20201106Petition to Intervene.pdf

JAI\ M. BENNETTS
ADA COUNTY PROSECUTING ATTORNEY
LORNA K. JORGENSEN
JOHN C. CORTABITARTE
Deputy Prosecuting Attorneys
Civil Division
200 W. Front Street, Room 3191
Boise,ID 83702
Telephone: [phone]
Facsimile: (208) 287 -77 19
ISB Nos. 6362 &9794
Email : civi lpafi [e-mail]
Attomeys for Intervenor Ada County
:e,:,.:+ il lYH *
;i:+ i1*d *6 FF{ l?, t+S
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. SUZ-W-20-02IN THE MATTER OF APPLICATION OF SUEZ
WATER IDAHO INC. FOR AUTHORIry TO
INCREASE ITS RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
ADA COUNTY'S PETITION
FOR LEAYE TO INTERVENE
COMES NOW, Ada County, pursuant to Rules 72 through 73 of the Rules of Procedure of
the Idaho Public Utility Commission (IDAPA 31.01.01.72-73), andpursuant to that Application
filed on Sepember 30,2020, and Notice of Application, Suspension of Proposed Effective Date
and Notice of Intervention Deadline, Order No. 34819 filed on October Zl,z}2},hereby petitions
the Commission for leave to intervene herein and to appear and participate as a party,and as basis
therefore states as follows:
l. The name and address of this Intervenor is:
Ada County
200 W. Front Street
Boise,ID 83702
ADA COUNTY'S PETITION FOR LEAVE TO INTERVENE. PAGE I
Z. Copies of all pleadings, production requests, production responses, Commission
orders and other documents should be provided to Lorna Jorgensen and John Cortabitarte at:
Ada County Prosecuting Attorney's Office
Civil Division
200 W. Front Street, Room 3l9l
Boise,lD 83702
Telephone: (208) 287'77 00
Facsimile: (208) 287 -77 19
Email: civi lpafi [e-mail]
In the interest of reducing costs to all parties, please provide hard copies of pleading, testimony,
and briefs only. All other production requests, response, notices, Commission orders and other
filings may be submitted via electronic mail in accordance with Rule 63 of the Rules of Procedure
of the ldaho Public Utility Commission (IDAPA 31.01.01.063).
3. Ada County is a duly formed and existing county pursuantto the laws and Constitution
of the State of Idaho.
4. Ada County has a direct and substantial interest in this matter as Ada County owns
and operates a number of buildings in Ada County which depend on Suez water. As stewards of
taxpayers' dollars, Ada County has an obligation to ensure that rates the County is paying for the
water are fair and equitable. Ada County also has a strong interest in ensuring that growth pays for
itself, that the citizens of Ada County are not subsidizing growth through increased rates, that
salaries and benefits of Suez employees are not excessive in comparison to the salaries and benefits
of ratepayers, and that ratepayers are not responsible for the company's bad debt' The outcome of
this proceeding potentially affects the ability of Ada County and average citizens to pay for water,
a critical public asset.
5. Without the opportunity to intervene herein, Ada County would be without any
means of participation in this proceeding which may have a negative impact the ability of Ada
ADA COUNTY'S PETITION FOR LEAVE TO INTERVENE. PAGE 2
County citizens to have access to affordable water offered by Suez Water Idaho Inc. If allowed to
intervene, Ada County will provide wriffen comments and otherwise fully participate in these
proceedings. In addition, should it be necessary, Ada County will appear in all matters as may be
required and appropriate; present evidence; call and examine witnesses; and present argument.
6. Granting Ada County's petition to intervene will not unduly broaden the issues, nor
will it prejudice any pafi to this case.
7. Ada County intends to fully participate in this maffer as aparty. The nature and
quality of Ada County's intervention in this proceeding is dependent upon the nature and effect of
other evidence in this proceeding. Ada County requests that the Commission issue a timely order
granting or denying this Petition for Leave to Intervene following the seven-day opposition period
set fonh in IDAPA 31.01.01.075. Ada County also reserves its right to file for intervenor funding,
depending upon the amount of time and resources involved in this matter pursuant to IDApA 3l-
01.01.I6l-l65.
WHEREFORE, Ada County, respectfully requests that this Commission grant this
Petition for Leave to Intervene.
DATED this 6th day of November, 2020.
JAI\I M. BENNETTS
Ada County Prosecuting Attomey
By: /s/ Loma K. Jorgensen
Loma K. Jorgensen
Deputy Prosecuting Attorney
ADA COUNTY'S PETITION FOR LEAVE TO INTERVENE. PAGE 3
CERTIFICATE OF SERYICE
I hereby certi$ that on the 6th day of November 2020,1served the foregoing documents
on all parties as follows:
Michael C. Creamer
Preston N. Carter
SI"IEZ Water Idaho Inc
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
u
tr
tra
tr
U.S. Mail
Personal Delivery
Facsimile
Electronic Means il Consent
Other:
mcc@.s lev.com
prestoncarter@ givenspurslev.com
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
I1331 W. Chinden Blvd., Bldg. 8, Ste. 20lA
Boise,ID 83714
secretary@puc. idaho. gov
tr
tr
EII
tr
tr
tr
tra
tr
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent
Other:
David Njuguna
Suez Water Management & Services
461 From Road, Suite 400
Paramus, NJ 07052
david.ni [e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent
Other:
Bv: /s/ Shelbv Hannah
Shelby Hannah
Legal Assistant
ADA COUNTY'S PETITION FOR LEAVE TO INTERVENE. PAGE 4