20181129Petition to Intervene.pdf

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' I l't; Ii\, .-' ILIU: , l ,lssl0i.lNATALIE CAMACHO MENDOZA
INTERIM BOISE CITY ATTORNEY
ABIGAIL R. GERMAINE (ISB No. 9231)
Deputy City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: (208) 384-445 4
Email : [e-mail]
Attorney for Intervenor
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY TO STUDY THE
COSTS, BENEFITS, AND COMPENSATION
OF NET EXCESS ENERGY SUPPLIED BY
CUSTOMER ON-SITE GENERATION
BEFORE TIIE
IDAHO PUBLIC UTILITIES CONINIISSION
Case No. IPC-E- I 8- l5
CITY OF BOISE CITY'S
PETITION FOR LEAVE TO
INTERVENE
COMES NOW, the city of Boise City, herein referred to as "lntervenor," and pursuant to
Rules 7l through 73 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA
31.01.01 .71 -31.01.0.73) and, pursuant to that Petition filed on October 19,2018, and Notice of
Petition and Notice of lntervention Deadline, OrderNo. 34189, filed onNovember 9,z}l8,hereby
petitions the Commission for leave to intervene herein and to appear and participate as a party, and
as basis therefore states as follows:
1. The name and address of this lntervenor is:
City of Boise City
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE . I
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 Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
Telephone: [phone]
Facsimile: [phone]
Idaho State Bar No. 9231
Email:1Se.
3. The Intervenor, the city of Boise City, is a Municipal Corporation organized
under the laws of the state of Idaho.
4. The Intervenor 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, is invested in a thorough study of the
appropriate costs and benefits of excess solar generation. The Intervenor also has an interest in
ensuring on-site solar generation rates and programs are fair, just and equitable and encourage
more municipal governments and citizens to install and use solar panels, thereby reducing
pollution and furthering the Intervenor's progress in achieving its sustainability goals. The
Intervenor 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 fntervenor's broader
sustainability goals are a reflection of the comments and feedback received from the citizens of
Boise City in the course of the [nteryenor's various community engagement processes. The
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 2
Intervenor 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. 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 Intervenor would be without
any means of participation in this proceeding which may eventually have a material impact on the
rates that it and its citizens pay for electric service. If allowed to intervene, the Intervenor 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 Intervenor's petition to intervene will not unduly broaden the
issues, nor will it prejudice any party to this case.
7. Intervenor intends to fully participate in this matter as a party. The nature and
quality of the Intervenor's intervention in this proceeding is dependent upon the nature and effect
of other evidence in this proceeding. The Intervenor requests that the Commission issue a timely
order granting or denying this Petition for Leave to Intervene following the seven-day opposition
period set forth in IDAPA 3l.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 3 I -01.01. 161-165.
CITY OF BOISE CITY'S PETITION FOR LEAVE TO TNTERVENE - 3
WHEREFORE, the Intervenor, the city of Boise City, respectfully requests that this
Commission grant this Petition for Leave to Intervene.
DATED this 2 t day of November 2018.
City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 4
CERTIFICA OF SERVICE
Iherebycertifythatlhaveonthis ^2-t dayof November 2}ls,servedtheforegoing
documents on all parties of counsel as follows:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise, ID 83702
[e-mail]. gov
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
PO Box 70
Boise, ID 83707
Inordstrom@ iclahopou'er. com
dockets@ idahopow'cr.corn
Timothy E. Tatum
Connie Aschenbrenner
Idaho Por.ver Company
PO Box 70
Boise, ID 83707
tlatr-rm@ idahopou'er. com
caschenbrenner@ idahopon'er. com
C Tom Arkoosh
Attomey for IdaHydro
ARKOOSH LAW OFFICES
PO Box 2900
Boise, ID 83701
to m. arkoo shf(i arkoo sh. corn
eri n. cecil@ arkoosh. com
Benjamin J. Otto
Attomey for Idaho Conservation League
and Vote Solar
710 N.6th Street
Boise, ID 83701
btrtto? idalttrconscn rt iou.org
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CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE . 5
Eric L. Olsen
Attorney for Idaho Irrigation Pumpers
Assn., [nc.
Echo Hawk & Olsen, PLLC
505 Pershing Ave. Ste. 100
PO Box 6119
Pocatello, ID 83205
elo@echohau,'k.com
Yvonne R. Hogle
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
Yvo nne. ho gle4,pac i tl c,orp. coni
Tecl. v,'eston0 paci fi conl. co rl
David Bender
Attomey for Vote Solar
Earthjustice
3916 Nakoma Rd.
Madison, WI 5371I
dbender@ eart[i ustic.org
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City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 6