20201110Petition to Intervene.pdf

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Norman M. Semanko, ISB #4761
PARSONS BEHLE & LATIMER
800 West Main Street, Suite 1300
Boise,Idaho 83702
Telephone: [phone]
Facsimile: 208562.4901
N S emanko @p ars ons b eh I e. c om
b oi s e d o cket @p ars ons b ehl e. com
IN THE MATTER OF SUEZ WATER
IDAHO INC.'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE
IN IDAHO
Attomeys for Petitioner SUEZ Water Customer Group
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. SUZ-W-20-02
SUEZ WATER CUSTOMER GROUP'S
PETITION TO INTERVENE
COMES NOW, SUEZ Water Customer Group (hereinafter .'SWCG" or "the Customer
Group"), through the undersigned counsel ofrecord, pursuant to the Rules ofProcedure ofthe Idaho
Public Utilities Commission (hereinafter "RP"), IDAPA 37.01.01.071475, andNotice of
Application; Suspension of Proposed Effective Date; Notice of Intervention Deadline; Order No.
34819 (Oct.21,2020) (hereinafter "Notice of Application"), and hereby petitions the Commission
for an order granting intervention to SWCG to become a party and participate fully in the matter of
the SUEZ Water ldaho Inc.'s Applicationfor Authority to Increase its Rates and Chargesfor Water
Service in ldaho (hereinafter "Application" or "Rate Case").
1. The address and name of the Petitioner is:
SUEZ Water Customer Group
c/o Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise,Idaho 83702
SUEZ WATER CUSTOMER GROUP'S PETITION TO INTERVENE - Page 1
2. SWCG 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 @p ars on s b ehl e. com
B o is edo cke t@p ar s ons b e h I e. com
3. SWCG is an unincorporated nonprofit association, formed and recognized under the
laws of the State of Idaho, composed of ratepayers and customers of the Applicant, for the purpose
of opposing and responding to the proposed rate increase on SUEZ Water customers. SWCG
members stand to be impacted by significant rate increases proposed in the current Rate Case, as
set forth in the Application. If granted, these rate increases would average 22.3% across-the-board.
Notice of Application at 1. For the average residential customer, the average annual bill would
increase from $355.95 to$435.22. Notice of Applicationat2. This proposed increase is unjust and
unreasonable and threatens to impose considerable "rate shock" on SUEZ Water customers,
particularly those who are on fixed incomes or whose businesses operate on thin margins. The
Customer Group therefore has a direct and substantial interest in the outcome of the Application,
as required by RP 74.
4. SWCG seeks intervention as a full party, to participate on behalf of all classes of
ratepayers regarding the issues before the Commission, including those presented by the
Application, the direct testimony and exhibits submitted by the Applicant, the Notice of
Application, ffid in written comments submitted to the Commission. Therefore, SWCG's
intervention would not unduly broaden the issues, as required by RP 74.
SUEZ WATER CUSTOMER GROUP'S PETITION TO INTERVENE -Page2
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 2l days after the
service of its Order. Notice of Application at 3. As a result, this petition to intervene is timely.
6. SWCG was formed to oppose and respond to the proposed rate increase by the
Applicant. 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 and to demonstrate that
the proposed rate increase is not just or reasonable. No other party can adequately represent the
interests of SWCG. 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 SWCG reseryes the right to apply for
intervenor funding pursuant to RP 161-165.
For the foregoing reasons, SWCG's petition should be granted to allow SWCG to intervene
in this matter and fully participate in all aspects of the proceedings regarding the Application filed
by SUEZ Water Idaho, Inc.
DATED this l0th day ofNovember, 2020.
PARSONS BEHLE & LATIMER
-\
By:
Norman M. Semanko
SUEZ WATER CUSTOMER GROUP'S PETIION TO INTERVENE - Page 3
CERTIFICATE OF SERVICE
I hereby certiff that a true and correct copy of the foregoing document was served on the
following on this 10ft day ofNovember,2)2} by the following method:
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
47 2 W est Washington Steet
Boise,Idaho 83702
s e cr e tary@puc. i d ah o. gov
j an. n o riyuki @puc. idaho. gov
U.S. First Class Mail, Postage Prepaid
U.S. Certified Mail, Postage Prepaid
! Federal Express! uana Dehvery
I Electronic Mail or CIWECF
Dayn Hardie
Matt Hunter
Deputy Attorney General
Idaho Public Utilities Commission
47 2 W est Washington Steet
Boise,Idaho 83702
dayt. h ar di e@puc. idah o. gov
mat t. hunt er@pu c. i dah o. gov
E U.S.First Class Mail, Postage Prepaid
E U.S.Certified Mail, Postage Prepaid
Federal Express
Hand Delivery
Electronic Mail or CIWECF
Michael C. Creamer
Preston N. Carter
Givens Pursley LLP
601 W. Barurock St.
Boise,Idaho 83702
mcc @giv ens p urs I ey. c om
p res ton car ter@giv ensp ur s I ey. com
U.S. First Class Mail, Postage Prepaid
U.S. Certified Mail, Postage Prepaid
Federal Express
E Hana Delivery
[l Electronic Mail or CIWECF
DavidNjuguna
Suez Water Management & Services
461 From Road, Suite 400
Paramus, NJ 07052
D avi d. nj u gan a@s u e z. co m
E U.S.First Class Mail, Postage Prepaid
U.S. Certifred Mail, Postage Prepaid
Federal Express
Hand Delivery
Electronic Mail or CI\,{iECF
il!-\
Norman M. Semanko
SUEZ WATER CUSTOMER GROUP'S PETITION TO INTERVENE - Page 4
4845-2860-4369v2