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Home My WebLink About20181228Petition to Intervene.pdfCHARLENE K. QUADE,ISB #6921 HEATHER L. CONDER, ISB #7057 SEAN R. BECK, ISB #7992 LANCE M. POUNDS, ISB # 10028 C.K. QUADE LAW, PLLC 600 E. Riverpark Lane, Suite 215 Boise, Idaho 83706 Telephone: 208-367 -0723 Facsimile: 208-639 -6400 Email : char @charquadelaw. com Email : heather @charquadelaw. com Email : sean@charquadelaw. com Email : lance@charqudaelaw. com EService : efi leidaho(@charquadelaw.com Attomeys for Petitioner Citizens Allied for Integrity and Accountability BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION RECEIVED 2Cl8 0iC 28 PH t: 2tr TN THE MATTER OF THE JOINT APPLICATION OF SUEZ WATER IDAHO AND EAGLE WATER COMPANY FOR THE ACQUISITION OF EAGLE WATER COMPANY CASE NOS. SUZ-W-I8-02 EAG-W-18-01 CITIZENS ALLIED FOR INTEGRITY AI\D ACCOUNTABILITY'S PETITION TO INTERVENE Petitioner Citizens Allied for Integrity and Accountability, a 501(c)3 Corporation, (hereinafter .'CAIA") through undersigned counsel of record, C.K. Quade Law, PLLC, pursuant to the Rules of Procedure of the Idaho Public Utilities Commission (hereinafter "RP"), IDAPA 37.01.01 .071-075, and Notice of Application, Notice of Intervention; Order No. 34203 (Dec. 7, 2018) (hereinafter "Notice of Application"), and hereby petitions the Commission for an order granting intervention to CAIA to become a party and participate fully in the matter of the Joint Application for Approval of Acquisition of Eagle Water Company, Inc. Assets by Suez Water Idaho Inc. and Amendment of Certificate of Public Convenience and Necessity No. 143, Approval of Rates and Charges and Request for Modified Procedure (hereinafter "Joint Application"). l. The address and name of the Petitioner is: Citizens Allied for Integrity and Accountability PO BOX2622 Eagle, Idaho 83616 CAIA Petition to Intervene Page 1 2. CAIA is represented by the below counsel of record and effective immediately, all notices, correspondence, pleadings, filings, or other communications should be directed to the following persons at the address listed below: C.K. Quade Law, PLLC 600 E. Riverpark Ln., Ste.215 Boise, ID 83706 Telephone 208-367 -0723 Facsimile 208-39-6400efileiM 3. CAIA is a nonprofit 501(c)3 corporation, formed and recognized underthe laws of the State of Idaho, and based in the City of Eagle. CAIA is composed of ratepayers, taxpayers and concerned citizens, including customers of one of the Applicants, Eagle Water Company. CAIA is a citizen's advocacy group initially formed by Idaho citizens dedicated to protecting the public interest by preserving private property rights, public health, safety and critical natural resources. CAIA's mission is broad enough to include the current Petition, as they have a direct interest in maintaining high quality water resources that adequately support both current users and future development in Eagle by maintaining local control of this most precious, irreplaceable resource and protecting citizens from drastic rate hikes. No other party can adequately represent the interests of CAIA. Intervention by the CAIA would not disrupt the proceedings, prejudice the parties, or unduly broaden the issues. 4. CAIA members stand to be impacted by significant rate increases resulting from the proposed acquisition, as set forth in the Joint Application, and possible environmental harms stemming from the merger. If the acquisition is granted, water rates would exceed 200%o for residential customers and 300o/o for commercial customers, in just three years. Notice of Application at 2; Joint Application at T2-13. This threatens to impose a substantial financial hardship and a "rate shock" on Eagle Water customers, many of whom are single parents, elderly, or living with disabilities on fixed and limited incomes. The outcome of proceedings regarding