20230106Petition to Intervene.pdf

JAYME B. SULLIVAN BOISE CITY ATTORNEY
Darrell Early ISB No. 4748 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: [e-mail]
Attorneys for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS COMPANY’S APPLICATION FOR AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR NATURAL GAS SERVICE IN
THE STATE OF IDAHO
Case No. INT-G-22-07
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 December 1, 2022, and the Notice of
Application and Intervention Deadline, Order No. 35640, 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
2.Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be sent to the following:
CITY OF BOISE CITY’S PETITION TO INTERVENE - 1
RECEIVED
Friday, January 6, 2023 12:25:04 PM
IDAHO PUBLIC
UTILITIES COMMISSION

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] [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, many
of whom are customers of Intermountain Gas Company (“Intermountain Gas”), and will be
impacted by the decisions made in this docket. Boise City is also a large Intermountain Gas
customer with commercial natural gas service accounts. As an Intermountain Gas customer with
expressed clean energy preferences, this proceeding directly impacts Boise City’s ability to meet
its community clean energy goals through efficient and affordable thermal energy resources.
Without the opportunity to intervene herein, Boise City would not have the direct means of
CITY OF BOISE CITY’S PETITION TO INTERVENE - 2

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 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 6th day of January 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 6th day of January 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: __________________
Riley Newton Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Ste. 201-A Boise, ID 83714 [e-mail]
[e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
Givens Pursley LLP 601 W. Bannock St. Boise, ID 83702
[e-mail] [e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Director of Regulatory Affairs Intermountain Gas Company PO Box 7608
Boise, ID 83707 [e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
Cable Huston LLP 1455 SW Broadway Suite 1500 Portland, OR 97201
[e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
Brad Heusinkveld Idaho Conservation League 710 N. 6th St.
Boise, ID 83702 [e-mail] [e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
________________________________ Michelle Steel, Paralegal
CITY OF BOISE CITY’S PETITION TO INTERVENE - 4