20250718Petition to Intervene.pdf

OFFICE OF THE CITY ATTORNEY City Attorney's Office ;208)612-8178
City Prosecution [phone]
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IDAHO FALLS
RECEIVED
July 18, 2025
July 18, 2025 IDAHO PUBLIC
UTILITIES COMMISSION
Via Email Only
Secretary Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, Idaho 83714
Email: [e-mail]
Re: Petition of the City of Idaho Falls, Idaho, to Intervene
Case No. GNR-E-25-02
Dear Secretary Barrios-Sanchez:
Please find attached the City of Idaho Falls's Petition to intervene in the above-referenced
proceeding. Please let me know if you have any questions regarding the attached filing.
Sincerely,
Michael A. Kirkham
City Attorney
City of Idaho Falls
Attachment
CC: Adam Triplett via email only
Page 1 of 1
P.O. Box 50220 1 375 D Street I Idaho Falls, Idaho 83405-0220

Michael A. Kirkham/ISB # 8939
CITY OF IDAHO FALLS, IDAHO
375 D. Street
Idaho Falls, ID 83401
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for City of Idaho Falls, Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION ) CASE NO. GNR-E-25-02
STAFF'S APPLICATION FOR )
APPROVAL OF A FILING PROCESS ) Petition of City of Idaho Falls, Idaho, to
FOR WIDLFIRE MITIGATION PLAN ) Intervene
COMES NOW,the City of Idaho Falls,Idaho,a municipal corporation of the State of Idaho
("Idaho Falls") by and through its attorney of record, Michael Kirkham, pursuant to the Idaho
Public Utilities Commission's ("Commission") Pursuant to the Idaho Public Utilities
Commission's("Commission")Rules of Procedure 53 and 71 through 73, submitting Idaho Falls's
petition to intervene, and to appear and participate as a party, in the above-captioned matter.
1. Name and Address of Petitioner
City of Idaho Falls, Idaho
140 S. Capital Avenue
Idaho Falls, ID 83402
2. Nature of Business
Idaho Falls is a municipal corporation of the State of Idaho. Idaho Falls is empowered by
the Idaho Constitution and the general laws of the State of Idaho, including Idaho Code §§ 50-301,
50-326-50-328 to operate an electric utility,known as Idaho Falls Power. Idaho Falls has operated
its municipal power utility since 1900. Idaho Falls owns and operates five (5) hydroelectric
generators in the Snake River. In addition to generating power,Idaho Falls also distributes electric
power to retail customers within the City's geographic boundaries, located within Bonneville
County, Idaho.
PETITION OF CITY OF IDAHO FALLS,IDAHO,TO INTERVENE PAGE 1 of 4

3. Names of Representatives
Stephen Boorman Michael A. Kirkham (ISB No. 8939)
Interim General Manager City Attorney
City of Idaho Falls,Idaho-Idaho Falls Power City of Idaho Falls Idaho
P.O. Box 50220 P.O. Box 50220
140 S. Capital Avenue 375 "D" Street
Idaho Falls, Idaho 83402 Idaho Falls, Idaho 83402
Phone: [phone] Phone: [phone]
Email: [e-mail] Email: [e-mail]
4. Idaho Falls's Interest in this Proceeding
In Commission Staff s application to initiate this proceeding, Commission Staff requests
"that the Commission issue an order establishing a filing process for Wildfire Mitigation Plans
("WMPs")that will be submitted for approval under the Wildfire Mitigation Standard of Care Act
("WSCA"), after it takes effect on July 1,2025."Staffs Application for a Wildfire Mitigation Plan
Filing Process ("Application") at 1. Commission Staffs "primary objective in this case is to
establish a regulatory process that each investor-owned utility ("IOU"), electric municipality and
cooperative utility can follow to comply with the new legislation."Id.
Idaho Falls is a municipal corporation of the State of Idaho that distributes electricity under
Idaho Code§ 50-342.Pursuant to the WSCA,municipal electrical distribution systems"may adopt
and file a wildfire mitigation plan with the commission for its review at any time permitted by the
commission."Idaho Code § 61-1803(2)(b). Idaho Falls anticipates filing a wildfire mitigation plan
with the Commission for its review and approval pursuant to the WSCA. See Application at 5
(Staff noting that electric municipalities may intend to file a WMP).
As noted by Commission Staff, electric municipalities, like Idaho Falls, are not regulated
by the Commission. As a consequence, Idaho Falls has a direct and substantial interest in this
proceeding to ensure that the Commission adheres to the limits permitted by the Legislature
WSCA and does not overreach in an attempt to regulate electric municipalities. To that end, Idaho
Falls intends to participate as a party in this proceeding. As necessary, Idaho Falls will introduce
evidence, cross-examine witnesses, call and examine witnesses, and be heard in argument.
Without the opportunity to intervene herein, Idaho Falls will not be able to participate in
the process to adopt the rules and standards imposed upon Idaho Falls, which may affect Idaho
Falls's timing for filing, the review, and approval of Idaho Falls's fire mitigation plan. Allowing
Idaho Falls to intervene will provide the Commission with valuable insight into electric
municipalities, and it will not unduly broaden the issues.
PETITION OF CITY OF IDAHO FALLS,IDAHO,TO INTERVENE PAGE 2 of 4

5. Conclusion
For the foregoing reasons, Idaho Falls respectfully requests that the Commission Grant Idaho
Falls's petition and allow Idaho Falls to intervene as a parry in the above-captioned proceeding.
Respectfully submitted this 18th day of July 2025.
THE CITY OF IDAHO FALLS, IDAHO
ls/Michael A. Kirkham
Michael A. Kirkham
City Attorney
PETITION OF CITY OF IDAHO FALLS,IDAHO,TO INTERVENE PAGE 3 of 4

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 18th day of July 2025, served a copy of the foregoing
Petition of City of Idaho Falls, Idaho, to Intervene upon the following by electronically providing
a copy thereof to:
Commission Staff:
Adam Triplett
Secretary Monica Barrios-Sanchez Deputy Attorney General
Commission Secretary Idaho Public Utilities Commission PO
Idaho Public Utilities Commission Box 83720
11331 W. Chinden Blvd.Building 8, Boise, ID 83702-0074
Suite 201-A Email: [e-mail]
Boise, ID 83714
Email: [e-mail]
Taylor Thomas
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83702-0074
Email: [e-mail]
lsl Michael A.Kirkham
Michael A. Kirkham
City Attorney
PETITION OF CITY OF IDAHO FALLS,IDAHO,TO INTERVENE PAGE 4 of 4