20240429Petition to Intervene.pdf

RECEIVED
Monday, April 29, 2024 3:39PM
IDAHO PUBLIC
UTILITIES COMMISSION
JAYME B. SULLIVAN
BOISE CITY ATTORNEY
Ed Jewell ISB No. 10446
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: BoiseCityAttomey(ic,,cityofboise.org
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER Case No. IPC-E-24-11
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2023 DEMAND-SIDE CITY OF BOISE CITY'S
MANAGEMENT EXPENSES AS PRUDENTLY PETITION TO INTERVENE
INCURRED
COMES NOW, the city of Boise City, herein referred to as "Boise City," and pursuant to
Rules 71 through 73 of the Rules of Procedure of the Idaho Public Utilities Commission(IDAPA
31.01.01.71 —31.01.0.73),the Application filed on March 15,2024, and the Notice of Application
and Intervention Deadline, Order No. 36145, hereby requests to intervene in this matter and to
appear and participate as a party. As grounds, Boise City states as follows:
1. The name and address of this Intervenor is:
City of Boise City
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
2. Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be sent to the following:
CITY OF BOISE CITY'S PETITION TO INTERVENE - 1

Ed Jewell Steven Hubble
Deputy City Attorney Climate Action Senior Manager
BOISE CITY ATTORNEY'S OFFICE BOISE CITY DEPT. OF PUBLIC WORKS
150 N. Capitol Blvd. 150 N. Capitol Blvd.
P.O. Box 500 P.O. Box 500
Boise, Idaho 83701-0500 Boise, Idaho 83701-0500
Telephone: [phone] Telephone: [phone]
Facsimile: [phone] Email: shubble&cityofboise.org
Email: BoiseCityAttorney&cityof6oise.org
eiewell&cityofboise.org
Pursuant to Order No. 35375, Commission Rules 61 and 62 are suspended and all service in this
docket, except for voluminous discovery-related documents, is to be completed electronically. If
the Commission decides to return to hard copy service during this docket,Boise City requests hard
copies of pleading, testimony, and briefs only. All other production requests, response, notices,
Commission orders and other filings may be served on Boise City via electronic mail in accordance
with Rule 63 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA
31.01.01.063).
3. Boise City is a Municipal Corporation organized under the laws of the state of
Idaho.
4. Boise City has a direct and substantial interest in representing its constituents, who
are customers of Idaho Power Company ("Idaho Power") and will be impacted by the decisions
made in this docket. Boise City is also a large Idaho Power customer with Schedule 7, 9, and 19
electric service accounts. Boise City also maintains multiple solar panel installations and net
metering facilities, such as those located at the Twenty Mile South Farm Administration and
Maintenance Building. Additionally, Boise City is an Idaho Power customer with expressed clean
energy preferences. This proceeding may impact Boise City's ability to meet its clean energy goals
through energy efficiency resources and demand-side flexibility. Without the opportunity to
CITY OF BOISE CITY'S PETITION TO INTERVENE - 2

intervene herein, Boise City would not have the direct means of ensuring the outcome of this
proceeding positively impacts the environmental, health, and economic concerns of Boise City
and its citizens. Granting Boise City's petition to intervene will not unduly broaden the issues,nor
will it prejudice any party to this case.
5. Boise City intends to fully participate in this matter as a party and appear in all
matters as is appropriate. The nature and quality of Boise City's intervention in this proceeding is
dependent upon the nature and effect of other evidence in this proceeding. If necessary, Boise City
may present evidence; call and examine witnesses; and present argument.
WHEREFORE, the city of Boise City, respectfully requests that this Commission
grant this Petition to Intervene and issue a timely order as set forth in IDAPA 31.01.01.075.
DATED this 29th day of April 2024.
E e ell,
Deputy City Attorney
CITY OF BOISE CITY'S PETITION TO INTERVENE - 3

CERTIFICATE OF SERVICE
I hereby certify that I have on this 29th day of April 2024, served the foregoing documents
on all parties of record as follows:
Monica Barrios-Sanchez ❑ U.S. Mail
Commission Secretary ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 W. Chinden Blvd., Ste. 201-A 0 Electronic
Boise, ID 83714 ❑ Other:
secretgakpuc.idaho._og_v
Adam Triplett ❑ U.S. Mail
Deputy Attorney General ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 W. Chinden Blvd., Ste. 201-A 0 Electronic
Boise, ID 83714 ❑ Other:
adam.triplettgpuc.idaho.gov
Megan Goicoechea Allen ❑ U.S. Mail
Lisa Nordstrom ❑ Personal Delivery
Idaho Power Company ❑ Facsimile
PO Box 70 Q Electronic
Boise, ID 83707 ❑ Other:
mgoicoecheaallen(a idahopower.com
Inordstrom&idahopower
docketsgidahopower.com
Connie Aschenbrenner ❑ U.S. Mail
Zack Thompson ❑ Personal Delivery
Idaho Power Company ❑ Facsimile
PO Box 70 0 Electronic
Boise, ID 83707 ❑ Other:
cas chenbrenner&idahopower.com
zthomp songidahopower.com
"V
Michelle Steel,
Paralegal
CITY OF BOISE CITY'S PETITION TO INTERVENE - 4