20250103Petition for Leave to Intervene.pdf

RECEIVED
January 3, 2025
IDAHO PUBLIC
JAYME B. SULLIVAN
UTILITIES COMMISSION
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: [phone]
Email: BoiseCijvAttorneykcityofboise.org
mr rg ant6-�cityofboise.org
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF Case No. VEO-W-24-01
VEOLIA WATER IDAHO INC. FOR A CITY OF BOISE CITY'S
GENERAL RATE CASE PETITION FOR LEAVE TO
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 — 31.01.01.73) and, pursuant to that Veolia Water Idaho Inc. Notice of Intent to File
a General Rate Case filed on September 16, 2024; Application filed on November 22, 2024; and
Notice of Application, Notice of Suspension of Proposed Effective Date, Notice of Intervention
Deadline, and Order No. 36420, filed on December 13,2024,hereby petitions the Commission for
leave to intervene herein and to appear and participate as a party, and as basis therefore states as
follows:
1. The name and address of Boise City is:
City of Boise
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 1

150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
2. Copies of all pleadings,production requests,production responses, Commission orders
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: BoiseCi!vAttorney&cityofboise.org
mr rg ant(abcityofboise.org
and
Steve Hubble, Climate Action Senior Manager
Robin Lee-Beusan, Water Resources Program Coordinator
Email: shubble(&cityofboise.org
rleebeusankcityof boi se.org
Pursuant to Order 36420, all parties are to comply with Order No. 35375, issued April 21, 2022,
with all pleadings to be filed with the Commission electronically and they will be deemed timely
filed when received by the Commission Secretary. Service between parties should continue to be
accomplished electronically when possible. Voluminous discovery-related documents may be
filed and served on CD-ROM or a USB flash drive.
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. As of 2023, Boise City has approximately three hundred
twenty (320) municipal operations Veolia accounts and spends roughly five hundred thousand
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 2

dollars ($500,000.00) for potable water within Boise City municipal facilities annually. The
Company is proposing a nineteen, point eighty-four, percent (19.84%) rate increase. This large
rate increase will have an effect on Boise City as a customer, as well as on rate payers across the
community.
5. Without the opportunity to intervene herein, Boise City will 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 matters, and, as is necessary and appropriate,may:present evidence;
call and examine witnesses; present argument; and otherwise participate in these proceedings.
6. Granting Boise City's petition to intervene will not unduly broaden the issues, nor
will there be 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 the 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 3rd day of January 2025.
Mary RUAif
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 3rdday of January 2025 served the foregoing
documents on all parties of record as follows:
Monica Barrios-Sanchez ❑ U.S. Mail
Commission Secretary ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 W. Chinden Blvd., Ste. 201-A 0 Electronic
Boise, ID 83714 ❑ Other:
secretM(&puc.idaho. og_v
Preston N. Carter ❑ U.S. Mail
Morgan D. Goodin ❑ Personal Delivery
Megann E. Meier ❑ Facsimile
Givens Pursley LLP 0 Electronic
601 W Bannock Street ❑ Other:
Boise, ID 83702
prestoncarterk,izivenspursle.
morgan off(& ig venspursle.
memkgivenspursle.
David Njuguna ❑ U.S. Mail
Director-Regulatory Business ❑ Personal Delivery
Veolia Water M&S (Paramus), Inc. ❑ Facsimile
461 From Road, Suite 400 0 Electronic
Paramus,NJ 07052 ❑ Other:
david.njugunakveolia.com
Mary R. Grant,
Deputy City Attorney
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE - 4