20210614Petition to Intervene.pdf

C. Tom Arkoosh,ISB No. 2253
ARKOOSH LAW OFFICES
802 W. Bannock Street, Suite LP 103
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Admin copy: erin. ceci [e-mail]
Attorneys for IdaHydro
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOIDED COST CALCULATIONS
jr,; ii-i fil'i li: i9
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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Case No. IPC-E-2I-09
IDAIIYDRO'S PETITION TO
INTERVENE
AI\tD
JOINDER IN INDUSTRIAL
CUSTOMERS OF IDAHO POWER'S
MOTION TO STAY PROCEDURAL
SCHEDULE PENDING DISCOVERY
OPPORTIJNITY
AND
JOII\IDER IN INDUSTRIAL
CUSTOMERS OF IDAIIO POWER'S
WRITTEN PROTEST IN
OPPOSITION TO PROCEEDING
PURSUANT TO MODIFIED
PROCEDURE
COMES NOW the Idaho Hydroelectric Power Producers Trust, an Idaho Trust, d/b/a
IdaHydro ("IdaHydro"), by and through its counsel of record, C. Tom Arkoosh of Arkoosh Law
OfiEces, 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:
IDAHYDRO'S PETITION TO INTERVENE - Page I
1. The name and address of the intervenor is:
IdaHydro
clo C. Tom Arkoosh
Arkoosh Law Offrces
802 W. Bannock Street, Suite LP 103
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: tom. arkoosh(@arkoosh.com
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.
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 ldaho 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
IDAHYDRO'S PETITION TO INTERVENE - Page2
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.
Furthermore, IdaHydro hereby joins the Industrial Customers of Idatro Power's Motion to
Stay Procedural Schedule Pending Discovery Opportunity and Written Protest in Opposition to
Proceeding Pursuant to ModiJied Procedure.
DATED this 14tr of June 2021.
ARKOOSH LAW OFFICES
O
C. Tom Arkoosh
Attomey for IdaHydro
IDAHYDRO'S PETITION TO INTERVENE - Page 3
CERTIFICATE O[' MAILING
I HEREBY CERTIFY that on the 14tr of June 2021,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
472W. Washington
Boise,lD 83702
Edward Jewell
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702
Donovan E. Walker
Regulatory Dockets
Idaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise,ID 83707
Michael Darrington
Energy Contracts
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise,ID 83707
Peter J. Richardson
Richardson Adams, PLLC
515 N.27tr St.
P.O. Box 7218
Boise, lD 83702
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail:
[e-mail]. eov
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail:
edward j ewell fg)puc. idaho. gov
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail:
dwalker@idahopower. com
dockets@idahopower. com
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail:
mdarrin gton@idahoporver. com
enerqvcontracts@idahopower. com
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail:
peter@richardsonadams. com
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x
x
x
x
IDAHYDRO'S PETITION TO INTERVENE - Page 4
Ih. DonRcading
6070 HiU Road
Boise,ID 83703
x
U.S. Ivlail, Postage Prcpaid
Ov€rnight Couricr
Iland Delivered
Via Facsimile
Email:
dreadine@mindsprine. com
C. TomAr&oosh
IDAHYDRO'S PETITION TO INIERVENE - Page 5