20170816Petition 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]
Attorneys for Idahydro
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BEUTTLIZED FOR
AVOIDED COST CALCULATIONS
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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Case No. IPC-E-17-12
IDAHYDRO'S PETITION TO
INTERVENE
COMES NOW the Idaho Hydroelectric Power Producers Trust, an Idaho Trust, d/b/a
Idahydro ("ldahydro"), by and through its counsel of record, C. Tom Arkoosh of Arkoosh Law
Offices, 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]
With an email copy to: [e-mail]
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided as noted above
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IDAHYDRO'S PETITION TO INTERVENE - Page I
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
28 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 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.
t, *JA,
DATED this lL2 day of August,2\l7.
ARKOOSH LAW OFFICES
C. Tom Arkoosh
Attorney for Idahydro
IDAHYDRO'S PETITION TO INTERVENE - Page 2
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on th. -k&"y of Augus t,2077,I served a true and correct
copy of the foregoing document(s) upon the following person(s), in the manner indicated:
Orieinal and 7 copies to:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, lD 83702
x
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail
di ane. han i anf@puc. idaho. gov
Copies to:
Donovan E. Walker
Regulatory Dockets
Idaho Power Company
PO Box 70
Boise, ID 83707
X
X
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail [e-mail]
[e-mail]
Michael Darrington
Energy Contacts
Idaho Power Company
PO Box 70
Boise, lD 83701
X
X
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail
mdarrin gton@idahopower. com
energycontacts@idahopower. com
C. Tom Arkoosh
IDAHYDRO'S PETITION TO INTERVENE - Page 3