20160728Petition to Intervene.pdf

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ROBERT B. LUCE
BOISE CITY ATTORNEY
ELIZ ABETH A. KOECKERITZ
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile : (208)3 84 -445 4
Idaho State Bar No. 7670
Email : [e-mail]
Attorneys for Intervenor
IN THE MATTER'OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF NEW TARIFF SCHEDULE
63, A COMMUNITY SOLAR PILOT
PROGRAM
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-16-14
PETITION TO INTERVENE OF THE
CITY OF BOISE CITY
COMES NOW, the City of Boise City, hereinafter referred to as "Intervenor," and pursuant
to this Commission's Rules of Procedure, Rule 71 IDAPA 3101.01 .71 atd, pursuant to that Notice
of Application and Notice of Intervention Deadline issued by the Commission on July 7,2016, in
Order No. 33552, hereby petitions the Commission for leave to intervene herein and to appear and
participate herein as a party, and as grounds therefore states as follows:
l. The name and address of this lntervenor is:
City of Boise City
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
PETITION TO INTERVENE OF THE CITY OF BOISE CITY. 1
ORIGINAL
2. Copies of all pleadings, production requests, production responses, Commission
orders and other documents should be provided to Elizabeth A. Koeckeritz at:
Elizabeth A. Koeckeritz
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: (208\384-4454
Idaho State Bar No. 7670
Email : [e-mail]
3. This lntervenor, the City of Boise City, is a Municipal Corporation organized
under the laws of the state of ldaho.
4. Without the opportunity to intervene herein, this Intervenor would be without any
means of participation in this proceeding which may have a material impact on the rates that it
and its citizens pay for electric service. This outcome of this proceeding affects the
environmental, health and economic concerns of the city of Boise City and its citizens.
5. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case. As a substantial reason for the delay in the filing of
the Petition to lntervene, Intervenor submits that Intervenor's counsel has been out-of-town and
unable to be reached.
6. Intervenor intends to full participate in this matter as a party. The nature and
quality of the city of Boise City's intervention in this proceeding is dependent upon the nature
and effect of other evidence in this proceeding. If necessary, Intervenor may introduce evidence,
be heard in argument, and call, examine and cross-examine witnesses.
JAMIAHO
PETITION TO INTERVENE OF THE CITY OF BOISE CITY - 2
WHEREFORE, the city of Boise City respectfully requests that this Commission
grant its Petition to lntervene in these proceedings and to appear and participate in all matters as
may be necessary and appropriate; and to present evidence, call and examine witnesses, present
argument and to otherwise fully participate in these proceedings.
DArED *, &^rofJuly 2016.
CERTIFICATE OF SERVICE
I hereby certiff that I have on this '4 day of July 2Il6,served the foregoing
document on all parties of counsel as follows:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
1221 West Idaho St.
Boise,ID 83707-0070
I nordstrom @i dahopower. com
dockets@idahooower. com
Matt Larkin
Peter Pengilly
Idaho Power Company
l22l West Idaho Street (83702)
Boise,ID 83707-0070
mlarkin@idahopower. com
ppeneilly@idahopwer. com
A. Koeckeritz
City Attomey
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PETITION TO INTERVENE OF THE CITY OF BOISE CITY - 3
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, lD 83702
botto@idahoconservation. org
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise, ID 83702
[e-mail]. sov
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PETITION TO INTERVENE OF THE CITY OF BOISE CITY - 4