20210909Petition to Intervene.pdf

JAYME B. SULLIVAN
BOISE CIry ATTORNEY
Ed Jewell ISB No. 10446
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 : boi seci tyattornev@cityofboi se.org
ei ewell @cityofboise.ore
Attorney for Intervenor
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. INT-G-21-03IN THE MATTER OF INTERMOLINTAIN GAS
COMPANY'S APPLICATION FOR
DETERMINATION OF 2O2O EFFICIENCY
EXPENSES AS PRUDENTLY INCURRED 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 ldaho Public Utility Commission (IDAPA
31.01.01 .71 -31.01.0.73), the Application filed on July 14,2021, and Notice of Application and
Notice of Intervention Deadline, OrderNo. 35143, filed on August 20,202l,hereby requests leave
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 lntervenor 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 - I
2. Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Ed Jewell at:
Ed Jewell
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]
ej ewell @cityofboise. org
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 ofthe 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 representing the
public interest of Intermountain Gas customers that make up its constituency. Boise City is also a
large commercial Intermountain Gas customer. As a customer with expressed clean energy
preferences and community-wide energy efficiency targets, this proceeding directly impacts Boise
City's ability to meet its energy use reduction goals. 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 concems 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.
CITY OF BOISE CITY'S PETITION TO INTERVENE.2
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 Intenre,ne and issue a timely order as set forth in IDAPA 31.01.01.075.
DATED this 9th day of September 2021.
PAa,"L (
Ed Je$o0,
Deputy City Attorney
CITY OF BOISE CITY'S PETITION TO INTERVENE. 3
CERTIFICATE OF SERVICE
I hereby certiff that I have on this 9th day of September 2021, seryed the foregoing
documents on all parties of record as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Ste.201-A
Boise, ID 83714
i [e-mail]. sov
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. ChindenBlvd., Ste.201-A
Boise,ID 83714
[e-mail]. eov
Lori Blattner
Director-Regulatory Affairs
lntermountain Gas Company
P.O. Box 7608
Boise,ID 83707
Lori. Blattner@int gas. com
Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise, lD 83702
prestoncarter@ givensoursley. com
harmonywri ght@ eivenspursley. com
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Michelle Steel,
Paralegal
CITY OF BOISE CITY'S PETITION TO INTERVENE - 4