20260305Petition to Intervene.pdf

JAYME B. SULLIVAN RECEIVED
BOISE CITY ATTORNEY MARCH 5, 2026
IDAHO PUBLIC
Ed Jewell ISB No. 10446 UTILITIES COMMISSION
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: boisecityattorneygcityofboise.org
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER Case No. IPC-E-26-03
COMPANY'S APPLICATION FOR APPROVAL
OF THE 2032 ALL-SOURCE REQUEST FOR CITY OF BOISE CITY'S
PROPOSALS TO MEET CAPACITY PETITION TO INTERVENE
RESOURCE NEEDS IN AS EARLY AS 2031
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 February 20,2026,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
2. Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be sent to the following:
CITY OF BOISE CITY'S PETITION TO INTERVENE - 1

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: [phone] Telephone: [phone]
Facsimile: (208) 38404454 Email: koneil&cityofboise.org
Email: boisecityattomey(a,,cityofboise.org
ei ewell(kcityofboise.org
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
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. 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.
CITY OF BOISE CITY'S PETITION TO INTERVENE - 2

DATED this 5th day of March 2026.
� C (
Ed Jewell,
Deputy City ttorney
CITY OF BOISE CITY'S PETITION TO INTERVENE - 3

CERTIFICATE OF SERVICE
I hereby certify that I have on this 5th day of March 2026, 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 Q Electronic
Boise, ID 83714 ❑ Other:
secretgakpuc.idaho._og_v
Eric Olsen ❑ U.S. Mail
ECHO HAWK& OLSEN, PLLC ❑ Personal Delivery
505 Pershing Ave, Ste 100 ❑ Facsimile
PO Box 6119 Q Electronic
Pocatello, ID 83205 ❑ Other:
elo(&,echohawk.com
Donovan Walker ❑ U.S. Mail
Idaho Power Company ❑ Personal Delivery
PO Box 70 ❑ Facsimile
Boise, ID 83707 0 Electronic
dwalker&,idahopower.com ❑ Other:
dockets&idahopower.com
Connie Aschenbrenner ❑ U.S. Mail
Zack Thompson ❑ Personal Delivery
Idaho Power Company ❑ Facsimile
PO Box 70 Q Electronic
Boise, ID 83707 ❑ Other:
caschenbrenner(d),idahopower.com
zthomp s on&idahop ower.c om
Gregory M. Adams (ISB No. 7454) ❑ U.S. Mail
515 N. 27th Street Boise, Idaho 83702 ❑ Personal Delivery
Telephone: [phone] ❑ Facsimile
Fax: ( 208) 938- 7904 Q Electronic
-re richardsonadams.com ❑ Other:
CITY OF BOISE CITY'S PETITION TO INTERVENE - 4

Trion Sanger(ISB No. 12488) ❑ U.S. Mail
Sanger Greene, PC ❑ Personal Delivery
4031 SE Hawthorne Blvd. Portland, OR 97214 ❑ Facsimile
Telephone: ( 503) 756- 7533 R Electronic
Fax: ( 503) 334- 2235 ❑ Other:
Trion san er-law.com
Michelle Steel,
Paralegal
CITY OF BOISE CITY'S PETITION TO INTERVENE - 5