20081210Petition to Intervene.pdf

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Davis F. VanderVelde, ISB #7314
Mattew A. Johnson, ISB #7789
WHITE PETERSON GIGRA Y ROSSMAN NYE & NICHOLS, P .A.
5700 Eat Frain Road, Suite 200
Nampa, Idao 83687
Offce: [phone]
Fax: [phone]
mjohnson~whitepeteron.com
Attorneys for Intervenor: City of Nampa
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF TH APPLICATION OF )
IDAHO POWER COMPAN FOR AUTHORITY )
TO MODIFY ITS RULE H LIN EXTESION )
TARF RELATED TO NEW SERVICE )
ATTACHMNTS AN DISTRUTION LINE )INSTALLATIONS )
)
CASE NO. IPC-E-08-22
PETITION TO INTERVENE
The CITY OF NAMA hereby petitions to intervene in the above-captioned matter
pursuat to Idaho Public Utilities Commssion Rules of Proceure (IDAPA 31.01.01.000 et seq)
and the Commission's November 26, 2008 Notice of Application and Notice of Intervention
Deadline.
I. In support of this Petition, the City of Nampa alleges as follows:
1. The City of Nampa is duly orgaze as a muncipal corpration of the State of Idaho
under Idao Code Title 50.
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2. The City of Nampa own, govern, and controls public roadways and nght-of-ways
within the City limts. Under Chapter 3 of Title 50 of the Idao Code, the City of Nampa is
empowered to supervse, reguate, create, widen, improve, and otherwse control and direct such
public roadways.
3. The City of Nampa ha a dit and substatial interest in the above captioned matter.
Nampa's responsibilties for its roadways include maitenace and improvements tht requie
relocation of Idao Power facilties so tht such facilties do not interfere with trsporttion and
public safety. Idao Power's Application seeks to chage the relocation rues so tht the costs of
such relocation would be borne by the City and loca improvement distrcts organ by the
City. The City of Nampa is substtially intereste in makg sur tht relocation cost are not
unaily impose on the City. Additionaly the City ha a diect interest in makg surelS\ch rue
chages do not contrvene the frchise ageement between the City and Idao Power. The City
also has an interest in makg sure that such rue changes do not contrvene Idao sttutes and
cas law.
4. Intervention by the City of Nampa will not unduly broaden the issues in ths matter.
The City's concern relate pnmly to the proposed chages regarding the defition of thd-
par beneficianes, the treatment of local improvement distrcts, and alloction of reloction
costs. The City does not seek to introduce additiona issues or matters beyond those aleady
included in the propose rue chage.
5. Interention by the City of Nampa is in the public interes. The City ha comments
and concern related to the public inteest in trffc and roadways.
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6. Intervention by the City of Nampa will not cause delay or prejudice to the pares in
the above-captioned matter. The City of Nampa seeks to tiely intervene at an early ste in
ths matter and with foureen (14) days of the servce date of PUC Order No. 30687.
7. Intervention by the City of Nampa is appropnate to allow the City of Nampa to
appropnately express cert concern, objections, and protest in relation to the Application in
ths mattr.
8. The City of Nampa wishes to maita goo relations with Idao Power and believes
that status as an intervenor will allow for clearer communcations about concern and issues.
Date ths 10th day of December, 2008.
WHTE PETERSONBY:~~
Mattew A. Joil
Attorneys for the City of Nampa
CERTIFICATE OF SERVICE
I, the undersigned, hereby certfy that on the 10th day of December, 2008, a tre and
correc copy of the above and foregoing insent was served upon the followig by the
method indicated below:
Michael Fuss
City of Nampa
411 - 3rd Street South
Nam a, il 83651
Lisa D. Nordstom
Barn L. Kline
IDAHO POWER COMPAN
P.O.Box70
Boise, il 83707
X U.S. Mail
Overnght Mail-
_ Hand Delivery
Facsimle:
-Ã U.S. Mail
Overght Mail
Hand Delivery
Facsimle:
jaI:\ Wor\Nama\lda Powe - Rule H change\Nampa - lP Rul H Change.pet to inrvene.fi.do
PETITION TO INRVENE - 3