20130129Petition to Intervene.pdf

CARY B. COLAIANNI
BOISE CITY ATTORNEY
R. STEPHEN RUTHERFORD
Chief 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: BoiseCityAttorneycityofboise.org
Idaho State Bar No. 5410
?81JA429 PM 2:0 1,
1D;H
UTL1flES OOMMtS.
Attorney for City of Boise
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO MODIFY ITS NET
METERING SERVICE AND TO
INCREASE THE GENERATION
CAPACITY LIMIT.
Case No. IPC-E-12-27 ORIGINAL
CITY OF BOISE'S PETITION TO
INTERVENE
COMES NOW, the City of Boise City, Idaho (the "City") and hereby requests leave to
intervene in the above-captioned matter pursuant to Idaho Public Utilities Commission Rules of
Procedure, IDAPA 31.01.01.071-073. The City has direct and substantial interest in this matter,
as set forth further below, and therefore should be allowed to intervene.
1. The name and address of this Intervenor is:
R. Stephen Rutherford
City of Boise City, Idaho
P.O. Box 500
Boise, ID 83701-0500
Ph: [phone]
Fax: [phone]
BoiseCityAttorney(cityothoise.org
Please provide copies of all pleadings, production requests, production responses, Commission
orders, and other documents in this matter to the name and address above. In the interest of the
CITY OF BOISE'S PETITION TO INTERVENE - 1
conservation of natural resources and reducing costs to all parties, please provide hard copies
only of pleadings, briefs and testimony. Production requests, production responses, notices,
Commission orders and other filings may be submitted by electronic mail in accordance with
IDAPA 31.01.01.063.02-03.
2.The City has a direct and substantial interest in this matter as it maintains solar
panel installations, with its installation at the City's Foothills Learning Center being net metered
and, therefore, likely affected by the proposed change in the tariff. The City is also concerned
about the negative effects the proposed change will have in encouraging more citizens to install
and use solar panels, thereby reducing pollution and reducing the City's progress in achieving its
sustainability goals. The City's sustainability goals are a direct reflection of the comments
received from the citizens of Boise in the course of the City's regular citizen survey. The City
has an interest in the economic health of the area. Considering the abundant natural resources
such as geothermal heat and solar access in Boise, the renewable energy industry has the
possibility of being a strong component of a diverse local economy. However, the changes
proposed in this matter could have a swift, deleterious effect on the solar installation industry,
and render feckless home and business improvements made by City residents.
3.The City has a direct and substantial interest in the outcome of this matter and
intends to fully participate in its proceedings. Being a participant in the net metering program,
and being concerned about the effect this matter may have on the City's environment, and the
investment residents of the City have made in their homes, the City will likely conduct
discovery, and advocate for technical hearings to be held in the matter, and likely participate in
any settlement negotiations that may occur. The City requests that the Commission issue a timely
order granting or denying this Petition following the seven-day opposition period set forth in
CITY OF BOISE'S PETITION TO INTERVENE -2
IDAPA 31.01.01.075. The City also reserves its right to file for intervenor funding, depending
on the amount of time and resources involved in this matter pursuant to IDAPA 31.01.01-161 -
165.
WHEREFORE, the City respectfully requests the Commission grant this petition.
DATED this day of January 2013.
R* 'STEPHEN RUTIERFORD
Cief Deputy City 4ttorney
CITY OF BOISE'S PETITION TO INTERVENE -3
CERTIFICATE OF SERVICE
I hereby certify that I have on this day of January 2013, served the foregoing
document on all parties of record in this proceeding, as follows:
Jean Jewell U U.S. Mail
Commission Secretary El Personal Delivery
Idaho Public Utilities Commission U Facsimile [phone]
427 W. Washington St. U Electronic Mail
Boise, ID 83702-5983 U Other:
Original & 7 Copies
Lisa D. Nordstrom U U.S. Mail
Julia A. Hilton U Personal Delivery
Idaho Power Company U Facsimile [phone]
1221 W. Idaho Street El Electronic Mail
P.O. Box 70 U Other:
Boise, ID 83707
Attorneys for Idaho Power
Benjamin J. Otto U U.S. Mail
Attorney at Law U Personal Delivery
710 N. 6th Street U Facsimile [phone]
Boise, ID 83701 El Electronic Mail
Attorney for Idaho Conservation League U Other:
Chris Aepelbacher U U.S. Mail
PowerWorks LLC U Personal Delivery
5420 W. Wicher Rd. U Facsimile
Glenns Ferry, ID 83623 El Electronic Mail
Peter J. Richardson
RICHARDSON & O'LEARY
Attorneys at Law
515 N. 27' Street
P.O. Box 7218
Boise, ID 83702
Attorney for Pioneer Power, LLC
U Other:
U U.S.Mail
U Personal Delivery
U Facsimile [phone]
El Electronic Mail
U Other:
R. STEPHEN
Chief Deputy Attorney
CITY OF BOISE'S PETITION TO INTERVENE -4