20230609Petition 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 AUTHORITY TO IMPLEMENT CHANGES TO
THE COMPENSTION STRUCTURE
APPLICABLE TO CUSTOMER ON-SITE GENERATION UNDER SCHEDULES 6, 8, AND 84 NAD TO ESTABLISH AN EXPORT CREDIT RATE METHODOLOGY
Case No. IPC-E-23-14 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 May 1, 2023, and the Notice of Application
and Intervention Deadline, Order No. 35790, 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
2023 JUNE 9, 2023 10:53AM
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: (208) 38404454
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 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 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 9th day of June 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 9th day of June 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: __________________
Megan Goicoechea Allen
Idaho Power Company PO Box 70 Boise, ID 83707 [e-mail]
[e-mail]
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Connie Aschenbrenner Grant Anderson
Idaho Power Company
PO Box 70 Boise, ID 83707 [e-mail] [e-mail]
[e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
Idaho Conservation League
710 N. 6th St. Boise, ID 83702 [e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
CITY OF BOISE CITY’S PETITION TO INTERVENE - 4
Brad Heusinkveld Idaho Conservation League 710 N. 6th St.
Boise, ID 83702 [e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
Echo Hawk & Olsen, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205
[e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
2623 NW Bluebell Place Corvallis, OR 97330 [e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
IdaHydroArkoosh Law Offices
913 W. River Street, Suite 450Boise, ID [e-mail]@arkoosh.com

Personal Delivery
Facsimile
Electronic
Other: __________________
Mike Heckler Clean Energy Opportunities for Idaho 3778 Plantation River Dr. Suite 102 Boise, ID 83703
[e-mail]
[e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
Law for Conscious Leadership 920 N. Clover Dr.
Boise, ID 83703 [e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
Micron Technology, Inc. 8000 South Federal Way
Boise, ID 83707 [e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
CITY OF BOISE CITY’S PETITION TO INTERVENE - 5
Austin Rueschhoff Thorvald A. Nelson Austin W. Jensen
Holland & Hart, LLP 555 17th St. Suite 3200 Denver, CO 80202 [e-mail] [e-mail]
[e-mail] [e-mail] [e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
________________________________ Michelle Steel, Paralegal
CITY OF BOISE CITY’S PETITION TO INTERVENE - 6