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Home My WebLink About20170621Petition to Intervene.pdfMichael C. Creamer (ISB No. 4030) Preston N. Carter (ISB No. 8462) Givens Pursley LLP 601 W. Bannock St. Boise, lD 83702 Telephone: (208)-388 -1200 Facsimile: (208) -388-l 300 mcc@ givenspursley. com IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPAI{Y TO REVIEW THE SURROGATE AVOIDABLE RESOURCE (SAR) METHODOLOGY FOR CALCULATING PUBLISHED AVOIDED COST RATES iii:il E t'JEi) .,ii _1:r;l i i Pli 2: 00 ri,-'lf',Il Attorneys for Tamarack Energt Partnership BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. GNR-8.I7-02 TAMARACK ENERGY PARTNERSHIP'S PETITION TO INTERVENE COMES NOW, Tamarack Energy Partnership, though its above-named attorneys, hereinafter referred to as "Tamarack," and pursuant to this Commission's Rules of Procedure, Rule 7 1 IDAPA 3 I .01 .01 .71 hereby petitions the Commission for leave to intervene in the above-captioned matter and to appear and participate as a full party: l. The name and address of the intervenor is: Tamarack Energy Partnership c/o Michael C. Creamer 601 W. Bannock Boise,lD 83702 Phone: (208) 388-1200 Facsimile: (208) 388-1300E-Mail: mcc@givenspursley.com Copies of all correspondence, comments, pleadings, production requests, production responses, Commission orders and other documents should be provided to Michael Creamer as noted above. TAMARACK ENERGY PARTNERSHIP'S PETITION TO INTERVENE - I 2. Tamarack is a partnership of Evergreen Energy, Inc. and PV Investments, Inc., and sells electricity generated at its lumber mill facilities in Kooskia, Idaho to Idaho Power Company (the "Company') pursuant to a vintage, thirty-five year term, firm energy/dispatchable resource Power Sales Agreement entered into in l98l . 3. Tamarack's existing contract with the Company provides for monthly payments that include a fixed capacity component and a variable energy component tied to variable energy costs of the Company's to-be decommissioned Valmy unit. 4. Tamarack has initiated discussions with the Company in contemplation of entering into a replacement Energy Sales Agreement ("ESA"), and is one of the five projects identified at pages 6-7 of the Company's Response and Objection filed in this matter as likely requesting to enter into replacernent ESAs with the Company in 2018. As such, Tamarack has a direct and substantial interest in these proceedings. 5. Without the opportunity to intervene, Tamarack would be without a means of participation in this proceeding, which may have a material impact on the rates it would be entitled to receive under any replacement ESA with the Company. Indeed, depending on the outcome of this proceeding, it could be economically infeasible for Tamarack to continue to sell firm, dispatchable energy to the Company under any ESA. 6. Tamarack intends to participate herein as a party, to submit comments, and if necessary, to introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in argument. The nature and scope of evidence Tamarack may introduce is dependent upon the nature and scope of other evidence in this proceeding. 7. Granting Tamarack's Petition to lntervene will not unduly broaden the issues nor will it prejudice any other party to this case. TAMARACK ENERGY PARTNERSHIP'S PETITION TO INTERVENE - 2 CERTIFICATE OF SERVICE { I HEREBY CERTIFY that on theZ day of Jwrc,2017 I caused an original and seven (7) copies of the foregoing to be served upon: Ms. Diane M. Hanian, Secretary Idatro Public Utilities Commission 47 2 W . Washington Street Boise, lD 83702 by hand delivering the same to the above-named at the last known address(s) as set forth above and mailing a copy to the addresses below. Donovan E. Walker Idaho Power Company l22l W.Idaho Street PO Box 70 Boise, ID 83707 Michael Darrington Idaho Power Company PO Box 70 Boise,ID 83707 J.R. Simplot Company c/o Peter J. Richardson fuchardson Adams, PLLC 515 N. 27th Street PO Box 7218 Boise, ID 83702 Dr. Don Reading 6070 Hill Road Boise,ID 83703 Clint Kalich Avista Utilities l41l East Mission Street POBox3727 Spokane, WA 99220-3727 TAMARACK ENERGY PARTNERSHIP'S PETITION TO INTERVENE .4 a Daniel MacNeil PacifiCorp 825 NE Multnomah Street Portland, OR 97232 Yvonne Hogle Ted Weston PacifiCorp 1407 West North Temple, Ste. 330 Salt Lake City, UT 84116 Idahydro clo C. Tom Arkoosh Arkoosh Law Offices PO Box 2900 Boise,ID 83701 Gregory M. Adams Richardson Adams, PLLC P O Box 7218 Boise, lD 83707 Irion Sanger Sanger Law, PC I I l7 SE 53d Avenue Portland, OR 97215 Michael C. Creamer TAMARACK ENERGY PARTNERSHIP'S PETITION TO INTERVENE - 5