20210713Petition to Intervene.pdf

JAYME B. SULLIVAN
BOISE CITY ATTORNEY
Ed Jewell ISB No. (10446)
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: BoiseCitv
ei [e-mail]
Attorney for Intervenor
.,_ i3 Pi.i L:51
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-21-17IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES FOR
ELECTRIC SERVICE TO RECOVER COSTS
ASSOCIATED WITH THE JIM BRIDGER
POWER PLANT
CITY OF BOISE CITY'S
PETITION 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), the Application filed on June 3, 2021, and Notice of Application and
Notice of Intervention Deadline, Order No. 35088, filed on J:une24,202l, hereby requests leave
to intervene in this matter and to appear and participate as aparty. As grounds, Boise City 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 CITY'S PETITION TO INTERVENE - I
2. Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Ed Jewell at:
Ed Jewell
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 BarNo. 10446
Email: [e-mail]
ej ewel I @ ci tlzo fboi se. ore
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 Sched:ule 7,9, 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 will substantively impact
electric service rates. Without the opportunity to intervene herein, Boise City would not have the
direct means of ensuring the outcome of this proceeding positively impacts the environmental,
health, and economic concems of Boise City and its citizens. Granting Boise City's petition to
interuene will not unduly broaden the issues, nor will it prejudice any party to this case.
CITY OF BOISE CITY'S PETITION TO INTERVENE - 2
5. Boise City intends to fully participate in this matter as a party and appear in all
matters as is appropriate. The naturc and quality of Boise City's intervention in this proceeding is
dependent upon the nature and effect ofother evidence in this proceeding. If necessary, Boise City
may present evidence; call and examine witnesses; and present argument.
WHEREFORE, the city of Boise City, respectfully requests that this Commission
grant this Petition to Intervene and issue a timely order as set forth in IDAPA 3 1.01.01.075.
DATED this t3F-dayofJuly 2021.
a*,a(
Ba iew#-J
Depury City Attomey
CITY OF BOISE CITY'S PETTTION TO INTERVENE . 3
CERTIFICATE OF SERVICE.
I here,by certiff that I have on this l$:day of July z}zl,served the foregoing documents
on all parties of record as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Ste.20l-A
Boise,lD 83714
ian.noriyuki@puc. idalro. gov
Eric Shaner
Deputy Attomey General
Idatro Public Utilities Commission
I l33l W. Chinden Blvd., Ste. 201-A
Boise,ID 83714
eric. sh aner(0nu c. i d aho. ro v
Lisa Nordstrom
Matt Larkin
Idalp Power Company
PO Box 70
Boise,ID 83707
I nords trorn@.i-datropowcr.com
ml arki [e-mail]
[e-mail]
Peter Richardson
Industrial Customers of ldaho Power
Richardson Adams, PLLC
PO Box 7218
Boise ID,83702
peter(Orichardsonadam.s.corn
Benjamin Otto
Idaho Conservation League
710 N. 6e St.
Boiss [D83702
botto@id ahoconservation.orB
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other:
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other:
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Ed Jewell
Deputy CityAttomey
CITY OF BOISE CITY'S PETITION TO INTERVENE.4
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