20171027Withdrawal Petition to Intervene.pdf

Gregory M. Adams (ISB No. 7454)
Peter J. Richardson (ISB No. 3195)
Richardson Adams, PLLC
515 N.27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
gre g@richardsonadams. com
peter@richardsonadams. com
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
SHOROCK HYDRO INC., FOR THE SALE
AND PURCHASE OF ELECTRIC ENERGY
FROM THE ROCK CREEK 1 HYDRO
PROJECT.
RECEIVED
?0lIOCT e7 Pil h: 35
IDAFiC PUBLIC
i IT iLiTIES COilIMISSION
Attorneys for the Renewable Energy Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
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)
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CASE NO. IPC.E-I7-I4
RENEWABLE ENERGY
COALITION'S WITHDRAWAL
OF PETITION TO
INTERVENE
Pursuant to the Idaho Public Utilities Commission's ('oCommission") Rules of
Procedure, Rule 68, IDAPA 31.01.01.68, the Renewable Energy Coalition ("REC")
hereby withdraws its petition to intervene in this proceeding. REC does not necessarily
agree with the all of the assertions in Idaho Power Company's objection to REC's
petition to intervene. However, the stipulated motion of Idaho Power Company and
Shorock Hydro, Inc. effectively moots REC's primary concern in this proceeding by
stipulating the parties will not attempt to address the substantive issues of the
reasonableness ofthe 90-l l0 performance band and Schedule 72's operation and
maintenance charges in this case. Instead, the parties stipulated that those matters are left
to be addressed in a subsequent proceeding. REC agrees it is more reasonable to address
REC WITHDRAWAL OF PETITION TO INTERVENE
IPC-E-17-14
PAGE 1
those complex issues in a different proceeding without the time constraint of the parties'
expiring power purchase agreement. Accordingly, REC hereby withdraws its petition to
intervene.
Dated October R2On.
M. Adams (ISB No. 7454)
Adams, PLLC
515 N. 27th Street
Boise, ID 83702
Telephone: 208.938.223 6
Fax: [phone]
greg@richardsonadam s. com
REC WITHDRAWAL OF PETITION TO INTERVENE
IPC-E-17-14
PAGE 2
CERTIFICATE OF SERVICE
,g.,rnI HEREBY CERTIFY that on theU day of October 2017, a true and correct copy of the
within and foregoing WITHDRAWAL OF PETITION TO INTERVENE OF
RENEWABLE ENERGY COALITION TO INTERVENE in Case No. IPC-E-17-14 was
served by United States Mail, postage prepaid, and electronic mail to:
Donovan Walker
Idaho Power Company
l22l West Idaho Street
Boise, Idaho 83702
dwalker@idahopower. com
dockets@idahopower. com
Shorock Hydro, lnc.
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, Idaho 83701
tom. [e-mail]
I FURTHER CERTIFY that ontne4\a1of October 2017,a true and correct copy of
the within and foregoing WITHDRAWAL OF PETITION TO INTERVENE OF
RENEWABLE ENERGY COALITION TO INTERVENE in Case No. IPC-E-17-14 was
served by hand delivery to:
Daphne Huang
Deputy Attorney General
Idaho Public Utilities Commission
472West Idaho Street
Boise, Idaho 83702
daphne.huang@puc. idaho. gov
Adams
REC WITHDRAWAL OF PETITION TO INTERVENE
IPC-E-17-14
PAGE 3
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