20200311Petition to Intervene.pdf

REC f; IVED
;:$ F1,{i1 I I PH 2: I 7
rj '' . ,r: ll! lt'
' r", E t-,: !,', i, -. -: i..rl:,.ii,iiSSl*HJAYME B. SULLIVAN
BOISE CITY ATTORNEY
ABIGAIL R. GERMAINE (ISB No. 9231)
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]
Attorney for Boise City
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. INT-G-20-01IN THE MATTER OF INTERMOI.INTAIN GAS
COMPANY'S APPLICATION FOR
AUTHORITY TO REVISE ITS GENERAL
SERVICE PROVISIONS RELATED TO THE
INSTALLATION AND EXTENSION OF
NATURAL GAS MAINS AND SERVICES
CITY OF BOISE CITY'S
PETITION FOR LEAVE TO
INTERVENE
COMES NOW, the city of Boise City, herein referred to as "Boise City" and pursuant to
Rules 71 through 13 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA
31.01.01 .71 -31.01.0.73), and pursuant to that Application filed on January 27,2020, and Notice
of Application, Notice of Intervention Deadline and Notice of Suspension of Proposed Effective
Date, Order No. 34560, filed on February 25,2020, hereby petitions the Idaho Public Utilities
Commission ("Commission") for leave to intervene herein and to appear and participate as aprty,
and as basis therefore states as follows:
1. The name and address of this Intervenor is:
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - I
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 provided to Abigail R. Germaine at:
Abigail R. Germaine
Deputy City Attorney
BOISE CIry ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
Telephone: [phone]
Facsimile: (208) 384-445 4
Idaho State Bar No. 9231
Email : [e-mail]
In the interest of reducing costs to all parties, please provide hard copies of pleading, testimony,
and briefs only. All other production requests, response, notices, Commission orders, and other
filings may be submitted 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 the entity tasked
with administering the franchise agreement with lntermountain Gas Company for natural gas
services within Boise City. In addition, Boise City is pursuing clean and renewable energy
transition and energy use reduction goals which are a reflection of the comments and feedback
received from the citizens of Boise City in the course of Boise City's various community
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 2
engagement processes. Intermountain Gas Company's Application could affect environmental,
health, and economic issues conceming Boise City and its citizens.
5. Without the opportunity to intervene herein, Boise City would be without any
means of participation in this proceeding. If allowed to intervene, Boise City will provide written
comments and otherwise fully participate in these proceedings as ordered by the Commission. In
addition, should it be necessary, Boise City will appear in all matters as may be required and
appropriate; present evidence; call and examine witnesses; and present argument.
6. Granting Boise City's petition to intervene will not unduly broaden the issues, nor
will it prejudice any party to this case.
7. Boise City intends to fully participate in this matter as a party. 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. Boise City requests that the Commission issue a timely order
granting or denying this Petition for Leave to Intervene following the seven-day opposition period
set forth in IDAPA 31.01.01.075. Boise City also reserves its right to file for intervenor funding,
depending upon the amount of time and resources involved in this matter pursuant to IDAPA 31-
01.01.161-165.
WHEREFORE, the city of Boise City, respectfully requests that this Commission grant
this Petition for Leave to Intervene.
DATED this day of March2020.
Germaine
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 3
City Attorney
CERTIFICATE OF SERVICE
I hereby certit/ that I have on this day of March 2020, served the foregoing
documents on all parties of counsel as follows:
_l!_
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Building 8
Suite 201-A
Boise, lD 83714
[e-mail]. gov
Matt Hunter
Deputy Attomey General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8
Suite 201-A
Boise, lD 83714
matt.hunter@puc. idaho. gov
Intermountain Gas Company
C/O Preston N. Carter
Givens Pursley LLP
pnc@ givenspursl ey. com
kendrah@ givenspursley. com
Lori A. Blattner
Director - Regulatory Affairs
Intermountain Gas Company
Lori. B I attn er @inter sas. com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, lD 83702
botto@idahoconservation. ore
tr U.S. Mailg Personal Deliverytr Facsimiletr Electronic Meanstr Other:
tr U.S. Mailtr Personal Deliverytr FacsimileV Electronic Meanstr Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Meanstr Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Meanstr Other:
tr U.S. Mailtr Personal Deliverytr FacsimileV Electronic Meanstr Other:
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE.4
Attorney