20250221Petition to Intervene.pdf

RECEIVED
Friday, February 21, 2025
IDAHO PUBLIC
JAYME B. SULLIVAN UTILITIES COMMISSION
BOISE CITY ATTORNEY
Ed Jewell ISB No. 10446
Jessica Harrison ISB No. 9768
Deputy City Attorneys
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: BoiseCityAttorneykcityofboise.org
ei ewell(de,cityofboise.org
jharrison&cityofboise.org
Attorneys for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS Case No. INT-G-24-05
COMPANY'S APPLICATION FOR
DETERMINATION OF 2023 ENERGY CITY OF BOISE CITY'S
EFFICIENCY 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 December 20, 2024, and the Notice of
Application and Notice of Intervention Deadline, Order No. 36455, 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 Katie O'Neil
Jessica Harrison Energy Program Manager
Deputy City Attorneys BOISE CITY DEPT. OF PUBLIC WORKS
BOISE CITY ATTORNEY'S OFFICE 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] Email: koneil&cityofboise.org
Facsimile: [phone]
Email: BoiseCityAttorney(kcityofboise.org
ei ewell(&,cityofboise.org
jharrison(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 matter as representing the
public interest of Intermountain Gas Company ("Intermountain Gas") customers that make up its
constituency. Boise City is also a large commercial Intermountain Gas customer with a diversity
of natural gas service accounts. As a customer with expressed clean energy preferences and
community-wide energy efficiency targets,this proceeding directly impacts Boise City's ability to
CITY OF BOISE CITY'S PETITION TO INTERVENE - 2

meet its energy use reduction goals.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 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 21 st day of February 2025.
v� t
Ed Je ell
Deputy ' y Attorney
CITY OF BOISE CITY'S PETITION TO INTERVENE - 3

CERTIFICATE OF SERVICE
I hereby certify that I have on this 21 st day of February 2025, 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
Dayn Hardie ❑ 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:
dayn.hardie(kpuc.Idaho.gov
Lori A. Blattner ❑ U.S. Mail
Director—Regulatory Affairs ❑ Personal Delivery
Intermountain Gas Company ❑ Facsimile
PO Box 7608 Q Electronic
Boise, ID 83707 ❑ Other:
lori.blattner(&,,int ag s.com
igcre ug latory(kint ag_s.com
Preston N. Carter ❑ U.S. Mail
Givens Pursley LLP ❑ Personal Delivery
601 W. Bannock St. ❑ Facsimile
Boise, ID 83702 Q Electronic
prestoncarter&givenspursley.com ❑ Other:
morgan og odinAgivenspursley.com
stephaniew&givenspursle.
Michelle Steel,
Paralegal
CITY OF BOISE CITY'S PETITION TO INTERVENE - 4