HomeMy WebLinkAbout20211210Petition to Intervene.pdfIDAHYDRO’S PETITION TO INTERVENE – Page 1
C. Tom Arkoosh, ISB No. 2253Amber Dresslar, ISB No. 10536ARKOOSH LAW OFFICES913 W. River Street, Suite 450P.O. Box 2900Boise, ID 83701Telephone: (208) 343-5105Facsimile: (208) 343-5456Email: tom.arkoosh@arkoosh.comEmail: amber.dresslar@arkoosh.comAdmin copy: erin.cecil@arkoosh.com
Attorneys for IdaHydro
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY’S APPLICATION FOR AUTHORITY TO PROCEED WITH RESOURCE PROCUREMENTS TO MEET IDENTIFIED CAPACITY DEFICIENCIES IN 2023, 2024, AND 2025 TO ENSURE ADEQUATE, RELIABLE, AND FAIR-PRICED SERVICE TO ITS CUSTOMERS.
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Case No. IPC-E-21-41
IDAHYDRO’S PETITION TO INTERVENE
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 and Amber
Dresslar of Arkoosh Law Offices, 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:
1. The name and address of the intervenor is:
IdaHydro c/o C. Tom Arkoosh and Amber Dresslar Arkoosh Law Offices 913 W. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701 Telephone: (208) 343-5105 Facsimile: (208) 343-5456 Email: tom.arkoosh@arkoosh.com
RECEIVED
2021 DEC 10 PM 3:04
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHYDRO’S PETITION TO INTERVENE – Page 2
Email: amber.dresslar@arkoosh.com With an email copy to: erin.cecil@arkoosh.com 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 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 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
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.
IDAHYDRO’S PETITION TO INTERVENE – Page 3
DATED this 10th day of December 2021.
ARKOOSH LAW OFFICES
_______________________________ C. Tom Arkoosh
Attorney for IdaHydro
IDAHYDRO’S PETITION TO INTERVENE – Page 4
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 10th day of December 2021, 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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-mail:
ry@puc.idaho.gov
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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X___
S. Mail, Postage Prepaid
er ered -mail:
@idahopower.com
ower.com
Vice President, Regulatory Affairs
Idaho Power Company
1221 West Idaho Street (83702) P.O. Box 70 Boise, ID 83707
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