20210611Petition to Intervene.pdf

JAYME B. SULLIVAN
BOISE CITY ATTORNEY
MARY GRANT (ISB No. 8744)
Deputy City Attomey
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
.1",, .ri,ir i I Pli i2: 0i
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-21-12IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION ACKNOWLEDGING ITS
NORTH VALMY POWER PLANT EXIT DATE
CITY OF BOISE CITY'S
PETITION FOR LEAVE TO
INTER\TENE
COMES NOW, the city of Boise City, herein referred to as o'Boise Cit5r," 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 April 30,2021, and Notice of Application and
Notice of Intervention Deadline, Order No. 35051, filed on N,{;ay 21,2021, hereby requests leave
to intervene in this matter and to appear and participate as a party. As grounds, Boise City states
as follows:
l. 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 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]
Idatro State Bar No. 8744
Email: [e-mail]
boiseci tyofboise.org
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 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 representing the
public interest of Idaho Power Company ("Idaho Power") customers that make up its constituency.
Boise City is also a large Idaho Power customer with Schedule7,9, and 19 electric service
accounts. As an Idaho Power customer with expressed clean energy preferences, this proceeding
directly impacts Boise City's access to a clean energy resource mix and has the potential to impact
electric service rates. While Boise City is actively engaged in Idaho Power's 2021 Integrated
Resource Plan Advisory Council, Boise City's participation herein, if granted, will address the
process, analysis, and proposal presented in the Application, recognizing the inherent connection
between the two proceedings. Without the opportunity to intervene herein, Boise City would not
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 2
have the direct means of ensuring the outcome of this proceeding positively impacts the
environmental, health, and economic concerns of Boise City and its citizens. Granting Boise City's
petition to intervene will not unduly broaden the issues, nor will it prejudice any party to this case.
5. 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. Ifnecessary, Boise City
may present evide,nce; 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 matter pursuant to IDAPA 3l-01.01.161-165.
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 1oth day ofJune 2021.
Mary Grant
Deputy City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE. 3
CERTIFICATE OF SERVICE
I hereby certifr that I have on this 1lth day of June 2021, served the foregoing documents
on all parties of counsel as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,ID 83702
ian.noriyuki idaho.sov
tr U.S. Mailtr Personal Deliverytr FacsimileX Electronic Means w/ Consenttr Other:
Lisa Nordstrom
Idaho Power Company
PO Box 70
Boise,ID 83707
lnordstrom@idahopower. oom
dockets@idahopower. corn
tr U.S. Mailtr Personal Deliverytr FacsimileX Electronic Means w/ Consenttr Other:
Matt Larkin
Idaho Power Company
PO Box 70
Boise, lD 83707
mlarkin@i dahopower. corn
tr U.S. Mailtr Personal Deliverytr Facsimile
X Electronic Means w/ Consenttr Other:
Peter Richardson
Industrial Customers of Idaho Power
Richardson Adams, PLLC
PO Box 7218
Boise LD,83702
peter@.richardsonadams. com
tr U.S. Mailtr Personal Deliverytr FacsimileX Electronic Means w/ ConsentD Other:
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dread i n s(@,rni nd spri n g. corn
tr U.S. Mailtr Personal DeliveryD FacsimileX Electronic Means w/ Consenttr Other:
Benjamin Otto
Idaho Conservation League
710 N. 6e St.
Boise, ID 83702
conservation
tr U.S. Mailtr Personal Deliverytr FacsimileX Electronic Means w/ Consenttr Other:
Mary Grant, Deputy City attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 4