20181227Petition to Intervene.pdf

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NATALIE CAMACHO MENDOZA
INTERIM BOISE CITY ATTORNEY
ABIGAIL R. GERMAINE (ISB No. 9231)
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 : asermaine@cityo fboise. org
Attorney for Intervenor
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BEFORE THE
IDAIIO PUBLIC UTILITIES COMMISSION
IN 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-18-02
EAG-W-18-01
CITY OF BOISE CITY'S
PETITION FOR LEAYE TO
INTERVENE
COMES NOW, the city of Boise City, herein referred to as "Intervenor," and pursuant to
Rules 71 through 73 of the Rules of Procedure of the ldaho Public Utility Commission (IDAPA
3 I .01 .01 .7 I - 3l .01 .0.73) and, pursuant to that Joint Application filed on November I 5, 201 8, and
Notice of Joint Application and Notice of Intervention Deadline, Order No. 34203, filed on
December 7,2018, hereby petitions the Commission for leave to intervene herein and to appear
and participate as aparty, and as basis therefore states as follows:
1. The name and address of this lntervenor is:
City of Boise City
150 N. Capitol Blvd.
P.O. Box 500
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 1
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Boise, ID 83701-0500
2. Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Abigail R. Germaine at:
Abigail R. Germaine
Deputy City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
Telephone: [phone]
Facsimile: (208) 384-445 4
Idaho State Bar No. 9231
Email : agermaine@cit),ofboise. ore
3. The Intervenor, the city of Boise City, is a Municipal Corporation organized under
the laws of the state of Idaho.
4. The Intervenor has a direct and substantial interest in this matter as Suez Water
Idaho Inc. ("Suez") is the Intervenor's franchised potable water service provider for Boise City.
As Suez is the Intervenor's water service provider, the Intervenor desires to ensure its citizens and
residents are not financially impacted by this sale and acquisition. Likewise, the Intervener has an
interest in guaranteeing its residents' level of service will also not be affected. The outcome of this
proceeding may affect environmental, health, and economic issues of Boise City and its citizens.
5. Without the opportunity to intervene herein, the Intervenor would be without any
means of participation in this proceeding which could have an impact on the rates that it and its
citizens pay for potable water service. If allowed to intervene, the Intervenor will participate in the
proceedings and appear in all matters as may be necessary and appropriate; present evidence; call
and examine witnesses; present argument; and otherwise fully participate in these proceedings.
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 2
6. Granting the Intervenor's petition to intervene will not unduly broaden the issues,
nor will it prejudice any party to this case.
7. Intervenor intends to fully participate in this matter as a party. The nature and
quality of the Intervenor's intervention in this proceeding is dependent upon the nature and effect
of other evidence in this proceeding. The Intervenor requests that the Commission issue a timely
order granting or denying this Petition for Leave to Intervene following the seven-day opposition
period set forth in IDAPA 31.01.01.075. The Petitioner also reserves its right to file for intervenor
funding, depending upon the amount of time and resources involved in this matter pursuant to
rDAPA 3 1-01.01. I 61-165.
WHEREFORE, the Intervenor, the city of Boise City, respectfully requests that this
Commission grant this Petition for Leave to Intervene.
DArED this 27 day of December 2018.
Attomey
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 3
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CERTIFICATE OF SERVICE
I hereby certify that I have on this 2-7 day of December 2018, served the foregoing
documents on all parties of counsel as follows
Michael Creamer, Esq.
Givens Pursley LLP
601 W. Bannock St.
P.O. Box 2720-83701
Boise, lD 83702
mcc@ givenspursley. com
Mr. Marshall Thompson
SUEZ Water Idaho Inc.
8248 West Victory Road
Boise, ID 83709
uarstal l. thompson@s tez. com
Mr. Robert DeShazo
Eagle Water Company, Inc.
188 West Water Company, Inc
Eagle, ID 83616
Nr. N.L. Bangle
188 West State Street
Eagle, ID 83616
nbanele@h2o-sol utionsl lc.net
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise, ID 83702
di ane. holt@puc. i daho- gotr
City of Eagle
c/o Cherese D. Mclain
MSBT Law, Chtd.
7699 West Riverside Drive
Boise, lD 83714
cdm@)msbtlaw.com
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CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 4
Stan Ridgeway
Mayor
City of Eagle
660 East Civic Lane
Eagle, ID 83616
srid geway@citlzofeagl e. org
sb ergmann@ ci tyo fea gl e. or g
U.S. Mail
Personal Delivery
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Other:
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City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 5