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Home My WebLink About20181227Petition to Intervene.pdf:.. i:,/[Dt_, - Norman M. Semanko, ISB #4761 PARSONS BEHLE & LATIMER 800 West Main Street, Suite 1300 Boise, Idaho 83702 Telephone: 208.562.4900 Facsimile: 208.562.4901 NSemanko@parsonsbehle.com ecf@parsonsbehle.com IN THE MATTER OF THE JOINT APPLICATION OF SUEZ WATER IDAHO AND EAGLE WATER COMPANY FOR THE ACQUISITION OF EAGLE WATER COMPANY :, :: i;:C 2i Fii 3: 28 CASE NOS. SUZ-W.I8-02 EAG-W-18-01 EAGLE WATER CUSTOMER GROUP'S PETITION TO INTERVENE ta' IISIO ltl: Attorneys for Petitioner Eagle Water Customer Group BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION COMES NOW, Eagle Water Customer Group (hereinafter "EWCG" or "Customer Group"), through the undersigned counsel of record, pursuant to the Rules of Procedure of the Idaho Public Utilities Commission (hereinafter "RP"), IDAPA 37.01.01 .071-075, andNotice 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 EWCG 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 Wqter ldaho Inc. ond Amendment of Certificate of Public Convenience and Necessity No. 143, Approval of Rates and Charges and Request for Modified Procedure (hereinafter "Joint Application"). 1. The address and name of the Petitioner is: Eagle Water Customer Group 8770 W. Chaparral Road Eagle, Idaho 83616 EAGLE WATER CUSTOMER GROUP'S PETITION TO INTERVENE- Page 1 2. EWCG 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: Norman M. Semanko Parsons Behle & Latimer 800 West Main Street, Suite 1300 Boise, Idaho 83702 N S emanko @parsonsbehl e. co m ecf@parsonsbehle.com 3. EWCG is an unincorporated nonprofit association, formed and recognized under the laws of the State of Idaho, composed of ratepayers, taxpayers and concerned citizens, including customers of one of the Applicants, Eagle Water Company. EWCG members stand to be impacted by significant rate increases resulting from the proposed acquisition, as set forth in the Joint Application. If granted, these rate increases would exceed 200% for residential customers and 300% for commercial customers, in just three years. Notice of Application at 2; Joint Application at 12- 13. This threatens to impose considerable "rate shock" on Eagle Water customers. The outcome of proceedings regarding the Joint Application could also impact service to customers and other aspects of the public interest. EWCG therefore has a direct and substantial interest in the outcome of the Joint Application, as required by RP 74. 4. EWCG 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, EWCG's intervention would not unduly broaden the issues, as required by RP 74. EAGLE WATER CUSTOMER GROUP'S PETITION TO INTERVENE- Page 2 5. A petition to intervene is timely if it is filed by the time provided by order or notice of the Commission. RP 73. The Commission has set an intervention deadline of December 28, 2018. Notice of Application at 3-4. As a result, this petition to intervene is timely. 6. EWCG was formed to oppose and respond to the proposed acquisition of Eagle Water Company by Suez, including the proposed rate increases, potential impacts on service, and other aspects of the public interest. The Customer Group's intervention would allow for active participation in all aspects of these proceedings, as necessary to protect the interests of its members. No other party can adequately represent the interests of EWCG. The Customer Group's intervention would not disrupt the proceedings, prejudice the parties, or unduly broaden the issues. 7. In the event intervention is granted, Petitioner EWCG reserves the right to apply for intervenor funding pursuant to RP l6l-165. For the foregoing reasons, EWCG's petition should be granted to allow EWCG to intervene 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 27th day of December, 2018. PARSONS BEHLE & LATIMER By:g Norman M. EAGLE WATER CUSTOMER GROUP'S PETITION TO INTERVENE- Page 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the following on this 27th day of December,2018 by the following method: N.L. Bangle 188 W. State St. Eagle, Idaho 83616 nbangle@h2o-solutionsllc.net Diane M. Hanian Commission Secretary Idaho Public Utilities Commission 472 W est Washington Street Boise, Idaho 83702 secretary@puc.idaho. gov diane.hanian@nuc. idaho. sov Brandon Karpen Deputy Attorney General Idaho Public Utilities Commission 472 W est Washington Street Boise, Idaho 83702 brandon. karpen@.puc. idaho. eov Michael C. Creamer Givens Pursley LLP 601 W. Bannock St. Boise, Idaho 83702 mcc@ givenspursley. com Marshall Thompson Suez Water Idaho, Inc. 8248 W. Victory Rd. Boise, Idaho 83709 marshall.thompson@suez.com Robert DeShazo Eagle Water Company, Inc 188 W. State St. Eagle, Idaho 83616 LJ U.S. First Class Mail, Postage Prepaid Ll U.S.Certified Mail, Postage Prepaid [_] Federal Express [X] Hand Delivery [X] Electronic Mail or CM/ECF [-] U.S.First Class Mail, Postage Prepaid [l U.S.Certified Mail, Postage Prepaid [_] Federal Express [X] Hand Delivery [X] Electronic Mail or CM/ECF [X] U.S. First Class Mail, Postage Prepaid [l U.S. Certified Mail, Postage Prepaid [_] Federal Express [_] Hand Delivery [X] Electronic Mail or CM/ECF [X] U.S. First Class Mail, Postage Prepaid Ll U.S.Certified Mail, Postage Prepaid [_] Federal Express [_] Hand Delivery [X] Electronic Mail or CM/ECF El U.S. First Class Mail, Postage Prepaid Ll U.S. Certified Mail, Postage Prepaid [J Federal Express [J Hand Delivery [l Electronic Mail or CM/ECF [X] U.S. First Class Mail, Postage Prepaid Ll U.S.Certified Mail, Postage Prepaid [_] Federal Express [_] Hand Delivery [X] Electronic Mail or CM/ECF EAGLE WATER CUSTOMER GROUP'S PETITION TO INTERVENE- Page 4 Cherese D. Mclain MSBT Law, Chtd. 7699 W, Riverside Drive Boise, Idaho 83714 cdm@msbtlaw.com Stan Ridgeway, Mayor City of Eagle sri d geway@ cityo fea gle. o r g sber gmann@cityofeagle. org [X] U.S. First Class Mail, Postage Prepaid Ll U.S. Certified Mail, Postage Prepaid [_] Federal Express [_] Hand Delivery [X] Electronic Mail or CM/ECF Ll U.S.First Class Mail, Postage Prepaid L_l U.S. Certified Mail, Postage Prepaid I I Federal Express [J Hand Delivery [X] Electronic Mail or CM/ECF \----/1,I/ Norman M. Semanko EAGLE WATER CUSTOMER GROUP'S PETITION TO INTERVENE- Page 5 4829-4379-6356v1 ,l s;--