20200423Petition to Intervene.pdf

JAYME B. SULLIVAN 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: [phone]
Facsimile: [phone] Email: [e-mail]
Attorney for Intervenor
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
DETERMINATION OF 2019 DEMAND-SIDE MANAGEMENT EXPENSES AS PRUDENTLY INCURRED
CITY OF BOISE CITY’S PETITION FOR LEAVE TO INTERVENE
COMES NOW, the city of Boise City, herein referred to as “Boise City” and pursuant to
Rules 71 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 Application filed on March 13, 2020, and Notice
of Application and Notice of Intervention Deadline, Order No. 34620, filed on April 6, 2020,
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 Intervenor is:
City of Boise City 150 N. Capitol Blvd. P.O. Box 500
CITY OF BOISE CITY’S PETITION FOR LEAVE TO INTERVENE - 1
RECEIVED
2020 April 23,PM12:35
IDAHO PUBLIC
UTILITIES COMMISSION
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 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: [e-mail]
In the interest of reducing costs to all parties, please provide hard copies of pleading, testimony,
and briefs only. All other production requests, responses, notices, Commission orders, and other
filings may be submitted via electronic mail in accordance with Rule 63 of the Rules of Procedure
of the Idaho Public Utility Commission (IDAPA 31.01.01.063).
3.Boise City is a Municipal Corporation organized under the laws of the state of
Idaho.
4.Boise City has a direct and substantial interest in this matter as Boise City has a
strong interest in promoting demand-side management throughout the community. Boise City has
established aggressive energy goals, including demand-side management goals as part of Boise
City’s community-wide goal of 100% clean electricity by 2035. Specifically, Boise City
committed to increasing customer participation in efficiency and demand-side management
programs beginning in 2019 and achieving an annual electricity use reduction of approximately
2% by 2030 and beyond. Ensuring demand-side management programs are prudent, innovative,
CITY OF BOISE CITY’S PETITION FOR LEAVE TO INTERVENE - 2
and abundant is critical to Boise City meeting its goals. Therefore, Boise City encourages the
pursuit of any and all cost-effective demand-side management programs, including the
development of new programs. The outcome of this proceeding potentially affects environmental,
health, and economic concerns of Boise City and its citizens.
5. Without the opportunity to intervene herein, Boise City would be without any
means of participation in this proceeding, which may have a negative impact on demand-side
management programing offered by Idaho Power Company (“IPC”). If allowed to intervene, Boise
City 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 Boise City’s petition to intervene will not unduly broaden the issues, nor
will it prejudice any party to this case.
7. Boise City intends to fully participate in this matter as a party. The nature and
quality of Boise City’s intervention in this proceeding is dependent upon the nature and effect of
other evidence in this proceeding. Boise City 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. Boise City also reserves its right to file for intervenor funding,
depending upon the amount of time and resources involved in this matter pursuant to IDAPA 31-
01.01.161-165.
CITY OF BOISE CITY’S PETITION FOR LEAVE TO INTERVENE - 3
WHEREFORE, the city of Boise City, respectfully requests that this Commission grant
this Petition for Leave to Intervene.
DATED this day of April 2020.
______________________________ Abigail R. Germaine Deputy City Attorney
CITY OF BOISE CITY’S PETITION FOR LEAVE TO INTERVENE - 4
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CERTIFICATE OF SERVICE
I hereby certify that I have on this _____ day of April 2020, served the foregoing documents on all parties of counsel as follows:
Commission Secretary Idaho Public Utilities Commission 11331 West Chinden Boulevard
Building 8, Suite 201-A
PO Box 83720 Boise, ID 83714 [e-mail]

Personal Delivery
Facsimile
Electronic Means w/ Consent
Other: __________________
Regulatory Dockets Idaho Power Company PO Box 70 Boise, ID 83707
[e-mail]
[e-mail]

Personal Delivery
Facsimile
Electronic Means w/ Consent
Other: __________________
Idaho Power Company
PO Box 70
Boise, ID 83707 [e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent
Other: __________________
ECHO HAWK & OLSEN, PLLC
Attorneys at Law 505 Pershing Avenue Suite 100 PO Box 6119 Pocatello, ID 83205
[e-mail]
Attorneys for Idaho Irrigation Pumpers
Association, Inc.
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent
Other: __________________
12700 Lake Avenue, Unit 2505
Lakewood, OH 44107 [e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent

CITY OF BOISE CITY’S PETITION FOR LEAVE TO INTERVENE - 5
23rd
for Idaho Irrigation Pumpers Association,
Inc.
Peter J. Richardson
RICHARDSON ADAMS, PLLC
Attorneys at Law 515 North 27th Street PO Box 7218 Boise, ID 83702
[e-mail]
Attorneys for Industrial Customers of
Idaho Power
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent
Other: __________________
6070 Hill Road
Boise, ID 83703 [e-mail] for Industrial Customers of Idaho Power
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent

______________________________ Abigail R. Germaine
Deputy City Attorney
CITY OF BOISE CITY’S PETITION FOR LEAVE TO INTERVENE - 6