20220818Petition to Intervene.pdf

JAYME B. SULLIVAN
BOISE CITY 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: (208\ 384-4454
Email: BoiseCityAttornev(a)cityofboise.ore
ei ew el I (E c ityo fboi s e. ore
Attorney for Intervenor
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR A
DETERMINATION OF 2O2I ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRED
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. INT-G-22-03
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 7l 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 July 12,2022, and the Amended Notice of
Application and Amended Notice of lntervention Deadline, Amended Order No. 35480, hereby
requests 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 TNTERVENE - 1
2. Copies of all pleadings, production requests, production responses, Commission orders,
and other documents should be sent to the following:
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: BoiseCityAttorney(dcityofboise.ore
ej ew ell @ cityo fbo i se. ore
Wil Gehl
Energy Program Manager
BOISE CITY DEPT. OF PUBLIC WORKS
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701 -0500
Telephone: [phone]
Email : w eehl(r, citvofboise.ors
Pursuant to Order No. 35375, Commission Rules 6l 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, responses, 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
(TDAPA 31.0r.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 lntermountain Gas Company ("Intermountain Gas") customers that make up its
constituency. Boise City is also a large commercial Intermountain Gas customer with a diversity
of natural gas service accounts. 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
CITY OF BOISE CITY'S PETITION TO INTERVENE - 2
not have the direct means of ensuring the outcome of this proceeding positively impacts the
environmental, health, and economic concerns ofBoise 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 Crty'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 h IDAPA 31.01.01.075.
DATED this l8th day of August2022.
Plo".Ll
E6-.il[well,
Deputy City Attorney
CITY OF BOISE CITY'S PETITION TO TNTERVENE - 3
CERTIFICATE OF SERVICE
I hereby certit/ that I have on this 18th day of August 2022, served the foregoing
documents on all parties of record as follows:
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Ste. 201-A
Boise,ID 83714
i an.noriyuki@fuc. idaho. gov
Chris Burdin
Deputy Attomey General
Idaho Public Utilities Commission
11331 W. ChindenBlvd., Ste.20l-A
Boise, ID 83714
chris.burdin@puc. idaho. eov
Lori A. Blatbrer
Director - Regulatory Affairs
Intermountain Gas Company
PO Box 7608
Boise,ID 83707
lori. blattner@inteas. com
Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise,ID 83702
prestoncarter@ qivenspursley. com
stephaniew@ eivenspursley. com
O U.S. Mailtr Personal DeliveryE] Facsimileg Electronictr Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronictr Other:
tr U.S. MailA Personal Delivery
O Facsimileg ElectronicO Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg ElectonicEl Other:
Michelle Steel,
Paralegal
CITY OF BOISE CITY'S PETITION TO INTERVENE - 4