20220425Petition to Intervene.pdf

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HERBERT HEIMERL, ISBN 7849
HEIMERL BEARD ST CLAIR
20 CEDRON RD. SUITE 201
P.O. BOX 499
VICTOR,IDAHO 83455
208.787.0337 . 208.787.0334 FAX
[e-mail]
IN THE MATTER OF THE APPLICATION
OF TETON WATER & SEWER
COMPANIY FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES
FOR WATER SERVICE IN TIIE STATE
OF IDAHO.
REVISED APPLICATION _ MARCH 23,
2022
BEFORE THE
IDAHO PUBLIC UTILTIES COMMISSION
Case No. TTS-W-22-02
TETON SPRINGS HOMEOWNERS
ASSOCIATION, INC. PETITION FOR
LEAVE TO INTERVENE
COMES NOW, Teton Springs Homeowners Association, Inc. ("the HOA"), pursuant to
Rules 72 throtgh 73 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA
31.01.01.72-73), and pursuant to that Amended Application filed on March 29,2022, and Notice
of Application Order No. 35366 filed on April 16, 2022,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:
Teton Springs Homeowners Association, Inc.
c/o Tina Korpi/Grand Teton Property Management
610 West Broadway, Suite 203
Jackson, WY. 83001
2. Copies of all pleadings, production requests, production responses, Commission
orders and other documents should be provided to Herbert Heimerl at:
20 Cedron Road, Suite 201
PO Box 499
Victor,ID 83455
Telephone: [phone]
Email : herb@tetonlawfi rm.com
PETITION FOR LEAVE TO INTERVENE. I
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 Idaho Public Utility Commission (IDAPA 31.01.01.063).
3. Teton Springs Homeowners Association, Inc. is a duly formed and existing not for
profit corporation pursuant to the laws of the State of Idaho.
4. Teton Springs Homeowners Association, Inc. has a direct and substantial interest in
this matter as Teton Springs Homeowners Association, Inc. and its members constitute the vast
majority of the users of the Applicant.
5. Without the opportunity to intervene herein, Teton Springs Homeowners Association,
Inc. would be without any means of participation in this proceeding which may have a negative
impact the ability of Teton Springs Homeowners Association, Inc. residents to have access to
affordable water. If allowed to intervene, Teton Springs Homeowners Association, lnc. will
provide written comments and otherwise fully participate in these proceedings. In addition,
should it be necessary, Teton Springs Homeowners Association, Inc. will appear in all matters as
may be required and appropriate; present evidence; call and examine witnesses; and present
argument.
6. Granting Teton Springs Homeowners Association, Inc. petition to intervene will not
unduly broaden the issues, nor will it prejudice any party to this case.
7. Teton Springs Homeowners Association, Inc. intends to fully participate in this matter
as a party. The nature and quality of Teton Springs Homeowners Association, Inc. intervention
in this proceeding is dependent upon the nature and effect of other evidence in this proceeding.
Teton Springs Homeowners Association, Inc. 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.
WHEREFORE, Teton Springs Homeowners Association, Inc., respectfully requests that
this Commission grant this Petition for Leave to Intervene.
DATED this 25fr day of April,2022.
Herbert Heimerl
By: /s/ Herbert Heimerl
Attorney for Teton Springs Homeowners Association, Inc.
PETITION FOR LEAVE TO INTERVENE.2
CERTIFICATE OF SERVICE
I hereby certiff that on the _ day of April,2022,I served the foregoing documents on
all parties as follows:
Jon Pinardi
Managing Member
Teton Water and Sewer Company, LLC
3940 Grand Steet
Driggs, lD 83422
Telephone: [phone]
Email: tetonws@silverstar. com
tr iCourt efiling
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commissions
11331 W. Chinden Blvd., Bldg. 8, Ste 2014.
Boise, lD 83714
secretary@puc. idaho. gov
tr iCourt efiling
/i/ Herbert Heimerl
Herbert Heimerl
Heimerl Beard St. Clair PA
Attorney for Teton Springs Homeowners Association, Inc.
PETITION FORLEAVE TO INTERVENE- 3