20221110Petition to Intervene.pdf

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:il?? r{0v t0 PH 3: 02JAYME B. SULLTVAN
BOISE CITY ATTORNEY
MARY R. GRANT (ISB No. 8744)
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: BoiseCityAttorney(@cityofboise.org
mrerant@cityofboise. ore
Attorney for lntervenor
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. VEO-W-22-02IN THE MATTER OF THE APPLICATION OF
VEOLIA WATER IDAHO INC. FOR
AUTHOzuTY TO INCREASE ITS RATES AND
CHARGES FOR WATER SERVICE IN THE
STATE OF IDAHO
CITY OF BOISE CITY'S
PETITION FOR LEAVE TO
INTERVENE
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 Veolia Water tdaho Inc. Application for Authority
to Increase its Rates and Charges for Water Service in the State of Idaho, and Notice of Application
filed on September 30, 2022; and Notice of Application, Notice of Suspension of Proposed
Effective Date, Notice of lntervention Deadline, Order No. 35569, filed on October 20,2022,
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 Boise City is:
CITY OF BOTSE CITY'S PETITION FOR LEAVE TO INTERVENE - I
City of Boise City
150 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701-0500
2. Copies of all pleadings, production requests, production responses, Commission orders and
other documents should be provided to Mary R. Grant at:
Mary R.Grant
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idatro 83701 -0500
Telephone: [phone]
Facsimile: (208) 384 -4454
Idaho State Bar No. 8744
Email: BoiseCityAttorney(dcitvofboise.ors
[e-mail]
Pursuant to Order No. 35569, Commission Rules 6l and 62 arc suspended and all service in this
docket, except for voluminous discovery-related documents, is to be completed electronically. If
the Commission decides to return to hard copy service during this docket, Boise City requests hard
copies of pleadings, testimony, and briefs only. All other production requests, responses, notices,
Commission orders, and other filings may be served on Boise City via electronic mail in
accordance with Rule 63 of the Rules of Procedure of the Idaho Public Utility Commission
(TDAPA 31.0r.01.063)
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 Veolia Water Idaho Inc. (the "Company"), as well as being a
customer of the Company itself. Boise City has three hundred twenty (320) municipal operations
Veolia accounts and spends roughly five hundred thousand dollars ($500,000.00) for potable water
within Boise City municipal facilities annually. The Company is proposing a twenty-tlree, point
CITY OF BOISE CITY'S PETITION FOR LEAVE TO TNTERVENE - 2
four, percent (23.4o/o) 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 maffers 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.
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 lntervene following the seven-day opposition period set forth in TDAPA
31.01.01.075. Boise City also reserves its right to file for intervenor funding, depending upon the
a:nount of time and resources involved in this matterpursuant to IDAPA 31-01.01.161-165.
WHEREFORE, Boise City, respectfully requests that this Commission grant this
Petition for Leave to lntervene.
DATED this 10th day of November2022.
Mary R.Grant
Deputy City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO TNTERVENE - 3
CERTIFICATE OF SERVICE
I hereby certifu that I have on this l0th day of November 2022, served the foregoing
documents on all parties of counsel as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 West Chinden Boulevard
Building 8, Suite 201-A
PO Box 83720
Boise, ID 83720
i an. noriyuki (@puc. idaho. gov
David Njuguna
Manager - Regulatory Business
Veolia Water M&S (Paramus), lnc.
461 From Road, Suite 400
Paramus, NJ 07052
david. nj u euna(d veol i a. c om
Preston N. Carter
Morgan D. Goodin
GIVENS PURSLEY LLP
Attorneys at Law
601 West Bannock Street
Boise, ID 83702
prestoncarter(g) sivenspursley. com
moreaneoodin(a sivenspursley. com
Dayn Hardie
Deputy Attomey General
Idaho Public Utilities Commission
11331 West Chinden Boulevard
Building 8, Suite 201-,4.
PO Box 83720
Boise, D 83720
dalzn. hardi e(rDpuc. i daho. eov
Lorna Jorgensen
Meg Waddel
Ada County Prosecuting Attomey's Office
Civil Division
200 West Front Street, Room 3l9l
Boise,ID 83702
civilpafi les(@adacounty. id. gov
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Mary R. Grant,
CITY OF BOISE CITY'S PETITION FOR LEAVE TO TNTERVENE - 4
Attorney