20051201Protest, hearing request.pdf

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CHARLES L. HONSINGER (ISB #5240)
RINGERT CLARK CHARTERED
O. Box 2773
Boise, ID 83702
[phone]
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Attorneys for Protestant
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. B-\?VI (JJ
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INc., TO
AMEND AND REVISE ITS CERTIFICATE
OF PUBLIC CONVENIENCE AND
NECESSITY NO. 143
PROTEST
COMES NOW, the City of Meridian, by and through its counsel, Ringert Clark, Chartered
and hereby states its opposition to United Water Idaho Inc.' s October 21 , 2005 Application to
Amend and Revise its Certificate of Convenience and Necessity No. 143 on file with the Idaho
Public Utilities Commission. This Protest is submitted pursuant to IDAPA 31.01.01.203.
The grounds for this protest are: (1) that the requested changes in United Water Idaho
certificated boundary will result in interference with the water distribution and delivery system
currently under construction by the City of Meridian in the area proposed by United Water Idaho to
be included in its certificated area of boundary; (2) that public convenience and necessity do not
require the construction of a duplicate distribution and delivery system by United Water Idaho in the
same general location as the distribution and delivery system currently being constructed by the City
of Meridian; and (3) that Modified Procedure is inappropriate in this case as it is in the public
PROTEST - Page 1
interest to hold a hearing in this matter.
Protestant requests that a hearing be held in this matter.
Dated this 2 O ay of November, 2005.
RINGERT CLARK, C
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By: Charles L. Honsinger, Attorneys for City of
Meridian
CERTIFICATE OF SERVICE
I certify that on the J bb.-day of November, 2005 , I served copies of this document
including all attachments by U.S. Mail to the following:
Commission Secretary
Idaho Pubic Utilities Commission
O. Box 83720
Boise , ID 83720-0074
Dean J. Miller, Esq.
McDevitt & Miller LLP
O. Box 2564
Boise, ID 83701
Gregory P. Wyatt
United Water Idaho Inc.
O. Box 190420
Boise , ID 83719-0420
Charles L. Honsinger
PROTEST - Page 2