20210430Petition to Intervene.pdf

JAYME B. SULLIVAN
BOISE CITY ATTORNEY
MARY GRANT (ISB No. 8744)
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]
Boi seCit)rAttorney@cit)ro fboi se.ore
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-21-04IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2O2O DEMAND-SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURRED
CITY OF BOISE CITY'S
PETITION FOR LEAVE TO
INTER\rENE
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), the Application filed on March 15,2021, and Notice of Application and
Notice of Intervention Deadline, Order No. 34986, filed on April 6,2021, hereby requests leave
to intervene in this matter and to appear and participate as a party. As grounds, Boise City states
as follows:
1. The name and address of this lntervenor is:
City of Boise City
150 N. Capitol Blvd.
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - I
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 Mary Grant at:
Mary Grant
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. 8744
Email : mrqrant@cit),ofboi se. ore
[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, response, 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 3 1.01.01.063).
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 representing the
public interest of Idaho Power Company ("Idaho Power") customers that make up its constituency.
Boise City has established aggressive energy goals, including increasing customer participation in
demand side managernent and energy efficiency progftrms, as part of Boise City's community-
wide aspiration of 100% clean electricity by 2035. Ensuring demand side management programs
are prudent, innovative, and abundant is critical to Boise City meeting its goals. The pursuit of all
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 2
cost-effective demand side management progftrms includes a review of efficacy and prudency of
the current efforts, as well as the development of new programs, in partnership with the utility
provider. The outcome of this proceeding impacts the environmental, health, ffid economic
concerns of Boise City and its citizens.
Without the opportunity to intervene herein, Boise City would not have the direct means
of ensuring that demand side management programing offered by Idaho Power is guided in a
manner such that the impact is positive.
5. Granting Boise City's petition to intervene will not unduly broaden the issues, nor
will it prejudice any party to this case.
6. Boise City intends to fully participate in this matter as a party and appear in all
matters as is appropriate. 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. If necessary, Boise City
may present evidence; call and examine witnesses; and present argument. Boise City also reserves
its right to file for intervenor funding, depending upon the amount of time and resources involved
in this matterpursuant to IDAPA 3l-01.01.161-165.
7. Boise City asks that the Commission grant this Petition for Leave to Intervene, not
timely filed under Order No. 34986 entered April 6, 2021, which directed the deadline for
intervention to be 2l days from the date of such order, for the following reasons:
a. The Commission's Rule of Procedure 73, TDAPA 31.01.01 .072,provides that
petitions to intervene shall be filed at least fourteen (14) days before the date
set for hearing or prehearing, unless otherwise provided by notice or order. As
no such hearing has been set, the Petitioner and any other intervenors are not
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 3
prejudiced by the two-day delay in filing and there is no disruption in
proceedings.
b. The City has good cause for the negligible delay, the reason being staff
attrition, transitions in position roles and responsibilities, and onboarding of
new mernbers.
WHEREFORE, the city of Boise City, respectfully requests that this Commission grant
this Petition for Leave to Intervene and issue a timely order as set forth in IDAPA 31.01.01.075.
DATED this 29th day of April202l.
Mary Grant
Deputy City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 4
CERTIFICATE OF SERYICE
I hereby certiff that I have on this 29thday of April 2021, served the foregoing documents
on all parties of counsel as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise, lD 83702
i [e-mail]. eov
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
PO Box 70
Boise, ID 83707
lnordstrom@,idahopower. com
dockets@idahopower. com
Connie Aschenbrenner
Idaho Power Company
PO Box 70
Boise,ID 83707
caschenbrenner@idahopower. com
Adam Lowney
McDowell Rackner Gibson PC
419 SW 1lth Ave., Suite 400
Portland, OR 97205
[e-mail]
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
tr U.S. MailO Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
O U.S. MailD Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
tr U.S. Mailtr Personal DeliveryO Facsimileg Electronic Means w/ Consenttr Other:
Mary Grant
Deputy City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 5