20220412Petition to Intervene.pdf

JAYME B. SI.JLLIVAN
BOISE CITY ATTORNEY
Ed Jewell ISB No. l0M6
Depury City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701-0500
Telephone: [phone]
Facsimile: (208) 3 84 -445 4
Email: BoiseCityAttorney(@citvofboise.org
ej ew el I @ citvo fboi se. ore
Attorney for Intervenor
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BEFORE TIIE
IDAIIO PUBLIC UTILITIES COM1VtrSSION
Case No. IPC-E-22-08IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2021 DEMAND-SIDE
MANAGEMENT EXPENSES AS PRI.'DENTLY
INCURRED
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 frled on March 15,2022, and the Notice of Intervention
Deadline, Order No. 35365, 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
2. Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be sent to the following:
CTTY OF BOISE CITY'S PETITION TO TNTERVENE - 1
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: (208) 38404454
Email: BoiseCityAttorney(rDcitvofboise.ore
ej [e-mail]
Wil Gehl
Energy Program Manager
BOISE CITY DEPT. OF PUBLIC WORKS
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
Telephone: [phone] I
Email : w gehl(a) citvofboise.ore
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
(TDAPA 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. 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 accessible, innovative,
and cost-effective energy efficiency programs. Without the opportunity to intervene herein, Boise
City would not have the direct means of ensuring the outcome ofthis proceeding positively impacts
CITY OF BOISE CITY'S PETITION TO TNTERVENE - 2
the enviromrental, 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
depende,lrt upon the nature and effect of other evidence in this proceeding. If necessary, Boise City
may present evidence; call and examine witresses; 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 l2th day of April2022.
D"a"rLl
Ed Jewel, (J
Deputy City Attorney
CITY OF BOISE CITY'S PETITION TO INTERVENE - 3
CERTIFICATE OF SERYICE
I hereby certiff that I have on this l2thday of April 2022, served the foregoing documents
on all parties of record as follows:
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Ste. 201-A
Boise,ID 83714
j an.norivuki@puc. idaho. eov
RileyNewton
Deputy Attorney General
Idaho Public Utilities Commission
I1331 W. Chinden Blvd., Ste. 201-A
Boise, lD 83714
riley.newton(4)puc. idaho. eov
Lisa Nordstom
Idaho Power Company
PO Box 70
Boise, lD 83707
lnordstrom (D idahopower. com
dockets@ idahopower. com
Connie Aschenbrenner
Zack Thompson
Idaho Power Company
PO Box 70
Boise, ID 83707
caschenbrenner(@idahopow er. com
ahompson@ idahopower. com
O U.S. Mailtr Personal Deliverytr Facsimileg ElectonicO Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronictr Other:
tr U.S. MailO Personal Deliverytr Facsimileg Electronictr Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronictr Other:
Michelle Steel,
Paralegal
CITY OF BOISE CITY'S PETTTION TO INTERVENE - 4