The URL can be used to link to this page

Home My WebLink About20231016Notice_Errata_Request.pdf AVIMOR’S NOTICE OF REPRESENTATION; ERRATA/CORRECTIONS TO FORMAL COMPLAINT; REQUEST TO PROCESS FORMAL COMPLAINT – Page 1 Norman M. Semanko, ISB #4761 PARSONS BEHLE & LATIMER 800 W. Main Street, Suite 1300 Boise, Idaho 83702 Telephone: 208.562.4900 Facsimile: 208.562.4901 Email: nsemanko@parsonsbehle.com boisedocket@parsonsbehle.com Attorneys for Complainant Avimor BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF AVIMOR’S FORMAL COMPLAINT AGAINST VEOLIA WATER IDAHO, INC. CASE NO. VEO-W-23-03 AVIMOR’S NOTICE OF REPRESENTATION; ERRATA/CORRECTIONS TO FORMAL COMPLAINT; REQUEST TO PROCESS FORMAL COMPLAINT COMES NOW, Norman M. Semanko, Parsons Behle & Latimer, and hereby enters his Notice of Representation as counsel of record on behalf of Complainant Avimor in the above- captioned matter, pursuant to Rules 41 and 43 of the Rules of Procedure of the Idaho Public Utilities Commission, IDAPA 31.01.01. Effective immediately, all notices, correspondence, pleadings, filings, and other communications regarding this matter should be served and directed to the following at the mailing and email addresses listed below: Norman M. Semanko PARSONS BEHLE & LATIMER 800 W. Main Street, Suite 1300 Boise, Idaho 83702 nsemanko@parsonsbehle.com boisedocket@parsonsbehle.com RECEIVED Monday, October 16, 2023 11:58:15 AM IDAHO PUBLIC UTILITIES COMMISSION AVIMOR’S NOTICE OF REPRESENTATION; ERRATA/CORRECTIONS TO FORMAL COMPLAINT; REQUEST TO PROCESS FORMAL COMPLAINT – Page 2 Further, pursuant to Rule 66, Complainant Avimor provides the following errata and corrections to inadvertent omissions from the formal complaint filed with the Commission on October 10, 2023: (1) A portion of Exhibit A to said formal complaint, referred to within said complaint as “an existing agreement with Suez,” was inadvertently omitted from the exhibit. A copy of said agreement is attached hereto and properly included in Exhibit A to the formal complaint, along with the design plans to the existing water main lines to service the Avimor Subdivision located in McLeod Road at the north and south ends of the public school’s property. Those design plans were approved by Suez pursuant to said agreement and were properly included in Exhibit A to the formal complaint when it was filed. This errata/correction adds the inadvertently omitted agreement with Suez to Exhibit A of the formal complaint. (2) The “Applicable Provisions” section of the formal complaint inadvertently omitted the “existing agreement with Suez” referred to above and hereby added to Exhibit A to the formal complaint, as well as Title 61, Idaho Code and other provisions of Idaho law applicable to Veolia’s acts and omissions in this matter. This errata/correction adds these inadvertently omitted “Applicable Provisions” to the formal complaint. Finally, pursuant to Rule 54.05, Complainant Avimor hereby requests that the formal complaint filed on October 10, 2023, including the errata/corrections noted above, be processed through issuance of a summons and service of a copy of the formal complaint, including the errata/corrections noted above, on Veolia Water Idaho, Inc. by the Commission Secretary, thereby requiring Veolia to file an answer to the formal complaint, including the errata/corrections noted above, within twenty-one (21) days, consistent with Rule 57. Avimor further requests that this matter proceed under Modified Procedure pursuant to Rules 201 through 204. AVIMOR’S NOTICE OF REPRESENTATION; ERRATA/CORRECTIONS TO FORMAL COMPLAINT; REQUEST TO PROCESS FORMAL COMPLAINT – Page 3 DATED this 16th day of October, 2023. PARSONS BEHLE & LATIMER Norman M. Semanko CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the following on this 16th day of October, 2023 by the following method: Jan Noriyuki Commission Secretary Idaho Public Utilities Commission P.O. Box 83720 Boise, Idaho 83720-0074 secretary@puc.idaho.gov jan.noriyuki@puc.idaho.gov [__] U.S. First Class Mail, Postage Prepaid [__] U.S. Certified Mail, Postage Prepaid [__] Federal Express [ ] Hand Delivery [X] Electronic Mail or CM/ECF Dayn Hardie Deputy Attorney General Idaho Public Utilities Commission P.O. Box 83720 Boise, Idaho 83720-0074 dayn.hardie@puc.idaho.gov [__] U.S. First Class Mail, Postage Prepaid [__] U.S. Certified Mail, Postage Prepaid [__] Federal Express [ ] Hand Delivery [X] Electronic Mail or CM/ECF Norman M. Semanko EXHIBIT “A”