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Home My WebLink About20250611Petition to Intervene.pdf RECEIVED June 11, 2025 JAYME B. SULLIVAN IDAHO PUBLIC BOISE CITY ATTORNEY UTILITIES COMMISSION 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 ei ewellgcityofboise.org Attorney for Intervenor BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF Case No. IPC-E-25-16 IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS RATES AND CITY OF BOISE CITY'S CHARGES FOR ELECTRIC SERVICE IN THE PETITION TO INTERVENE STATE OF IDAHO AND AUTHORITY TO IMPLEMENT CERTAIN MEASURES TO MITIGATE THE IMPACT OF REGULATORY LAG 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)and the Application filed on May 30,2025,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 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) 384-4454 Email: koneilgcityofboise.org Email: BoiseCityAttorneygcityofboise.org ei ewell(c�r�,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 1 Ith day of June 2025. EcQdvell, 1-1 Deputy City Attorney CITY OF BOISE CITY'S PETITION TO INTERVENE - 3 CERTIFICATE OF SERVICE I hereby certify that I have on this 1 Ith day of June 2025, served the foregoing documents on all parties of record as follows: Commission Secretary ❑ U.S. Mail Idaho Public Utilities Commission ❑ Personal Delivery 11331 W. Chinden Blvd., Ste. 201-A ❑ Facsimile Boise, ID 83714 Q Electronic secretar ]2uc.idaho.gov ❑ Other: Donovan Walker ❑ U.S. Mail Megan Goicoechea Allen ❑ Personal Delivery Idaho Power Company ❑ Facsimile PO Box 70 Q Electronic Boise, ID 83707 ❑ Other: dwalkergidahopower.com mgoicoecheaallen(d),idahopower.com dockets gidahopower.com Timothy Tatum ❑ U.S. Mail Connie Aschenbrenner ❑ Personal Delivery Matt Larkin ❑ Facsimile Idaho Power Company Q Electronic 1221 West Idaho Street (83702) ❑ Other: Boise, ID 83707 ttatumgidahopower.com caschenbrenner(aidahopower.com mlarkin(kidahopower.com Kelsey Jae ❑ U.S. Mail Law for Conscious Leadership ❑ Personal Delivery 920 N. Clover Drive ❑ Facsimile Boise, ID 83703 Q Electronic kelsey(kkelseyjae.com ❑ Other: Courtney White ❑ U.S. Mail Mike Heckler ❑ Personal Delivery Clean Energy Opportunities for Idaho ❑ Facsimile 3778 Plantation River Drive, Suite 102 ✓Q Electronic Boise, ID 83703 ❑ Other: courtney(kcl eanenergyoppportunities.com mikegcleanenergyyopportunities.com CITY OF BOISE CITY'S PETITION TO INTERVENE - 4 Eric L. Olsen ❑ U.S. Mail Echo Hawk& Olsen, PLLC ❑ Personal Delivery 505 Pershing Avenue, Suite 100 ❑ Facsimile PO Box 6119 Q Electronic Pocatello, ID 83205 ❑ Other: elo(d),,echohawk.com Lance Kaufman, Ph.D. ❑ U.S. Mail 2623 NW Bluebell Place ❑ Personal Delivery Corvallis, OR 97330 ❑ Facsimile lance&ae isg insi hg t.com Q Electronic ❑ Other: Michelle Steel, Paralegal CITY OF BOISE CITY'S PETITION TO INTERVENE - 5