20201110Petition to Intervene.pdf

JAYME B. SULLTVAN
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: (208) 384-445 4
Email : [e-mail]
Attorneyfor Boise City
IN THE MATTER OF SUEZ WATER IDAHO
INC.'S APPLICATION FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
WATER SERVICE IN IDAHO
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BEFORE THE
IDAHO PT'BLIC UTILITIES COMMISSION
CaseNo. SUZ-W-20-02
CITY OF BOISE CITY'S
PETITION FOR LEAVE TO
INTERYENE
COMES NOW, the city of Boise City, herein referred to as "Boise City" and pursuant to
Rules 7l through 73 of the Rules of Procedure of the Idaho Public Utility Commission (IDApA
31.01.01.71 - 31.01 .0.73) and, pursuant to that SUEZ Water Idaho Inc. Application for Authority
to Increase its Rates and Charges for Water Service in Idaho, and Notice of Application filed on
October 21,2020; and Notice of Application, Suspension of Proposed Effective Date, Notice of
lntervention Deadline, Order No. 34819, filed on October 2I, 2020, hereby petitions the
Commission for leave to intervene herein and to appear and participate as a party, and as basis
therefore states as follows:
1. The name and address of Boise City is:
City of Boise City
150 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701-0500
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - I
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 Attorney
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 : [e-mail]
3' Boise City is a Municipal Corporation organized under the laws of the state of Idaho.
4' Boise City has a direct and substantial interest in this matter as it represents the citizens of
Boise city who are served by Suez Water Idaho Inc. (the "company"), as well as being a customer
of the company itself' Boise city has three hundred twenty (320) municipal operations suez
accounts and spends roughly five hundred thousand dollars ($500,000.00) forpotable water within
Boise City municipal facilities annually. The Company is proposing a twenty-two, point three,
percent (22'3%) rate increase. This large rate increase will have a dramatic effect on rate payers
all across the community.
5' without the opportunity to intervene herein, Boise City would be without any means of
participation in this proceeding which may have a material impact on the rates paid by Boise City
citizens and Boise city itself. If allowed to intervene, Boise city 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.
6' Granting Boise City's petition to intervene will not unduly broaden the issues, nor will it
prejudice any party to this case.
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 2
7. Boise City intends to fully participate in this matter as a party. The nature and quality of
Boise City's intervention in this proceeding is dependent upon the nature and effect of other
evidence in this proceeding' Boise City requests that the Commission issue a timely order granting
this Petition for Leave to Intervene following the seven-day opposition period set forth in IDApA
31.01.01.075' Boise City also reseryes its right to file for intervenor funding, depending upon the
amount of time and resources involved in this matter pursuant to IDApA 3 I -01 .01 . I 6l - 165.
WHEREFORE, Boise City, respectfully requests that this Commission grant this
Petition for Leave to lntervene.
DATED this l0th day ofNovember 2020.
drr*e
R. Germaine
Deputy City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 3
CERTIFICATE OF SERVICE
I hereby certify that I have on this 10ft day of November 2020, served the foregoing
documents on all parties of counsel as follows
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
I1331 West Chinden Boulevard
Building 8, Suite 201-A
PO Box 83720
Boise, D 83720
j an.noriwki@puc. idaho. eov
David Njuguna
Suez Water Management & ServiceS
461 From Road, Suite 400
Paramus, NJ 07052
David. nj u guna@ suez. com
Michael C. Creamer
Preston N. Carter
GTVENS PURSLEY LLP
Attorneys atLaw
601 West Bannock Street
Boise, D 83702
mcc(r, gi venspursley.com
prestoncarter@ qivenspurslelz. com
Attorneys for Suez Water ldaho, Inc.
Dayn Hardie
Deputy Attomey General
Idaho Public Utilities Commission
11331 West Chinden Boulevard
Building 8, Suite 201-A
PO Box 83720
Boise, D 83720
dayn. hardie@puc. idaho. eov
Loma Jorgensen tr
John Cortabitarte tr
Ada County Prosecuting Attorney's Office tr
Civil Division V
200 W. Front Street, Room 3191 tr
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CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 4
Boise, ID 83702
civiloafi [e-mail]
Attorneys for Ada County
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R. Germaine
Deputy City Attomey
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 5