CERTIFICATE OF MAILING I HEREBY CERTIFY that on the 23rd day of May 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) secretar ]2uc.idaho.gov P.O. Box 83720 Boise, ID 83720-0074 IDAHO PUBLIC UTILITIES U.S. Mail, Postage Prepaid COMMISSION STAFF: Overnight Courier Chris Burdin Hand Delivered Deputy Attorney General Via Facsimile Idaho Public Utilities Commission X_ E-mail: 11331 W. Chinden Blvd., Building 8, chris.burdingpuc.idaho.gov Suite 201-A (83714) P.O. Box 83720 Boise, ID 83720-0074 IDAHO POWER: Donovan E. Walker U.S. Mail, Postage Prepaid Idaho Power Company Overnight Courier 1221 W. Idaho Street(83702) Hand Delivered P.O. Box 70 Via Facsimile Boise, ID 83707 X E-mail: dwalker(a,idahopower.com dockets gidahopower.com Tim Tatum U.S. Mail, Postage Prepaid Riley Maloney Overnight Courier Idaho Power Company Hand Delivered 1221 W. Idaho Street(83702) Via Facsimile P.O. Box 70 X_ E-mail: Boise, ID 83707 ttatumgidahopower.com rmaloney(kidahopower.com C. Tom Arkoosh IDAHYDRO'S PETITION TO INTERVENE AND REQUEST FOR HEARING—Page 3