20230328Petition to Intervene.pdf

JAYME B. SULLIVAN BOISE CITY ATTORNEY
Darrell Early ISB No. 4748 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 FOR A CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY TO ACQUIRE RESOURCES
TO BE ONLINE BY 2024 AND FOR APPROVAL OF A POWER PURCHASE AGREEMENT WITH FRANKLIN SOLAR LLC
Case No. IPC-E-23-05 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 Utilities Commission (IDAPA
31.01.01.71 – 31.01.0.73), the Application filed on February 17, 2023, and the Notice of
Application and Intervention Deadline, Order No. 35701, hereby requests 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
Tuesday, March 28, 2023 11:45:41 AM
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]

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, 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 representing its constituents, who
are customers of Idaho Power Company (“Idaho Power”) and will be impacted by the decisions
made in this docket. 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. Additionally, Boise City is an Idaho Power customer with expressed clean
CITY OF BOISE CITY’S PETITION TO INTERVENE - 2
energy preferences. This proceeding may impact Boise City’s ability to meet its clean energy goals
through utility-scale renewable 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 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 28th day of March 2023.
______________________________
Darrell Early,
Deputy City Attorney
CITY OF BOISE CITY’S PETITION TO INTERVENE - 3
CERTIFICATE OF SERVICE
I hereby certify that I have on this 28th day of March 2023, 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: __________________
________________________________
Michelle Steel, Paralegal
CITY OF BOISE CITY’S PETITION TO INTERVENE - 4