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Home My WebLink About20170906Petition to Intervene.pdfBOISE CITY ATTORNEY'S OFFICE MAYOR: David H. Bieter I BOISE CITY ATTORNEY Robert Luce i':t-i': Ir/f-n: ! -.!.1-.-l t LUt'Y" 5 Fl'i L: 30 Idaho Public Utilities Commission 472 W . Washington Street Boise, ID 83702 September 6,2017 RE: Case No. IPC-E-17-1,3Idaho Power New Schedules For Customers With On-Site Generation Dear Commissioners: Please find enclosed the original and seven copies of the City of Boise's Petition to Intervene regarding Idaho Power's proposed new schedules for customers with on-site generation, case number IPC-E-17-13. If there are any questions regarding the enclosed documents, please contact Abigail Germaine at (208) 608-7956 or via email at eger:'::aineiir citlotboisc.org. Sincerely Abigail Deputy Attorney BOISE CITY I{ALL: r5o N. Capitol Boulevard I MAIL' p,O. Box 5oo, Boise, ldaho 837o1-o5oo I P: 208-608-7950 | F: 2o8-584-44s4 I TDDIITY:80<:-577-3529 BOISE CITY COUNCIL, Elaine Clegg (President), Lauren McLean (President Pro Tem), Maryanne Jordan, Scot Luclwig, Ben Quintana, TJ Thomson CITYOFBOISE.ORG A*^ ROBERT B. LUCE BOISE CITY ATTORNEY ABIGAIL R. GERMAINE (ISB No. 9231) Deputy City Attorney BOISE CITY ATTORNEY'S OFFICE 150 N. Capitol Blvd. P.O. Box 500 Boise, ID 83701-0500 Telephone: (208) 384-3870 Facsimile: (208) 384-4454 Email : aeermaine@,cityofboise.org Attorneys for Petitioner IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATON FOR AUTHORITY TO ESTABLISH NEW SCHEDULES FOR RESIDENTIAL AND SMALL GENERAL SERVICE CUSTOMERS WITH ON-SITE GENERATION BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case No. IPC-E-17-13 CITY OF BOISE CITY PETITION TO INTERVENE COMES NOW, the city of Boise City, hereinafter referred to as "Petitioner," and pursuant to this Commission's Rules of Procedure, Rule 71 IDAPA 3101.01 .71 and, pursuant to that Application filed on July 27,2077 , and Notice of Application and Notice of Intervention Deadline, Order No. 33843, filed on August 17,2017, 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: 1. The name and address of this Petitioner 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 provided to Abigail R. Germaine at: Abigail R. Germaine Deputy City Attomey BOTSE CITY ATTORNEY'S OFFICE 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701 -0500 Telephone: (208) 608-7950 Facsimile: (208) 384-445 4 Idaho State Bar No. 9231 Email : agermaine(4citlzofboise.org 3. The Petitioner, the city of Boise City, is a Municipal Corporation organized under the laws of the state of Idaho. 4. The Petitioner has a direct and substantial interest in this matter as it maintains solar panel installations, such as those located at the Twenty Mile South Farm Administration and Maintenance Building, which are net metered and, therefore) are potentially affected by these proposed changes. The Petitioner also has an interest in protecting against any potential negative effects the proposed changes will have in discouraging more municipal goverlments and citizens to install and use solar panels, thereby reducing pollution and furthering the Petitioner's progress in achieving its sustainability goals. The Petitioner has set specific energy use and carbon reduction goals for internal operations based on detailed baselining of current energy use and the implementation of energy efficiency measures in combination with increased installation of renewable energy. The Petitioner's broader sustainability goals are a direct reflection of the comments received from the citizens of Boise City in the course of the Petitioner's regular citizen survey. The Petitioner has an interest in the economic health of the area which in the future could be dependent on the ability to provide affordable renewable energy to more and more companies who are setting 100% Renewable Energy goals. In addition, considering the abundant natural resources such as geothermal heat and solar access in Boise City, 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 home and building improvements made by the Petitioner and Boise City residents less productive. The outcome of this proceeding affects environmental, health, and economic concerns of Boise City and its citizens. 5. Without the opportunity to intervene herein, the Petitioner 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. If allowed to intervene, the Petitioner will participate in the proceedings and appear in all matters as may be necessary and appropriate; present evidence; call and examine witnesses; present argument; and otherwise fully participate in these proceedings. 6. Granting the Petitioner's petition to intervene will not unduly broaden the issues, nor will it prejudice any party to this case. 7. Petitioner intends to fully participate in this matter as a party. The nature and quality of the Petitioner's intervention in this proceeding is dependent upon the nature and effect of other evidence in this proceeding. The Petitioner requests that the Commission issue a timely order granting or denying this Petition following the seven-day opposition period set forth in IDAPA 31.01.01.075. The Petitioner also reserves its right to file for intervenor funding, depending upon the amount of time and resources involved in this matter pursuant to IDAPA 3l - 01.01.161-165. WHEREFORE, the Petitioner, the city of Boise City, respectfully requests that this Commission grant this Petition to Intervene. DATED this day of September 2017 . Germaine Attomey ( 4- CERTIFICATE OF SERVICE I hereby certify that I have on this 4-6-Ll, day of September,2017, served the foregoing documents on all parties of counsel as follows: Lisa Nordstrom Regulatory Dockets Idaho Power Company PO Box 70 Boise, ID 83707 I nordstrorn (9, i daho po wer. com dockets@i dahopower. com Timothy E. Tatum Connie Aschenbrenner Idaho Power Company PO Box 70 Boise, lD 83707 ttatum @) i d ahopo wer. com caschenbrenner(rD,idahopower. corll Diane Hanian Commission Secretary Idaho Public Utilities Commission 472West Washington Boise, ID 83702 di ane.hol t((Dpuc. id aho. gov Idahydro c/o C Tom Arkoosh Arkoosh Law Offices PO Box 2900 Boise, tD 83701 !o qr. arkoo sh (at arkoo sh. qom U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: tr U.S. Mailtr Personal Delivery E, Facsimile { Electronic Means w/ Consenttr Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: tr tr tr-Atr trr/a tr tr tr tr tr_Atr erin.cecil @tarkoosh. com Matthew A. Nykiel Idaho Conservation League PO Box 2308 102 S. Etclid#207 Sandpoint, ID 83864 rnnykiel@idahoconservation.ore tr o tr U.S. Mail Personal Delivery Facsimile F Electronic Means w/ Consent tr Other Idaho Irrigation Pumpers Association, Inc. c/o Eric L. Olsen Echo Hawk & Olsen, PLLC 505 Pershing Ave. Ste. 100 PO Box 6119 Pocatello, ID 83205 elo@echohawk.com tr tr tr { U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other:tr Anthony Yankel 12700 Lake Avenue, Unit 2505 Lakewood, OH 44107 tonlz@),ankel.net tr U.S. Mailtr Personal Delivery tr . Facsimile { Electronic Means w/ Consenttr Other: Elias Bishop Auric Solar, LLC 2310 S. 1300 W. West Valley City, UT 84119 el ias. b i sho p(rJ,)auri csolar. corn tr tr tr U.S. Mail Personal Delivery tr Electronic Means w/ Consent Other: