20231117Petition 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
COMPANY’S APPLICATION FOR APPROVAL OF THE CAPACITY DEFICIENCY PERIOD TO BE UTILIZED FOR AVOIDED COST CALCULATIONS
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Case No. IPC-E-23-27 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
Friday, November 17, 2023 1:19:28 PM
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. 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 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 17th day of November 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 17th day of November 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 __
rier -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
_____ _ X __
urier
acsimile -mail:
IDAHO POWER:
Donovan E. Walker Megan Goicoechea Allen Idaho Power Company 1221 W. Idaho Street (83702) P.O. Box 70
Boise, ID 83707
_____ __
X___
S. Mail, Postage Prepaid ourier ered simile -mail:
@idahopower.com [e-mail]
Energy Contracts 1221 W. Idaho Street (83702) P.O. Box 70 Boise, ID 83707
______
____________ _ X __
acsimile -mail:
____________________________________