20220621Petition to Intervene.pdf

JAYME B. SI.'LLTVAN
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]
ei [e-mail]
Attorney for Intervenor
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHOzuTY TO MODIFY SCHEDULETg _
WEATHERZATION ASSISTANCE FOR
QUALIFIED CUSTOMERS
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CaseNo. IPC-E-22-15
CITY OF BOISE CITY'S
PETITION TO INTERYENE
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 May 4,2022, ard the Notice of Application
and Interve,ntion Deadline, Order No.35424, hereby requests leave to intervene in this matter and
to appear and participate as apafiy. 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:
CITY OF BOISE CITY'S PETITION TO TNTERVENE - 1
Ed Jewell
Deputy City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701 -0500
Telephone: [phone]
Facsimile: (208) 38404454
Email: BoiseCityAttorney(a)cit),ofboise.ore
ei [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]
Email : wsehl(rDcit)rofboi se. ore
Pursuant to Order No. 35375, Commission Rules 6l and 62 are suspended and all service in this
docket, except for voluminous discovery-related documents, 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 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 OF BOISE CITY'S PETITION TO INTERVENE - 2
City would not have the direct means of ensuring the outcome ofthis 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 evide,nce 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 2lst day of hne2022.
w*a*tt
Ed Jewel, (*)
Deputy City Attorney
CITY OF BOISE CITY'S PETITION TO INTERYENE - 3
CERTIFICATE OF SERVICE
I hereby certiff that I have on this 21st day of June 2022, sewed the foregoing documents
on all parties of record as follows:
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. ChindenBlvd., Ste.20l-A
Boise,ID 83714
i an.nori)ruki@puc. idaho. eov
Dayn Hardie
Deputy Attorrey General
Idaho Public Utilities Commission
11331 W. ChindenBlvd., Ste.201-A
Boise, D 83714
dayn.hardie@puc. idaho. eov
Lisa Nordstrom
Connie Aschenbrenner
Zack Thompson
Idaho Power Company
PO Box 70
Boise,ID 83707
lnordstrom@ idahopower. com
caschenbrenner@ idahopower. com
zthompson@ idahopower. com
dockets@.idahopower. com
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronictr Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg ElectronicO Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronictr Other:
Michelle Steel,
Paralegal
CITY OF BOISE CITY'S PETITION TO INTERVENE - 4