20181129Petition to Intervene.pdf

NATALIE CAMACHO MENDOZA
INTERIM BOISE CIry ATTORNEY
ABIGAIL R. GERMAINE (ISB No.923l)
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 : agermaine@ cityofboise.ore
Attorney for Intervenor
TN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY TO STUDY
FIXED COSTS OF PROVIDING ELECTRIC
SERVICE TO CUSTOMERS
RECEIVED
?flt8 r{0Y 29 AH B: 0?
CITY OF BOISE CITY'S
PETITION FOR LEAVE TO
INTERVENE
0hr
BEFORE THE
IDAHO PUBLIC UTILITIES CONII\IISSION
Case No. IPC-E-18-16
COMES NOW, the city of Boise City, herein referred to as "Interyenor," and pursuant to
Rules 7l through 73 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA
3 1 .01 .01 .7 | - 31 .01 .0.73) and, pursuant to that Petition filed on October 19, 2018, and Notice of
Petition and Notice of lntervention Deadline, Order No. 34 I 90, filed on November 9 ,2018, hereby
petitions the Commission for leave to intervene herein and to appear and participate as a party, and
as basis therefore states as follows:
l. The name and address of this Intervenor is:
City of Boise City
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
CITY OF BOISE'S PETITION FOR LEAVE TO INTERVENE - 1
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: aqenraine@ ci tl'ofboise.clrs
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 a customer with
numerous Boise City owned facilities served by Idaho Power and on behalf of all the citizens of
Boise City. The Intervenor has an interest in ensuring that fair, just, and equitable rates and charges
for electricity are established and encourage more municipal govemments and citizens to
efficiently use and conserve resources. The lntervenor has an interest in the economic health of
the area which is effected by the accurate and equitable determination and recovery of fixed costs
by Idaho Power. 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 will 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
CITY OF BOISE'S PETITION FOR LEAVE TO INTERVENE - 2
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 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 3 1-01.01. 161-165.
WHEREFORE, the Intervenor, the city of Boise City, respectfully requests that this
Commission grant this Petition for Leave to Intervene.
DArED this f t day of November 2018
Ab
ty Attomey
CITY OF BOISE'S PETITION FOR LEAVE TO TNTERVENE - 3
CERTIFICA OF SERVICE
I hereby certify that I have on this Xi day of November 2018, served the foregoing
documents on all parties of counsel as follows
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise, ID 83702
cl iane.holt@'puc. idaho. so \.'
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
PO Box 70
Boise, ID 83707
hqIlbt ro ni r/i i d aho p or\t!.qe r!
dockets@.idahopow'er.com
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
PO Box 70
Boise, ID 83707
ttatum@ idahopou'er.corn
c45chenbrenn er@ idahopelt€r. celt1
C Tom Arkoosh
Attorney for IdaHydro
ARKOOSH LAW OFFICES
PO Box 2900
Boise, ID 83701
torn. arkoosh[4 arkoosh. corn
eri n. cecil@.arkoosh.com
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CITY OF BOISE'S PETITION FOR LEAVE TO INTERVENE - 4
Benjamin J. Otto
Attorney for Idaho Conservation League
and NW Energy Coalition
710 N. 6th Street
Boise, ID 83701
h()tt(ra(_/ idah()c() nscl-i ati()lt.org
Eric L. Olsen
Attomey for Idaho Irrigation Pumpers
Assn., Inc.
Echo Hawk & Olsen, PLLC
505 Pershing Ave. Ste. 100
PO Box 6119
Pocatello, ID 83205
elo@echoha',vk.com
Yvonne R. Hogle
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
!p114 e.ho gl e6 pacifi cerp.!qu
Ted. w'eston@ pacifi corp. celn
David Bender
Attomey for Vote Solar
Earthjustice
3916 Nakoma Rd.
Madison, WI 5371I
db ender(ii earth-i usti c. org
David J. Meyer
Vice President & Chief Counsel of
Regulatory and Governmental Affairs
AVISTA CORPORATION
l4l I E. Mission Ave.
P.O.Box3727
Spokane, WA99220
David. mever@ avistacorp. com
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Gennaine
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CITY OF BOISE'S PETITION FOR LEAVE TO TNTERVENE - 5
City Attomey