20240412Petition to Intervene.pdf

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Friday,April 12,20241.45:15 PM
IDAHOPUB IC
UIIIITIES C101VMSg0N
JAYME B. SULLIVAN
BOISE CITY ATTORNEY
MARY R. GRANT (ISB No. 8744)
DARRELL EARLY(ISB No. 4748)
Deputy City Attorneys
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: BoiseCityAttorneykeityofboise.org
mr rg ant(kcityofboise.org
Attorney for Boise City
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CAPITOL WATER Case No. CAP-W-24-01
CORPORATION'S APPLICATION TO CITY OF BOISE CITY'S
INCREASE ITS RATES AND CHARGES FOR PETITION FOR LEAVE TO
WATER SERVICE IN THE STATE OF IDAHO INTERVENE
COMES NOW, the city of Boise City, herein referred to as "Boise City" and pursuant to
Rules 71 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 Application of Capitol Water Corporation to
Increase its Rates and Charges for Water Service in the State of Idaho, filed on March 1, 2024;
and Notice of Application, Notice of Intervention Deadline, Notice of Suspension of Proposed
Effective Date, Order No. 36118, filed on March 22, 2024, hereby petitions the Commission for
leave to intervene herein and to appear and participate as a parry, and as basis therefore states as
follows:
1. The name and address of Boise City is:
City of Boise City
150 N. Capitol Blvd.
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 1

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, Idaho 83701-0500
Telephone: [phone]
Facsimile: [phone]
Idaho State Bar No. 8744
Email: boisecityattorney(kcityofboise.org
mr rraantkcityofboise.org
Pursuant to Order No. 35569, Commission Rules 61 and 62 are 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 Capitol Water Corporation(the"Company") and Boise City is itself
a customer of the Company. Boise City has nine (9) accounts and spends a range of$3700 to
$4700 annually for potable water from the Company for Boise City facilities including the Library!
at Ustick, Fire Department Station #4, Winstead Park, Milwaukee Park, and Spaulding Ranch.
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 2

The Company is proposing a twenty-four, point sixty-one, percent (24.61%) rate increase. This
large rate increase will have a substantial effect on rate payers within 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. If allowed to intervene, Boise City will participate in the proceedings and appear in all
matters 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 Intervene following the seven-day opposition period set forth in IDAPA
31.01.01.075. Boise City also reserves its right to file for intervenor funding, depending upon the
amount of time and resources involved in this matter pursuant to IDAPA 31-01.01.161-165.
WHEREFORE, Boise City, respectfully requests that this Commission grant this
Petition for Leave to Intervene.
DATED this 12th day of April, 2024. _tx^7
Mary R. Grant
Deputy City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 3

CERTIFICATE OF SERVICE
I hereby certify that I have on this 12th day of April 2024, served the foregoing documents
on all parties of counsel as follows:
Monica Barrios-Sanchez ❑ U.S. Mail
Commission Secretary ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 West Chinden Boulevard Q Electronic Means w/Consent
Building 8, Suite 201-A ❑ Other:
PO Box 83720
Boise, ID 83720
secretarykpuc.Idaho.gov
H. Robert Price ❑ U.S. Mail
Capitol Water Corporation ❑ Personal Delivery
2626 Eldorado ❑ Facsimile
Boise, ID 83704 Q Electronic Means w/Consent
info(kcapitolwatercorp.com ❑ Other:
Kathy Stockton ❑ U.S. Mail
2310 W. Lemhi St. ❑ Personal Delivery
Boise, ID 83705 ❑ Facsimile
[e-mail] 0 Electronic Means w/Consent
❑ Other:
Adam Triplett ❑ U.S. Mail
Deputy Attorney General ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 West Chinden Boulevard Q Electronic Means w/Consent
Building 8, Suite 201-A ❑ Other:
PO Box 83720
Boise, ID 83720
[e-mail]
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Mary R. Grant
Deputy City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 4