20230816Comments_Supp-Sorenson Eng_IdaHydro_1.pdf

SORENSON ENGINEERING, INC., AND IDAHYDRO’S SUPPLEMENTAL COMMENTS – Page 1
C. Tom Arkoosh, ISB No. 2253 ARKOOSH LAW OFFICES 913 W. River Street, Suite 450 P.O. Box 2900 Boise, ID 83701 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Admin copy: [e-mail] Attorneys for Sorenson Engineering, Inc., and IdaHydro BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
OF IDAHO POWER COMPANY FOR APPROVAL OR REJECTION OF AN ENERGY SALES AGREEMENT WITH AMERICAN FALLS RESERVOIR
DISTRICT NO. 2 FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY FROM THE DIETRICH DROP HYDRO PROJECT
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Case No. IPC-E-23-19 SORENSON ENGINEERING, INC., AND IDAHYDRO’S SUPPLEMENTAL
COMMENTS

COMES NOW Sorenson Engineering, Inc. (“Sorenson Engineering”), and Idaho
Hydroelectric Power Producers Trust, an Idaho Trust, d/b/a IdaHydro (“IdaHydro”), by and
through their counsel of record, C. Tom Arkoosh of Arkoosh Law Offices, and respectfully
submits the following supplemental comments pursuant to Order No. 35887. This Commenter
agrees with the Company’s Motion and Supplemental Comments explaining the need for a
Second Amendment to the proposed Power Sales Agreement (“PSA”) in the above matter.
Operations have confirmed an operational capacity in excess of the nameplate capacity which
should be accommodated in the PSA to avoid the negative consequence of producing in excess
of the PSA or the alternative irrational consequence of throttling down generation of renewable
energy from a hydroelectric project in a time of the Company’s capacity need.

RECEIVED
2023 AUGUST 15, 2023 4:32PM
IDAHO PUBLIC
UTILITIES COMMISSION
SORENSON ENGINEERING, INC., AND IDAHYDRO’S SUPPLEMENTAL COMMENTS – Page 2
It is respectfully requested that the Commission approve the PSA with First and Second
Amendments.
DATED this 14th day of August 2023.
ARKOOSH LAW OFFICES
_______________________________ C. Tom Arkoosh Attorney for Sorenson Engineering, Inc. and IdaHydro
SORENSON ENGINEERING, INC., AND IDAHYDRO’S SUPPLEMENTAL COMMENTS – Page 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 14th day of August 2023, I served a true and correct
copy of the foregoing document(s) upon the following person(s), in the manner indicated:
IDAHO PUBLIC UTILITIES COMMISSION: Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Building 8,
Suite 201-A (83714)
P.O. Box 83720 Boise, ID 83720-0074
____ _ X __
IDAHO POWER:
Megan Goicoechea Allen
Donovan Walker Idaho Power Company 1221 W. Idaho Street (83702) P.O. Box 70
Boise, ID 83707
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X___
U.S. Mail, Postage Prepaid
Overnight Courier Hand Delivered Via Facsimile E-mail:
U.S. Mail, Postage Prepaid
Overnight Courier Hand Delivered Via Facsimile E-mail:
____________________________________ C.Tom Arkoosh