20230629Petition to Intervene.pdf

IDAHYDRO’S PETITION TO INTERVENE – 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 IdaHydro BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC SERVICE IN THE STATE OF IDAHO AND FOR ASSOCIATED REGULATORY ACCOUNTING TREATMENT
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Case No. IPC-E-23-11 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 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 therefor states as follows:
1. The name and address of the intervenor is:
IdaHydro c/o C. Tom Arkoosh Arkoosh Law Offices 913 W. River Street, Suite 450
P.O. Box 2900 Boise, ID 83701 Telephone: [phone] Facsimile: [phone] Email: [e-mail] 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.

RECEIVED
2023 JUNE 20, 2023 11:39AM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHYDRO’S PETITION TO INTERVENE – Page 2
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
34 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. Therefore,
IdaHydro claims a direct and substantial interest in this proceeding in that the prices it receives
for electrical sales and the 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, call and examine witnesses, cross-examine witnesses, and be heard in argument. The
nature and quality of evidence that this Intervenor will introduce are 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 the 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.
DATED this 20th day of June 2023.
ARKOOSH LAW OFFICES
_______________________________ C. Tom Arkoosh Attorney for IdaHydro
IDAHYDRO’S PETITION TO INTERVENE – Page 3
CERTIFICATE OF MAILING I HEREBY CERTIFY that on the 20th day of June 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: Jan Noriyuki Commission Secretary Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8,
Suite 201-A (83714) P.O. Box 83720 Boise, ID 83720-0074
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rier -mail:
[e-mail]
[e-mail]
IDAHO PUBLIC UTILITIES COMMISSION STAFF: Chris Burdin Deputy Attorney General Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8,
Suite 201-A (83714) P.O. Box 83720 Boise, ID 83720-0074
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urier acsimile -mail:

IDAHO POWER: Lisa D. Nordstrom Donovan E. Walker Megan Goicoechea Allen Timothy Tatum
Connie Aschenbrenner Matt Larkin Idaho Power Company 1221 W. Idaho Street (83702) P.O. Box 70
Boise, ID 83707
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S. Mail, Postage Prepaid ourier ered simile
-mail: ower.com @idahopower.com power.com
[e-mail] [e-mail]
IDAHYDRO’S PETITION TO INTERVENE – Page 4
CLEAN ENERGY OPPORTUNITIES FOR IDAHO: Kelsey Jae
Law for Conscious Leadership 920 N. Clover Dr. Boise, ID 83703
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acsimile -mail: [e-mail]
Courtney White Clean Energy Opportunities for Idaho 3778 Plantation River Dr., Ste. 102 Boise, ID 83703
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Courier acsimile -mail: opportunities.com
opportunities.com
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.: Eric L. Olsen
ECHO HAWK & OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, ID 83205
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acsimile -mail: [e-mail]
Lance Kaufman, Ph.D.2623 NW Bluebell Place Corvallis, OR 97330 _____
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d Delivered acsimile
-mail: [e-mail]
INDUSTRIAL CUSTOMERS OF IDAHO POWER: Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St. (83702) P.O. Box 7218 Boise, ID 83707
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Courier
acsimile
-mail: [e-mail]
280 Silverwood Way Eagle, ID 83616 _____
elivered acsimile
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