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Home My WebLink About20240712Petition to Intervene.pdf RECEIVED Thursday, July 12, 2024 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: (208) 608-7950 Facsimile: (208) 384-4454 Email: BoiseCityAttomey(ic,,cityofboise.org Attorney for Intervenor BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF Case No. IPC-E-24-07 IDAHO POWER COMPANY TO INCREASE RATES FOR ELECTRIC SERVICE TO CITY OF BOISE CITY'S RECOVER COSTS ASSOCIATED WITH PETITION TO INTERVENE INCREMENTAL CAPITAL INVESTMENTS AND CERTAIN ONGOING OPERATIONS AND MAINTENANCE EXPENSES 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 May 31, 2024, and the Notice of Application, Suspension of Proposed Effective Date and Intervention Deadline, Order No. 36238, 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: (208) 608-7950 Telephone: (208) 608-7521 Facsimile: (208) 38404454 Email: shubblekcityofboise.org Email: BoiseCityAttomey(a cityofboise.org ei ewell&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 CITY OF BOISE CITY'S PETITION TO INTERVENE - 2 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 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 parry 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 I Ith day of July 2024. � t Ed J e , Deputy City Attorney CITY OF BOISE CITY'S PETITION TO INTERVENE - 3 CERTIFICATE OF SERVICE I hereby certify that I have on this 1 lth day of July 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 Chris Burdin ❑ 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: chris.burdingpuc.idaho.gov Lisa D. Nordstrom ❑ U.S. Mail Donovan E. Walker ❑ Personal Delivery Megan Goicoechea Allen ❑ Facsimile Idaho Power Company Q Electronic PO Box 70 ❑ Other: Boise, ID 83707 lnordstrom&idahopower.com dwalker(d),idahopower.com m goicoecheaallen&idahopower.com docketsgidahopower.com Timothy Tatum ❑ U.S. Mail Connie Aschenbrenner ❑ Personal Delivery Matt Larkin ❑ Facsimile Idaho Power Company Q Electronic PO Box 70 ❑ Other: Boise, ID 83707 ttatum(k idahopower.com caschenbrennergidahopower.com mlarkin&idahopower.com Matthew Nykiel, Attorney ❑ U.S. Mail Brad Heusinkveld, Regulatory Counsel ❑ Personal Delivery Idaho Conservation League ❑ Facsimile 710 N. 61h St. 0 Electronic Boise, ID 83702 ❑ Other: matthew.n. k elkgmail.com bhesusinkveldkidahoconservation.org CITY OF BOISE CITY'S PETITION TO INTERVENE - 4 Industrial Customers of Idaho Power ❑ U.S. Mail c/o Peter J. Richardson ❑ Personal Delivery Richardson Adams, PLLC ❑ Facsimile 515 N. 271h St. Q Electronic P.O. Box 7218 ❑ Other: Boise, ID 83702 peter&richardsonadams.com Dr. Don Reading ❑ U.S. Mail 280 S. Silverwood Way ❑ Personal Delivery Eagle, ID 83616 ❑ Facsimile dreadin mindsprin_.cgom 0 Electronic ❑ Other: Idaho Irrigation Pumpers Association, Inc. ❑ U.S. Mail c/o Eric L. Olsen ❑ Personal Delivery ECHO HAWK& OLSON, PLLC ❑ Facsimile 505 Pershing Avenue, Suite 100 0 Electronic Pocatello, ID 83205 ❑ Other: elo(a,echohawk.com Lance Kaufman, Ph.D. ❑ U.S. Mail 2623 NW Bluebell Place ❑ Personal Delivery Corvallis, OR 97330 ❑ Facsimile lance(q,ae_is�_h� 0 Electronic ❑ Other: Michelle Steel, Paralegal CITY OF BOISE CITY'S PETITION TO INTERVENE - 5