20220502Petition to Intervene.pdf

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- ': ' i:' itri -''' uu'C. Tom Arkoosh, ISB No.2253
Amber Dresslar,ISB No. 10536
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email : [e-mail]
Admin copy: erin.ceci [e-mail]
Attorneys for IdaHydro
IN THE MATTER OF COMMISSION
STAFF'S APPLICATION TO UPDATE
INPUTS TO THE *SURROGATE
AVOIDED RESOURCE'' METHOD
AVOIDED COST RATES
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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Case No. GNR-E-22-01
IDAHYDRO'S PETITION TO
INTERYEI\'E
COMES NOW the Idaho Hydroelectric Power Producers Trust, an Idaho Trust, d/b/a
ldaHydro ("IdaHydro"), by and through its counsel of record, C. Tom Arkoosh and Amber
Dresslar 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 therefore states as follows:
The name and address of the intervenor is:
IdaHydro
clo C. Tom Arkoosh and Amber Dresslar
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, tD 83701
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email : [e-mail]
With an email copy to: erin.cecil@,arkoosh.com
Copies of all pleadings, production requests, production responses, Commission orders
I
IDAHYDRO'S PETITION TO INTERVENE - Page I
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 90 MW of capacity
produced by 33 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 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, 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 and 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.
DATED this 2nd day of May 2022.
ARKOOSH LAW OFFICES
C. Tom Arkoosh
Attorney for ldaHydro
IDAHYDRO'S PETITION TO INTERVENE - Page 2
CERTE'ICATE OF' MAILING
I HEREBY CERTIFY that on the 2nd day of May 2022,I served a true and correct copy
of the foregoing document(s) upon the following person(s), in the manner indicated:
Commission Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Building 8,
Suite 201-A
P.O. Box 83720
Boise, ID 83720-0074
Dayn Hardie
Deputy Attorney General
P.O. Box 83720
Boise, lD 83702-0074
Mike Louis
Idaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83702-0074
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail:
secretarv@puc. idaho. gov
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail:
[e-mail]. gov
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail:
[e-mail]. gov
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x
x
C. Tom Arkoosh
IDAHYDRO'S PETITION TO INTERVENE - Page 3