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Home My WebLink About20250505Petition to Intervene.pdf RECEIVED May 05, 2025 JAYME B. SULLIVAN IDAHO PUBLIC BOISE CITY ATTORNEY UTILITIES COMMISSION Jessica Harrison ISB No. 9768 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( ,cityof6oise.org Attorney for Intervenor BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER Case No. IPC-E-25-15 COMPANY'S APPLICATION FOR ITS FIRST ANNUAL UPDATE TO THE EXPORT CREDIT CITY OF BOISE CITY'S RATE FOR NON-LEGACY ON-SITE PETITION TO INTERVENE GENERATION CUSTOMERS FROM JUNE I, 2025 THROUGH MAY 31, 2026, IN COMPLIANCE WITH ORDER NO. 36048 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 1, 2025, and the Notice of Application, Order No. 36558, 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 - I 2. Copies of all pleadings, production requests, production responses, Commission orders and other documents should be sent to the following: Jessica Harrison Katie O'Neil Deputy City Attorney Energy Program 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) 608-7571 Facsimile: (208) 38404454 Email: koneil&cityofboise.org Email: BoiseCityAttomey(ic,,cityofboise.org jharrison&cityof boise.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 Idaho Power Company ("Idaho Power Company") customers that make up its constituency. Boise City is also a large commercial Idaho Power customer with a diversity of electricity accounts. As a customer with expressed clean energy preferences and community-wide energy efficiency targets, this proceeding directly impacts Boise City's ability to meet its energy use reduction goals. Without the opportunity to intervene herein, Boise City would not have the CITY OF BOISE CITY'S PETITION TO INTERVENE - 2 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 5th day of May 2025. J sica Harrison Deputy City Attorney CITY OF BOISE CITY'S PETITION TO INTERVENE - 3 CERTIFICATE OF SERVICE I hereby certify that I have on this 5th day of May 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: secretga&puc.Idaho.gov Erika K. Melanson ❑ 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: Erika.melanson&puc.Idaho.gov Megan Goicoechea Allen ❑ U.S. Mail Donovan Walker ❑ Personal Delivery Connie Aschenbrenner ❑ Facsimile Mary Alice Taylor 0 Electronic Regulatory Dockets ❑ Other: Idaho Power Company 1221 West Idaho Street(83702) PO Box 70 Boise, ID 83707 mgoicoeacheaallen(k idahopower.com dwalkerA idahopower.com caschenbrenner(a,idahopower.com mtaylor(d)lidahopower.com dockets(kidahopower.com Kevin Dickey ❑ U.S. Mail PO Box 337 ❑ Personal Delivery Emmett, ID 83617 ❑ Facsimile BellefourcheOI&gmail.com 0 Electronic ❑ Other: Courtney White ❑ U.S. Mail Mike Heckler ❑ Personal Delivery Clean Energy Opportunities for Idaho ("CEO") ❑ Facsimile 3778 Plantation River Drive, Ste 102 0 Electronic Boise, ID 83703 ❑ Other: Courtney(a),cleanenergyopportunities.com mike&cleanenerg_yoPportunities.com CITY OF BOISE CITY'S PETITION TO INTERVENE - 4 Kelsey Jae ❑ U.S. Mail 920 N Clover Drive ❑ Personal Delivery Boise, ID 83703 ❑ Facsimile kelsey(a,kelseyjae.com 0 Electronic ❑ Other: Rose Monahan ❑ U.S. Mail Sierra Club ❑ Personal Delivery 2101 Webster Street, Ste 1300 ❑ Facsimile Oakland, CA 94612 0 Electronic rose.monahan(&,,sierraclub.org ❑ Other: Kate Bowman ❑ U.S. Mail Vote Solar ❑ Personal Delivery 299 S Main Street ❑ Facsimile Suite 1300, PMB 93601 Q Electronic Salt Lake City, UT 84111 ❑ Other: kbowman(avotesolar.org 4�4 zi-ud Michelle Steel, Paralegal CITY OF BOISE CITY'S PETITION TO INTERVENE - 5