20200813Comments.pdf

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C. Tom Arkoosh, ISB No.2253
Amber Dresslar, ISB No. 10536
ARKOOSH LAW OFFICES
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: [phone]
Email : tonr.arkoosh@)arkoosh.com
anrber.dress I ar@arkoosh. conl
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
COLEMAN HYDROELECTRIC LLC
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Admin: stacie.lbo com
Attorneys for Coleman Hydroelectric LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-20-27)
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COMMENTS OF THE COLEMAN
HYDROELECTRIC, LLC
COMES NOW Coleman Hydroelectric, LLC, by its manager and submits the following
preliminary comments in the above matter.
l. Request for more time to comment: The undersigned represents to this
Commission that this come as a surprise to me because I was unaware of the gravity of this
matter until I was contacted by Idaho Power on August 12,2020, and was unaware of the
comment filing deadline until August 12,2020. I would request an extension of time to file
more complete comments.
2. There was a legally enforceable obligation prior to May 31,2020: This project
has achieved all of the Schedule 73 contracting process prior to May 3l ,2020, except the
signatures prior to the rate change. The only ministerial matter remaining after that date was the
physical process of affixing signatures.
COMMENTS OF THE COLEMAN HYDROELECTRIC, LLC - 1
3. If the only way that a legally enforceable obligation in Idaho can be formed is by
a signed contract in or a meritorious complainq it is my rmderstanding the Commission has the
ability, and has exercised that ability in the past to grandfather atnibutes of contracts and is
requested to so in this instance.
DATED this l3e day of August 2020
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Amber Dresslar
CoMMENTS OF TIIE COLEMAN ITYITROELECTRIC, LLC -2
Donovan E. Walker
Regulatory Dockets
Idaho Power Company
PO Box 70
Boise, Idaho 837 07 -007 0
X E-MAIL
dwalker@idahopower. com
dockets@ idahopower.com
John Hammond
Deputy Attorney General
Idaho Public Utilities Commission
PO Box 83720
Boise.Idaho 83720
X EMAIL
John.hammond@nuc. idaho. sov
Energy Contracts
Idaho Power Company
PO Box 70
Boise,Idaho 83707
X EMAIL
energycontracts@ idahopower.com
CERTIFICATE OF SERYICE
I hereby certiff that I have this 13ft day of August 2020 served the foregoin g Comments
of the Commission Staff, in Case No. IPC-E-20-27, by emailing a copy thereof, to the following:
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Amber Dresslar
COMMEI{TS OF THE COLEMAN HYDROELECTRIC, LLC - 3