20220106Petition for Cross-Reconsideration.pdf

MC6 HYDRO LLC’S PETITION FOR CROSS-RECONSIDERATION – Page 1
C. Tom Arkoosh, ISB No. 2253ARKOOSH LAW OFFICES913 W. River Street, Suite 450P.O. Box 2900Boise, ID 83701Telephone: [phone]Facsimile: [phone]Email: [e-mail] copy: [e-mail]
Attorneys for IdaHydro
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY’S FOR APPROVAL OR REJECTION OF THE SECOND AMENDMENT TO THE ENERGY SALES AGREEMENT WITH MC6 HYDRO LLC FOR THE SALE AND PURCHASE OF ELECTRIC ENERGY FROM THE MC6 HYDRO PROJECT.
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Case No. IPC-E-21-30
MC6 HYDRO LLC’S PETITION FOR CROSS-RECONSIDERATION
Comes now MC6 Hydro LLC, an Idaho limited liability company (“MC6”), by and
through its counsel of record, C. Tom Arkoosh of Arkoosh Law Offices, pursuant to Rule 331,
and files this Petition for Cross-Reconsideration in support of the Petition for Reconsideration
(“Reconsideration”) filed by Idaho Power Company in the instant docket.
MC6 concurs with the Reconsideration. MC6 is in the process of amending the
nameplate capacity of the project generator to 2.1 megawatts (MW).
MC6 urges the Commission to set a reasonable materiality threshold for contracts at
de minimum variance with the machinery name plate capacity on a project. From the experience
of this developer, a variation of 1 MW or less in actual nameplate capacity, when compared to
the legal and administrative costs incurred by Idaho Power Company, the developer, and the
Commission, insistence upon an exact match-up between nameplate capacity and contract
values, is wasteful. Further, for the most part, the magnitude of these variances has proven to be
RECEIVED
2022 JAN 06 AM 8:00
IDAHO PUBLIC
UTILITIES COMMISSION
MC6 HYDRO LLC’S PETITION FOR CROSS-RECONSIDERATION – Page 2
“noise” in the utility’s system, thus not affecting rate payers.
DATED this 5th day of January 2022.
ARKOOSH LAW OFFICES _______________________________
C. Tom Arkoosh Attorney for IdaHydro
MC6 HYDRO LLC’S PETITION FOR CROSS-RECONSIDERATION – Page 3
CERTIFICATE OF MAILING I HEREBY CERTIFY that on the 5th day of January 2022, I served a true and correct
copy of the foregoing document(s) upon the following person(s), in the manner indicated:

____________________________________ C. Tom Arkoosh
Idaho Public Utilities Commission 11331 W. Chinden Blvd., Building 8, Suite 201-A P.O. Box 83720
Boise, ID 83720-0074

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ia Facsimile -mail:
[e-mail]
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720 Boise, ID 83720-0074
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ia Facsimile -mail: [e-mail]
Idaho Power:
Donovan E. Walker Regulatory Dockets Idaho Power Company 1221 West Idaho Street (83702)
P.O. Box 70 Boise, ID 83707
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-mail: @idahopower.com om [e-mail]