20041217Petition to Intervene.pdf

c, Ct ' r-
' .
r-
i\ Co. tJ C I \f t.
'""':",
L~~J
f; r-
"-_.
~;f\0
,:-, .
ili~j ; u :",,.1 'V
. ' . ,,: ,; "
' tj Lie
' T r r I r : '~::: (' ('
;~/:.
" I C~(~ IL.iti,..",-"UI!fll....
CARY B. COLAIANNI
BOISE CITY ATTORNEY
Douglas K. Strickling
Assistant City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: dstrickling~cityotboise. org
Idaho State Bar No. 3230
Attorney for Boise City ORIGINAL
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE
IN THE STATE OF IDAHO
Case No. UWI W -04-
PETITION TO INTERVENE BY CITY
OF BOISE CITY
COMES NOW, the City of Boise City, hereinafter referred to as "Intervenor" and
pursuant to the "Notice of Application" issued in the above-captioned case by the Secretary of
the Idaho Public Utilities Commission (Commission) on December 2, 2004, and pursuant to this
Commission s Rules of Procedure, IDAP A 31.01.01.072-073 , by this Petition requests leave to
intervene herein and to appear and participate as a party herein, and as grounds therefore states
as follows:
BOISE CITY'S PETITION TO INTERVENE - Page
The name and address of the Intervenor is:
Boise City
ATTN: Chuck Mickelson
O. Box 500
150 N. Capitol Boulevard
Boise, Idaho 83701
This Intervenor will be represented by:
Douglas K. Strickling
Boise City Attorney s Office
O. Box 500
150 N. Capitol Boulevard
Boise, Idaho 83701
Copies of all pleadings, testimony, exhibits, production requests, production responses
Commission orders and other documents should be provided to the parties identified above.
Boise City is a Municipal Corporation of the State of Idaho. Boise City receives
water utility services from the Applicant. This Intervenor will be affected by this proceeding in
that, if the Applicant's request is granted in whole or in part , it will suffer an increase in its water
rate.
This Intervenor, intends to participate herein as a party, and if necessary, to
introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in
argument. The nature and quality of evidence which this Intervenor will introduce is dependent
upon the nature and effect of other evidence in this proceeding.
4. Without the opportunity to intervene herein, this Intervenor would be without any
BOISE CITY'S PETITION TO INTERVENE - Page 2
means of participation in a proceeding that could have significant impacts on the rates paid by
Boise City as a large municipal water user for future water service.
WHEREFORE, Boise City requests that this Commission grant this Petition to Intervene
in these proceedings and to appear and participate in all matters as may be necessary and
appropriate; and to present evidence, call and examine witnesses, present argument and to
otherwise fully participate in these proceedings.
DATED this I~A day of December, 2004.
BOISE CITY ATTORNEY'S OFFICE
Douglas '. Strickling
Attorne tor Intervenor
BOISE CITY'S PETITION TO INTERVENE - Page 3
CERTIFICA TE OF SERVICE
I HEREBY CERTIFY that I have on this --l1a.ih- day of December, 2004, served a
copy of the Petition to Intervene by Boise City, Case No. UWI-04-04 upon the following
parties of record in this proceeding, by mail a copy thereof, properly addressed with postage
prepaid to the following:
Mark Gennar
United Water
200 Old Hook Road
Harrington Park, NJ 07640-1738
Fax [phone]
~ U.S. Mail
Personal Delivery
Facsimile
Other:
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
PO Box 2564-73701
Boise, ID 83702
Fax [phone]
S. Mail
Personal Delivery
Facsimile
Other:
'-.J
BOISE CITY'S PETITION TO INTERVENE - Page 4