20240522Petition to Intervene.pdf

RECEIVED
2024 May 22, 10:41 AM
IDAHO PUBLIC
QJAYME B. SULLIVAN UTILITIES COMMISSION
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
ei ewellgcityofboise.org
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER Case No. IPC-E-24-18
COMPANY'S APPLICATION FOR APPROVAL
OF A CLEAN ENERGY YOUR WAY CITY OF BOISE CITY'S
CONSTRUCTION AGREEMENT WITH THE PETITION TO INTERVENE
CITY OF BOISE AND THE FIRST
AMENDMENT THERETO
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 April 23, 2024, and the Notice of Application
and Intervention Deadline, Order No. 36170, 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
CITY OF BOISE CITY'S PETITION TO INTERVENE - 1

2. Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be sent to the following:
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: (208) 38404454 Email: shubblegcityofboise.org
Email: [e-mail]
ei ewell(kcityofboise.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 this docket as the participating
customer in the proposed Clean Energy Your Way Construction Agreement with Idaho Power.
Additionally, Boise City is a large Idaho Power customer with Schedule 7, 9, and 19 electric
service accounts with expressed clean energy preferences. This proceeding will impact Boise
City's ability to meet its clean energy goals through voluntary clean energy procurement. Granting
CITY OF BOISE CITY'S PETITION TO INTERVENE - 2

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 22nd day of May 2024.
ENe tw- 1,
Deputy City Attorney
CITY OF BOISE CITY'S PETITION TO INTERVENE - 3

CERTIFICATE OF SERVICE
I hereby certify that I have on this 22nd day of May 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
Donovan Walker ❑ U.S. Mail
Idaho Power Company ❑ Personal Delivery
PO Box 70 ❑ Facsimile
Boise, ID 83707 Q Electronic
dwalker&idahopower.com ❑ Other:
dockets(&,idahopower.com
Tim Tatum ❑ U.S. Mail
Alison Williams ❑ Personal Delivery
Idaho Power Company ❑ Facsimile
PO Box 70 0 Electronic
Boise, ID 83707 ❑ Other:
ttatum(k idahopower.com
awilliams&idahopower.com
Michelle Steel,
Paralegal
CITY OF BOISE CITY'S PETITION TO INTERVENE - 4