20200316Response.pdf

Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: (208) 388- I 200
[e-mail]
Attomeys for Intermountain Gas Company
BEFORE TFIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF
INTERMOLNTAIN GAS COMPANY
FOR AUTHORITY TO REVISE ITS
GENERAL SERVICE PROVISIONS
RELATED TO THE INSTALLATION
AND EXTENSION OF NATURAL
GAS MAINS AND SERVICES.
Case No. INT-G-20-01
RESPONSE TO CITY OF
BOISE'S PETITION FOR
LEAVE TO INTERVENE
T{ECEIVED
irill l{irl I 6 AH ll : 25
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Pursuant to Rule 75 of the Idaho Public Utilities Commission ("Commission"), IDAPA
31.01.01.075, Intermountain Gas Company ("lntermountain Gas" or "Company'') submits this
response to the City of Boise's Petition for Leave to Intervene ("Petition") in this proceeding.
In its Petition, the City of Boise states that it has a direct and substantial interest in this
matter "as the entity tasked with administering the franchise agreement" with Intermountain Gas;
because the City "is pursuing clean and renewable energy transition and energy use reduction
goals;" and because Intermountain Gas's application "could affect environmental, health, and
economic issues conceming Boise City and its citizens." Petition at2-3.
lntermountain Gas recognizes that the City has an interest in this proceeding as a natural gas
customer and as a govemmental entity whose citizens are natural gas customers. Because the City
has an interest in this proceeding, and because the Company welcomes dialogue with stakeholders
regarding the subject matter of this application, lntermountain Gas does not object to the City's
intervention.
RESPONSE TO CITY OF BOISE'S PETITION FOR LEAVE TO TNTERVENE - 1
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ORIGINAL
However, as the City recognizes, intervention is not permitted if it would unduly broaden
the issues in a proceeding. Rule 37, IDAPA 31.01.01.073; Petition at 6. The Company respectfully
submits that issues regading the franchise agreement and the Crty's clean energy goals are not a
part of this proceeding, and that the City's intervention (or Intemrountain Gas's lack of objection to
the City's intervention) should not be constued as pennission to broaden the scope of this
proceeding to encompass those issues.
Dated: March 16,2020.
GTVENS PURSLEY LLP
By f
Preston N. Carter
Attorney for Intermountain Gas Company
RESPONSE TO CITY OF BOISE'S PEMION FORLEAVE TO INTERVENE.2
15(X8300_l.docx
CERTIFICATE OF SERVICE
I certify that on March 16,2020, a true and correct copy of the foregoing comments were served
upon all parties of record in this proceeding via the manner indicated below:
Commission Staff
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Ste.20l-A
Boise, lD 83714
[e-mail]. eov
Maff Hunter, Deputy Attorney General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, lD 83714
Edward.Jewel I @puc. idaho. sov
Hand Delivery & Electronic Mail
(Original and 7 Copies)
Electronic Mail
Via Electronic Mail
Abigail R. Germaine
Boise City Attorney's Office
I50 N. Capitol Blvd.
Boise, ID 83701
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, lD 83702
botto@ idahoconservation.orq
f
Preston N. Carter
RESPONSE TO CITY OF BOISE'S PETITION FORLEAVE TO INTERVENE - 3
15048300 l.docx