20200807Petition to Intervene.pdf

JAYME B. SULLTVAN
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]
Attorneyfor Boise City
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO MODIFY SCHEDULE 84'S
METERING REQUIREMENT AND TO
GRANDFATHER EXISTING CUSTOMERS
WITH TWO METERS
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-20-26
CITY OF BOISE CITY'S
PETITION FOR LEAVE TO
INTERVENE
COMES NOW, the city of Boise City, herein referred to as o'Boise City" 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 Idaho Power Company's Application for Authority
to Modi8, Schedule 84's Metering Requirement and to Grandfather Existing Customers with Two
Meters, and Notice of Application filed on June 19,2020; and Notice of Intervention Deadline,
Order No. 34728, filed on July 17, 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:
l. The name and address of Boise City 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: aeermaine(dcityofboise.ore
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 it maintains multiple solar
panel installations and net metering facilities, such as those located at the Twenty Mile South Farm
Administration and Maintenance Building. Boise City also has an interest in ensuring on-site solar
generation program requirements are fair, just and equitable and encourage more municipal
governments and citizens to install and use solar panels, thereby reducing pollution and achieving
Boise City's energy goals. Boise City's broader clean energy goals are a reflection ofthe comments
and feedback received from the citizens of Boise City in the course of Boise Crty's various
community engagement processes. Boise City 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
existing and new 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 potentially affects environmental, health, and economic
concerns of Boise City and its citizens.
CITY OF BOISE CITY'S PETITION FOR LEAVE TO TNTERVENE - 2
5. Without the opportunity to intervene herein, Boise City would be without any means of
participation in this proceeding which may have a material impact on the net metering progftIm
and system payback analyses. 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 maffer 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 lntervene 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 3l-01.01.161-
165.
WHEREFORE, Boise City, respectfully requests that this Commission grant this
Petition for Leave to Intervene.
DATED this 7th day of August2020.
R. Germaine
City Attomey
CITY OF BOISE CITY'S PETITION FOR LEAVE TO TNTERVENE - 3
CERTIFICATE OF SERVICE
I hereby certii/ that I have on this 7th day of August 2020, served the foregoing
documents on all parties of counsel as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
I l33l West Chinden Boulevard
Building 8, Suite 201-A
PO Box 83720
Boise, ID 83720
i an.noriyuki(@puc.idaho. eov
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
PO Box 70
Boise,ID 83707
lnordstrom(@idahopower.com
[e-mail]
Connie Aschenbrenner
Timothy Tatum
Idaho Power Company
PO Box 70
Boise,ID 83707
caschenbrenner(n) idahopow er. com
ttatum (@ i dahopow er. com
Edward Jewell
Deputy Attomey General
Idaho Public Utilities Commission
I l33l West Chinden Boulevard
Building 8, Suite 201-A
PO Box 83720
Boise,ID 83720
edward.j ewell(rrpuc. idaho. sov
g U.S. Mailtr Personal DeliveryD Facsimileg Electronic Means w/ Consenttr Other:
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CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 4
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
Attorneys at Law
505 Pershing Avenue Suite 100
PO Box 6l 19
Pocatello, ID 83205
elo(ZDechohawk.com
Attorneys for ldaho lrrigation Pumpers
Association, Inc.
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, OH 44107
tony(a),yankel.net
for ldaho lruigation Pumpers Association,
Inc.
Kelsey Jae
Law for Conscious Leadership
920 North Clover Drive
Boise,ID 83703
kel s ey(a).kel seyj aenunez. com
Attorneysfor ldaho Sierra Club
Lisa Young
Mike Heckler
503 West Franklin Street
Boise, lD 83702
L i sa. )rouns(41 si eff acl ub. orq
Michael.p.heckler(4 gmail.com
For ldaho Sierra Club
Benjamin J. Otto
Idaho Conservation League
710 Nonh 6ft Street
Boise, ID 83702
botto(ca idahoconserv ation.ors,
Russell Schiermeier
29393 Davis Road
Bruneau, ID 83604
buvhavGdemail.oom
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R. Germaine
City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO TNTERVENE - 5