20170609Petition to Intervene.pdf

C. Tom Arkoosh, ISB No. 2253
ARKOOSH LAW OFFICES
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attomeys for Idahydro
IN THE MATTER OF THE APPLICATION
OF THE ANNUAL UPDATE TO
PUBLISHED AVOIDED COST RATES TO
REFLECT AN UPDATED NATURAL GAS
PRICE FORECAST OF THE U.S. ENERGY
INFORMATION AGENCY (EIA)
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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Case No. GNR-E-17-02
IDAHYDRO'S PETITION TO
INTERVENE
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
Offrces, and pursuant to this Commission's Rules of Procedure, Rule 7l IDAPA 31.01.01.71,
hereby petitions the Commission for leave to intervene herein and to appear and participate
herein as a party, and as grounds therefore states as follows:
l. The name and address of the intervenor is:
Idahydro
clo C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
IDAHYDRO'S PETITION TO INTERVENE - Page I
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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 80 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. Therefore, Idahydro claims a direct and
substantial interest in this proceeding in that the prices it receives for electrical sales 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, cross-examine witnesses, call and examine witnesses, and be heard in argument. The
nature and quality of evidence which this Intervenor will introduce is 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 to Idaho Power.
5. Granting Idahydro's Petition to Intervene will not unduly broaden the issues nor
will it prejudice any party to this case.
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IDAHYDRO'S PETITION TO INTERVENE - Page 2
WHEREFORE, Idahydro respectfully requests that this Commission grant its Petition to
Intervene in these proceedings and to eppeax and participate in all matters as may be necessary
and appropriate and to fully participate in these proceedings.
DATED U, -fauyof June, 2017.
ARKOOSH LAW OFFICES
C. Tom
Attorney for Idatrydro
IDAHYDRO'S PETITION TO INTERVENE - Page 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the _*^,ofJune, 2017, I served a true and correct
copy of the foregoing document(s) upon the following person(s), in the manner indicated:
Original and 7 copies to:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, lD 83702
U.S. Mail, Postage Prepaid
Overnight CourierX Hand Delivered
Via Facsimile
E-mail
diane.hanian@puc. idaho. gov
Copies to:
Donovan E. Walker
Idaho Power Company
l22l W.ldaho Street
PO Box 70
Boise, ID 83707
x
x
U.S. Mail, Postage Prepaid
Ovemight Courier
Hand Delivered
Via Facsimile
E-mail
dwalker@idahopower. com
[e-mail]
Michael Darrington
Idaho Power Company
P.O. Box 70
Boise, ID 83707
x
x
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail
mdarrin gton@ idahopower. com
J.R. Simplot Company
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St.
PO Box 7218
Boise, ID 83702
x
x
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail
peter@ri chardsonadams. com
IDAHYDRO'S PETITION TO INTERVENE - Page 4
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
Clint Kalich
Avista utilities
l411 East Mission Street
Holland &Hart
POBox3727
Spokane, WA99220-3727
Daniel MacNeil
PacifiCorp
825 NE Multnomah Street
Portland, OR97232
Yvonne Hogle
Ted Weston
PacifiCorp
1407 West North Temple, Ste. 330
Salt Lake City, UT 841l6
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail
dreadin g@mindsprine. com
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail
clint. kalich@avistacom. com
U.S. Mail, Postage Prepaid
Ovemight Courier
Hand Delivered
Via Facsimile
E-mail
daniel.macneil@pacifi com.com
U.S. Mail, Postage Prepaid
Ovemight Courier
Hand Delivered
Via Facsimile
E-mail
yvonne. ho gle@Ecifi corp. com
ted.weston@pacifi corp.com
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C. Tom Arkoosh
IDAHYDRO'S PETITION TO INTERVENE - Page 5