20230725Motion for Extension.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )CASE NOS.ATL-E-22-02
OF GREYLOCK ENERGY HOLDINGS,LLC )FOR APPROVAL OF ITS STOCK AND )MOTION TO EXTEND TIME
OWNERSHIP INTERESTS PURCHASE )FOR COMPLIANCE FILING
AGREEMENT WITH ISRAEL RAY FOR )
THE ACQUISITIONOF THE ATLANTA )POWER COMPANY )
BACKGROUND
On December 2,2022 Greylock Energy Holdings was ORDERED that no later than
August 1,2023,the parties shall submit updated and complete legal descriptions of the land swap
described in Section 6.4 of the PSA,indicating clear ownership of the land in question,and clearly
delineating Greylock's access to all equipment and land necessary for the continued operation of
Atlanta Power.-Order No.35649
Greylock Energy Holdings is unable to meet the deadline of August 1,2023 and would
like to request an extension for the following reasons
•After assessing the system,Atlanta Power District decided to focus on reliability and
safety.
•With funds being limited and the remote location of Atlanta,Idaho it has been a
challenge finding a surveyor who will not only come but willingto quote a reasonable
price.
REQUST FOR RELIEF
For the above reasons we request that the Commission extend the date for filing the
compliance filing ordered in Order No.35649 to May 16',2024
Arnold Eugene Haugh Jul 24-2023 14:17 MDT)
Arnold Haught
Nick J es (Ju124,2023 14:06 MDT)
Nick Jones
MOTION TO EXTENDTIME FOR COMPLIANCEFILENG Î
RECEIVED
2023 JULY 25, 2023 8:00AM
IDAHO PUBLIC
UTILITIES COMMISSION