20220725Petition to Intervene.pdf

JAYME B. SI.JLLTVAN
BOISE CITY ATTORNEY
Mary Grant ISB No. 8744
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
PO Box 500
Boise,ID 83701-0500
Telephone: [phone]
Facsimile: Q08) 384-4454
Email: [e-mail]
mrerant@citvofboise. ore
Attorney for Intervenor
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CITY OF BOISE CITY'S
PETITION TO INTERVENE
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BEFORE TIIE
IDAHO PUBLIC UTILITIES COMMISSION
CaseNo. PC-E-22-22IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO COMPLETE
THE STUDY REVIEW PHASE OF THE
COMPREHENSTVE STI.JDY OF COSTS AND
BENEFITS OF ON-SME CUSTOMER
GENERATION & TO IMPLEMENT CHANGES
TO SCHEDI.JLES 6, 8, AND 84 NON-LEGACY
SYSTEMS
COMES NOW, the city of Boise City, herein referred to as "Boise City," and pursuant to
Rules 7l through 73 of the Rules of Procedure of the Idaho Public Utilities Commission (IDAPA
31.01.01.71 - 31.01.0.73), the Application filed on June 30, 2022, and the Notice of Application
and Intervention Deadline, Order No. 35464, hereby requests 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 Intervenor is:
City of Boise City
150 N. Capitol Blvd.
PO 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 sent to the following:
Mary Grant
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
PO Box 500
Boise, Idaho 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: BoiseCit),Attorney(@citvofboise.orq
mrsrant@citvofboise. org
Wil Gehl
Energy Program Manager
BOISE CITY DEPT. OF PUBLIC WORKS
150 N. Capitol Blvd.
PO Box 500
Boise, Idaho 83701 -0500
Telephone: [phone]
Email : w eehl(dcitvofboise. ors
Pursuant to Order No. 35375, Commission Rules 61 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, responses, 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 31.0r.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
CITY OF BOISE CITY'S PETITION TO INTERVENE - 2
impacts Boise City's ability to meet its community clean energy goals through distributed energy
resources. 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 concenrs 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 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 22nd day of July 2022.
Mary Grant,
Deputy City Attorney
CITY OF BOISE CTTY'S PETTTION TO INTERVENE - 3
CERTIFICATE OF SERVICE
I hereby certi$that I have on this 22nd day of Jnly 2022, served the foregoing
documents on all parties of record as follows:
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
1 1331 W. Chinden Blvd., Ste. 201-4.
Boise,ID 83714
i an.noriyuki@Fuc. idaho. eov
RileyNewton
Deputy Affomey General
Idaho Public Utilities Commission
I1331 W. Chinden Blvd., Ste. 201-A
Boise, D 83714
riley. newton@.puc. idaho. sov
LisaNordshom
Megan Goicoechea Allen
Idaho Power Company
PO Box 70
Boise, lD 83707
[e-mail]
meoicoecheaallen@ idahopower. ocm
[e-mail]
trUS Mailtr Personal Deliverytr FacsimileX Electronictr Other:
trUS Mailtr Personal Deliverytr FacsimileX Electronictr Other:
trUS Mailtr Personal Deliverytr FacsimileX Electronictr Other:
trUS Mailtr Personal Deliverytr FacsimileX Electronictr Other:
Timothy Tatum
Connie Aschenbrenner
Grant Anderson
Idaho Power Company
PO Box 70
Boise, D 83707
caschenbrenner(d idahopow er. com
ganderson@idahopower. com
ttatum@ idahopower. com
Michelle Steel,
Paralegal
CITY OF BOISE CITY'S PETITION TO TNTERVENE - 4