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HomeMy WebLinkAbout20240318Petition to Intervene.pdf PETITION TO INTERVENE –Page 1 4860-3882-6668.v2 Norman M. Semanko, ISB #4761 Patrick M. Ngalamulume, ISB #11200 PARSONS BEHLE & LATIMER 800 W. Main Street, Suite 1300 Boise, Idaho 83702 Tel: (208) 562-4900 Fax: (208) 562-4901 Email: nsemanko@parsonsbehle.com pngalamulume@parsonsbehle.com Attorneys for Stoneridge Property Owners Association BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF CDS STONERIDGE UTILITIES, LLC’S APPLICATION FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO Case No.: SWS-W-24-01 PETITION TO INTERVENE COMES NOW, Stoneridge Property Owners Association, Inc. (hereinafter “SPOA” or “Petitioner”), by and through its counsel of record, Parsons Behle & Latimer, pursuant to the Rules of Procedure of the Idaho Public Utilities Commission (hereinafter “RP”), IDAPA 31.01.01 et seq, and Notice of Application; Notice of Intervention Deadline; Notice of Suspension of Proposed Effective Date; Order No. 36116, issued March 13, 2024 (hereinafter “Notice of Application”), and hereby petitions the Commission for an order granting intervention for SPOA to become a party and participate fully in the matter of CDS Stoneridge Utilities, LLC’s Application for Authority to Increase its Rates and Charges for Water Service in the State of Idaho; Case No. SWS-W-24-01 (hereinafter “Application” or “Rate Case”). /// /// RECEIVED Monday, March 18, 2024 11:46AM IDAHO PUBLIC UTILITIES COMMISSION PETITION TO INTERVENE –Page 2 4860-3882-6668.v2 1. The address and Name of the Petitioner is: STONERIDGE PROPERTY OWNERS ASSOCIATION, INC. c/o Parsons Behle & Latimer 800 West Main Street, Suite 1300 Boise, Idaho 83702 2. SPOA 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 Patrick M. Ngalamulume PARSONS BEHLE & LATIMER 800 West Main Street, Suite 1300 Boise, Idaho 83702 NSemanko@parsonsbehle.com PNgalamulume@parsonsbehle.com Boisedocket@parsonsbehle.com 3. SPOA is a nonprofit corporation, formed and duly recognized under the laws of the State of Idaho. SPOA is a customer of the Applicant and its members are also customers of the Applicant. SPOA is aiming to oppose and respond to the proposed rate increase by CDS Stoneridge Utilities (“Stoneridge”). SPOA and its members stand to be impacted by significant rate increases proposed in the current Rate Case, as set forth in the Application. If Stoneridge’s Application is granted as proposed, it will increase the average rate by 261% to be applied to all classes of customers. Notice of Application at 1-2. This proposed increase is unjust and unreasonable and threatens to impose considerable “rate shock” on Stoneridge customers, including SPOA and its members, particularly those who lack the financial means to afford the 261% rate increase. SPOA has a direct and substantial interest in the outcome of the Application pursuant to RP 74. PETITION TO INTERVENE –Page 3 4860-3882-6668.v2 4. SPOA seeks intervention as a full party, to participate regarding the issues before the Commission, including those presented by the Application, including all attachments and exhibits thereto, the Notice of Application, and in written comments submitted to the Commission. Therefore, SPOA’s intervention would not unduly broaden the issues, as required by RP 74. 5. A petition to intervene is timely if it is filed by the time provided by order or notice of the Commission in accordance with RP 73. The Commission has set an intervention deadline of 21 days after the service of its Order. Notice of Application at 3-4. The Order was issued on March 13, 2024. As a result, this petition to intervene is timely filed. 6. SPOA’s intervention will allow for active participation in all aspects of these proceedings, as necessary to protect the interests of the association and its members and to demonstrate that the proposed rate increase is unjust and/or unreasonable. No other party can adequately represent the interests of SPOA. SPOA’s intervention will not disrupt the proceedings, prejudice the parties, or unduly broaden the issues. 7. In the event intervention is granted, SPOA reserves the right to apply for intervenor funding pursuant to RP 161-165. For the foregoing reasons, SPOA’s petition should be granted to allow SPOA to intervene in this matter and fully participate in all aspects of the proceedings regarding the Application filed by Stoneridge. DATED this 18th day of March, 2024. PARSONS BEHLE & LATIMER Norman M. Semanko; Patrick M. Ngalamulume Attorneys for Stoneridge Property Owners Association PETITION TO INTERVENE –Page 4 4860-3882-6668.v2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 18th day of March, 2024, I served a true and correct copy of the foregoing upon each party in this matter by delivering the same to each of the following individuals by the method indicated below, addressed as follows: Michael Duval Deputy Attorney General IDAHO PUBLIC UTILITIES COMMISSION P.O. Box 83720 Boise, ID 83720-0074 U.S. Mail Facsimile Hand Delivery Overnight Delivery Email michael.duval@puc.idaho.gov CDS STONERIDGE UTILITIES, LLC P.O. Box 298 Blanchard, ID 83804 U.S. Mail Facsimile Hand Delivery Overnight Delivery Email chansan@comcast.net utilities@stoneridgeidaho.com DATED this 18th day of March, 2024. Norman M. Semanko