20201116Petition to Intervene.pdf

C. Tom Arkoosh,ISB No.2253
Amber Dresslar, ISB No. 10536
ARKOOSH LAW OFFICES
802 W. Bannock Street, Suite LP 103
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
amber.dresslar@arkoosh. com
Admin copy: [e-mail]
Attorneys for IdaHydro
IN THE MATTER OF ROCKY
MOUNTAIN POWER FOR APPROVAL OF
A CAPACITY DEFICIENCY PERIOD TO
BE USED FOR AVOIDED COST
CALCULATIONS
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BEFORE THE IDAHO PUBLIC UTILITIES COMIVtrSSION
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Case No. PAC-E-20-13
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 Offrces, 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
clo C. Tom Arkoosh
Amber Dresslar
Arkoosh Law Offices
802 W. Bannock Street, Suite LP 103
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
amber.dressl ar@arkoosh. com
With an email copy to: [e-mail]
IDAHYDRO'S PETITION TO INTERVENE - Page I
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 ldaho small hydroelectric
producers joined in a trust for mutual benefit, consisting of approximately 100 MW of capacity
produced by small hydroelectric plants. Some of its members' plants currently sell electric
power and energy to PacifiCorp ("the Company") 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 costs it pays to the
Company 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 or via
comments. The nature and quality of evidence which this lntervenor 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 with limited
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 the Company.
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 16ft day of November 2020. ARKOOSH LAW OFFICES
c==.)
C. Tom Arkoosh
Attorney for IdaHydro
IDAHYDRO'S PETITION TO INTERVENE - Page 2
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the l6s day of November, I served a true and correct copy
of the foregoing document(s) upon the following person(s), in the manner indicated:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702 x
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail
i an.noriyuki@puc. idaho. eov
secretary@nuc. idaho. gov
Ted Weston
Emily Wegener
1407 West North Temple, Suite 330
salt Lake city, uT 841l6
Attorneysfor Rocly Mountain Power x
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail
ted.weston@paci fi corp.com
emi Iy.we gener@pacifi com.com
Ron Scheirer
825 NE Multnomah, Suite 600
Portland, OR97232
Attorneysfor RoclE Mountain Power
x
U.S. Mail, Postage Prepaid
Overnight Courier
Hand Delivered
Via Facsimile
E-mail
ron. schei rer@pac i fi corp.com
C. Tom Arkoosh
IDAHYDRO'S PETITION TO INTERVENE - page 3