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Home My WebLink About20201119Petition to Intervene.pdfC. 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: (208)343-5105 Facsimile: (208) 343-545G Email: tom.arkoosh@arkoosh.com amber. dressl ar@arkoosh.com Admin copy: erin.ceci l@arkoosh.com J fi., "-: r\i it {it ir3l.{-= r_ i a *e :i;ii littj t3 *H Il: s9 :,.r *t*lii,ill-, , : ,-.:-,l..lit:;SiSiJ Attorneys for ldaHydro and the Renewable Energt coalition BEFORE TIIE IDAHO PT'BLIC UTILITIES COMMISSION IN THE MATTER OF ROCKY MOI.INTAIN POWER' S APPLICATION FOR APPROVAL OF A CAPACITY DEFICIENCY PERIOD TO BE USED FOR AVOIDED COST CALCULATIONS CASE NO. PAC.E.2O.Is RENEWABLE ENERGY COALITION'S PETITION TO INTERVEI\IE Pursuant to the Idaho Public Utilities Commission's ("Commission,,) Rules of Procedure, Rule 7l IDAPA 31.01.01 .71-073, the Renewable Energy Coalition ("Coalition") hereby petitions the Commission to intervene and appear with full party stafus, and as grounds therefore states as follows: l. The name and address of Coalition is: Renewable Energy Coalition c/o John Lowe PO Box 25576 Portland, OR9729B Telephone: (503) 997 - 3033 E-Mail : jravenesanmarcos@yahoo.com 2. Arkoosh Law Offices will represent Coalition in this proceeding. AII documents relating to these proceedings should be served on the following persons at the addresses listed below: RENEWABLE ENERGY COALITION'S PETITION TO INTERVENE PAC-E-2O-13 PAGE I OF 4 John Lowe Renewable Energy Coalition PO Box 25576 Portland, OR 97298 Telephone: (503) 997- 3033 i ravenesanmarcos@Yahoo.com lrion Sanger Sanger Law, PC 1041 SE 58th Pl Portland, OR 97215 Telephone: (503) 7 56-7 533 Fax: (503) 334-2235 irion@sanger-law.com C. Tom Arkoosh Amber Dresslar Arkoosh Law Offices 802 West Bannock St., Suite LP 103 P.O. Box 2900 Boise,ID 83701 Telephone: (208) 343-5 I 05 Fax: (208) 343-5456 tom.arkoosh@arkoosh.com amber.dresslar@arkoosh. com erin.cecil@arkoosh.com 3. The Coalition was established in 2009 and is comprised of nearly forty members who own and operate over fifty qualiffing facilities ("QFs") or are attempting to develop new projects in oregon, Idaho, washington, utah, Montana, and wyoming. The coalition has participated in numerous state regulatory proceedings intended to promote appropriate interconnection procedures, competitive markets, PURPA, renewable energy, diversity of generation ownership, and proceedings regarding QF contract and rate eligibility. 4. The Coalition has a substantial interest in this proceeding because a Commission decision on this matter will impact Rocky Mountain Power's avoided cost rates for QFs that sell power under the public Utility Regulatory Policies Act ("PURPA"). The Coalition's members are eFs that have (or intend to have) power purchase agreements ("PPAs") with Idaho utilities with rates based on its avoided costs. The Coalition's members sell power to Avista, Portland General Electric, Idaho Power, and PacifiCorp in Oregon, Idaho, Washington, Wyoming, and/or Utah, including Rocky Mountain power in Idaho. Most of the Coalition's members have existing RENEWABLE ENERGY COALITION'S PETITION TO INTERVENE PAC-E-20-13 PAGE 2 OF 4 projects that have been operating and selling to utilities for numerous years; however, many Coalition members are attempting to construct new renewable energy projects. Without intervention, the Coalition would not have the ability to participate in the proceeding, which could result in material harm to its members. 5. The Coalition's intervention will assist the Commission in resolving the issues and will not unreasonably broaden the issues, burden the record, or delay this proceeding. Finally, the Coalition's interest is not adequately represented by any other party in this proceeding. WHEREFORE, the Coalition respectfully requests that the Commission grant its petition to intervene with full party status in this proceeding and to appear and participate in all matters as may be necessary and appropriate; and to present evidence, call and examine witnesses, cross- examine witnesses, present argument, and to otherwise fully participate in the proceedings. DATED this lfth day of November 2020. ARKOOSH LAW OFFICES C. Tom Arkoosh Attorneysfor ldaHydro and the Renewable Energt Coalition RENEWABLE ENERGY COALITION'S PETITION TO INTERVENE PAC-E-20-13 PAGE 3 OF 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the lgth day of November 2020,I served a true and correct copy of the foregoing document(s) upon the following person(s), in the manner indicated: _ U.S. Mail, Postage Prepaid _ Overnight Courier Hand Delivered Via Facsimile ln-mail ian.norivuki@puc.idaho. gov secretary@puc. idaho. eov Jan Noriyuki Commission Secretary Idaho Public Utilities Commission 472W. Washington Boise, lD 83702 Ted Weston Emily Wegener 1407 West North Temple, Suite 330 Salt Lake City, UT 84116 Attorneysfor Rocky Mountain Power Ron Scheirer 825 NE Multnomah, Suite 600 Portland, OR97232 Attorneys for Rocky Mountain Power John Lowe Renewable Energy Coalition PO Box 25576 Portland, OR 97298 Irion Sanger Sanger Law, PC l04l sE 58th Pl Portland, OR 97215 _ U.S. Mail, Postage PrePaid _ Overnight Courier Hand Delivered Via Facsimile L E-mail ted.weston@paci fi corP.com emi ly.we gener@pacifi corP.com _ U.S. Mail, Postage PrePaid _ Ovemight Courier _ Hand Delivered _ Via Facsimile LE-mail ron. scheirer@paci fi corP.com _ U.S. Mail, Postage Prepaid _ Overnight Courier Hand Delivered Via Facsimile x P-mail i ravenesanmarcos@yahoo.com _ U.S. Mail, Postage PrePaid _ Overnight Courier _ Hand Delivered _ Via Facsimile LE-mail irion@sanser-law.com C. Tom Arkoosh RENEWABLE ENERGY COALITION'S PETITION TO INTERVENE PAC-E-20-13 PAGE 4 OF 4