20231205Petition to Intervene.pdf

CITY OF BOISE CITY’S PETITION TO INTERVENE - 1
JAYME B. SULLIVAN BOISE CITY ATTORNEY
Ed Jewell ISB No. 10446 Daphne Huang ISB No. 8370 Deputy City Attorneys BOISE CITY ATTORNEY’S OFFICE 150 N. Capitol Blvd.
P.O. Box 500 Boise, ID 83701-0500 Telephone: [phone] Email: [e-mail]
Attorneys for Intervenor BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS COMPANY’S APPLICATION FOR A DETERMINATION OF 2022 ENERGY EFFICIENCY EXPENSES AS PRUDENTLY INCURRED
Case No. INT-G-23-06 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 October 6, 2023, and the Notice of Application
and Notice of Intervention Deadline, Order No. 36002, 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:
RECEIVED
Tuesday, December 5, 2023 4:13:17 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CITY OF BOISE CITY’S PETITION TO INTERVENE - 2

Daphne Huang
Deputy City Attorneys BOISE CITY ATTORNEY’S OFFICE 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500
Telephone: [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, 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
(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 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
not have the direct means of ensuring the outcome of this proceeding positively impacts the
CITY OF BOISE CITY’S PETITION TO INTERVENE - 3
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 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 Intervene and issue a timely order as set forth in IDAPA 31.01.01.075.
DATED this 5th day of December 2023.
______________________________ Daphne Huang, Deputy City Attorney
CITY OF BOISE CITY’S PETITION TO INTERVENE - 4
CERTIFICATE OF SERVICE
I hereby certify that I have on this 5th day of December 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: __________________
Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Ste. 201-A
Boise, ID 83714
[e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
Director – Regulatory Affairs
Intermountain Gas Company PO Box 7608 Boise, ID 83707 [e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Givens Pursley LLP 601 W. Bannock St. Boise, ID 83702
[e-mail]
[e-mail]

Personal Delivery
Facsimile
Electronic
Other: __________________
________________________________
Michelle Steel, Paralegal