the Joint Application could also impact service to customers and other aspects of the public interest, including water quality, chemical treatments, and environmental concerns. CAIA therefore has a direct and substantial interest in the outcome of the Joint Application, as required by RP 74. CAIA Petition to lntervene Page 2 5. CAIA seeks intervention as a full party, to participate regarding the issues before the Commission, including those presented by the Joint Application, the direct testimony and exhibits submitted by the Applicants, the Notice of Application, and in written comments submitted to the Commission. Therefore, CAIA's intervention would not unduly broaden the issues, as required by RP 74. 6. A petition to intervene is timely if it is filed by the time provided by order or notice ofthe Commission. RP 73. The Commission has set an intervention deadline of December 28,2018. Notice of Application at 3-4. As aresult, this petition to intervene istimely. 7. In the event intervention is granted, Petitioner CAIA reserves the right to apply for intervenor funding pursuant to RP l6l-165. For the foregoing reasons, CAIA's petition should be granted to allow CAIA to interyene in this matter and fully participate in all aspects of the proceedings regarding the Joint Application filed by Eagle Water Company and Suez. DATED this 28th day of December, 2018. c.K. QUADE LAW PLLC By: SEAN Attorney for Petitioner CAIA CAIA Petition to Intervene Page 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 28th day of December, 2018, a true and correct copy of the foregoing document was served on the following in the manner indicated: Diane M. Hanian Commission Secretary Idaho Public Utilities Commission 472 W est Washington Street Boise, Idaho 83702 secretary@puc. idaho. gov diane.hanian@puc. idaho. eov IPUC Brandon Karpen Deputy Attomey General Idaho Public Utilities Commission 472 W est Washington Street Boise, Idaho 83702 brandon.ka@ IPUC Michael C. Creamer Givens Pursley LLP 601 W. Bannock St. Boise, Idaho 83702 mcc@ eivenspursley.com Attorneys for P etitioners Marshall Thompson Suez Water Idaho, Inc. 8248 W. Victory Rd. Boise,Idaho 83709 marshall.thompson@ suez. com Petitioner Robert DeShazo Eagle Water Company, Inc 188 W. State St. Eagle, Idaho 83616 Petitioner [ ] bv U.S. Mail [X] by Personal Delivery [ ] bV Facsimile [X] bv E-Mail [ ] bv U.S. Mail [ ] bV Personal Delivery [ ] by Facsimile lxl bv E-Mail [ ] bv U.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile [x] bv E-Mail [ ] by U.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile lxl bv E-Mail [x] bv U.S. Mail [ ] by Personal Delivery [ ] bV Facsimile [ ] bv E-Mail CAIA Petition to Intervene Page 4 N.L. Bangle 188 W. State St. Eagle, Idaho 83616 nbansle@h2o-solutionsllc.net Petitioner Cherese D. Mclain MSBT Law, Chtd. 7699 W. Riverside Drive Boise, Idaho 83714 cdm@msbtlaw.com Attorneys for Intervenor City of Eagle Stan Ridgeway, Mayor City of Eagle sri d geway@ citvo fea gle. or g sbersmann@cityofeasle. ore Intervenor City of Eagle Norman M. Semanko Parsons Behle & Latimer 800 West Main Street, Suite 1300 Boise,Idaho 83702 NSemanko@f arsonsbehle. com ecf@parsonsbehle.com Intervenor Eagle Water Customer Group (EWCG) Abigail R. Germaine Deputy City Attomey Boise City Attorney's Office 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 agermaine @ cityofboise. org Intervenor, City of Boise [ ] by U.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile lxl bv E-Mail [ ] bv U.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile [x] bv E-Mail [ ] bv U.S. Mail [ ] bV Personal Delivery [ ] by Facsimile lxl bv E-Mail [ ] by U.S. Mail [ ] bV Personal Delivery [ ] by Facsimile lxl bv E-Mail ,borah S.lson, Paralegal CAIA Petition to Intervene C.K. Quade Law, PLLC Page 5 [ ] by U.S. Mail [ ] by Personal Delivery [ ] bV Facsimile [x] bv E-Mail