20220217Petition 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: [e-mail]
[e-mail]
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY’S APPLICATION TO PROCEED WITH RESOURCE PROCUREMENTS TO
MEET IDENTIFIED CAPACITY
DEFICIENCIES IN 2023, 2024, AND 2025 TO ENSURE ADEQUATE, RELIABLE, AND FAIR-PRICED SERVICE TO ITS CUSTOMERS
Case No. IPC-E-21-41
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 December 3, 2021, and the Notice of
Intervention Deadline, Order No. 35314, 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 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 - 1
RECEIVED
2022 FEB 17 PM4:22
IDAHO PUBLIC
UTILITIES COMMISSION
2. Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be sent to the following:

Deputy City Attorney
BOISE CITY ATTORNEY’S OFFICE
150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 Telephone: [phone]
Facsimile: [phone]
Email: [e-mail] [e-mail]
Energy Program Manager
BOISE CITY DEPT. OF PUBLIC
WORKS 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500
Telephone: [phone]
Email: [e-mail]
In compliance with Order No. 35058, all service in this docket is to be completed electronically.
If the Commission decides to return to hard copy service during this docket, Boise City requests
hard copies of pleading, testimony, and briefs only. All other production requests, response,
notices, Commission orders and other filings may be served on Boise City 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 Schedule 7, 9, and 19 electric service
accounts. Boise City also maintains multiple solar panel installations and net metering facilities,
such as those located at the Twenty Mile South Farm Administration and Maintenance Building.
As an Idaho Power customer with expressed clean energy preferences, this proceeding directly
impacts Boise City’s ability to meet its community clean energy goals with new utility-scale
CITY OF BOISE CITY’S PETITION TO INTERVENE - 2
renewable resources procured by the Company. 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 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. 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 31.01.01.075.
DATED this 17th day of February 2022.
______________________________
Ed Jewell,
Deputy City Attorney
CITY OF BOISE CITY’S PETITION TO INTERVENE - 3
CERTIFICATE OF SERVICE
I hereby certify that I have on this 17th day of February 2022, served the foregoing
documents on all parties of record as follows:
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Ste. 201-A Boise, ID 83714 [e-mail]

 Personal Delivery
 Facsimile
 Electronic
 Other: __________________
Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Ste. 201-A
Boise, ID 83714 [e-mail]

 Personal Delivery
 Facsimile
 Electronic
 Other: __________________
Tim Tatum Idaho Power Company PO Box 70 Boise, ID 83707 [e-mail]
[e-mail] [e-mail]
 U.S. Mail
 Personal Delivery
 Facsimile
 Electronic
 Other: __________________
Emma E. Sperry Idaho Conservation League
710 N. 6th St. Boise, ID 83702 [e-mail] [e-mail]

 Personal Delivery
 Facsimile
 Electronic
 Other: __________________
Richardson Adams, PLLC 515 N. 27th St. Boise, ID 83702 [e-mail] for Industrial Customers of Idaho Power
 U.S. Mail
 Personal Delivery
 Facsimile
 Electronic
 Other: __________________
6070 Hill Road Boise, ID 83703 [e-mail] for Industrial Customers of Idaho Power

 Personal Delivery
 Facsimile
 Electronic
 Other: __________________
CITY OF BOISE CITY’S PETITION TO INTERVENE - 4
C.Tom Arkoosh Amber Dresslar
Arkoosh Law Offices
PO Box 2900 Boise, ID 83701 [e-mail] [e-mail]
[e-mail]
for IdaHydro

 Personal Delivery
 Facsimile
 Electronic
 Other: __________________
Richardson Adams, PLLC 515 N. 27th St.
Boise, ID 83702
[e-mail] for Northwest and Intermountain Power Producers Coalition

 Personal Delivery
 Facsimile
 Electronic
 Other: __________________
Producers Coalition
c/o Spencer Gray Executive Director PO Box 504 Mercer Island, WA 98040
[e-mail]
 U.S. Mail
 Personal Delivery
 Facsimile
 Electronic
 Other: __________________

______________________________
Michelle Steel, Paralegal
CITY OF BOISE CITY’S PETITION TO INTERVENE - 5