20250203Petition to Intervene.pdf

RECEIVED
Monday, February 3, 2025
IDAHO PUBLIC
Norman M. Semanko, ISB #4761 UTILITIES COMMISSION
Patrick M. Ngalamulume, ISB #11200
PARSONS BEHLE&LATIMER
800 W. Main Street, Suite 1300
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Marvin Estates Property Owners
Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PRIEST LAKE Case No.: PLW-W-24-02
WATER LLC'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES PETITION TO INTERVENE
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO
COMES NOW, Marvin Estates Property Owners Association, Inc. (hereinafter "Marvin
Estates"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 hereby petitions the Commission for an order granting intervention for
Marvin Estates to become a party and participate fully in the matter of Priest Lake Water LLC's
Application for Authority to Increase its Rates and Charges for Water Service in the State of Idaho;
Case No. PLW-W-24-02 (hereinafter"Application" or"Rate Case").
///
PETITION TO INTERVENE—Page I
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1. The address and Name of the Petitioner is:
MARVIN ESTATES PROPERTY OWNERS ASSOCIATION,INC.
c/o Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
2. Marvin Estates 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
[e-mail]
[e-mail]
[e-mail]
3. Marvin Estates is a nonprofit corporation, formed and duly recognized under the
laws of the State of Idaho. As the Commission has already recognized, the Company currently
serves 72 residential customers in the Marvin Estates Subdivision near Priest Lake, Idaho. Order
No. 36408 at 1; Order No. 36442 at 1. Marvin Estates' members are customers of the Applicant.
Marvin Estates is aiming to oppose and respond to the proposed rate increase by Priest Lake Water
LLC. Marvin Estates and its members stand to be impacted by significant rate increases proposed
in the current Rate Case, as set forth in the Application, which seeks to increase the rate from the
current flat monthly rate of$37 to a flat monthly rate of$98 for residential customers and a flat
monthly rate of $100 for commercial customers. Order No. 36442 at 1. If the Application is
granted as proposed,it will increase the residential rate by 165%and the commercial rate by 170%.
This proposed increase is unjust and unreasonable and threatens to impose considerable "rate
shock" on customers, including Marvin Estates and its members, particularly those who lack the
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financial means to afford the 165%residential rate increase. Marvin Estates and its members have
a direct and substantial interest in the outcome of the Application pursuant to RP 74.
4. Marvin Estates seeks intervention as a full parry,to participate regarding the issues
before the Commission, including those presented by the Application, including all attachments
and exhibits thereto, and in written comments submitted to the Commission. Therefore, Marvin
Estates' 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 not issued an Order for an
intervention deadline. As a result, this petition to intervene is timely filed.
6. Marvin Estates' 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 parry can
adequately represent the interests of Marvin Estates and its members. Marvin Estates' intervention
will not disrupt the proceedings,prejudice the parties, or unduly broaden the issues.
7. In the event intervention is granted, Marvin Estates reserves the right to apply for
intervenor funding pursuant to RP 161-165.
For the foregoing reasons, Marvin Estates' petition should be granted to allow Marvin
Estates to intervene in this matter and fully participate in all aspects of the proceedings regarding
the Rate Case.
DATED this 3rd day of February, 2025.
PARSONS BEHLE&LATIMER
Norman M. Semanko; Patrick M. Ngalamulume
Attorneys for Marvin Estates Property Owners
Association
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3rd day of February, 2025, 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:
Commission Secretary ® U.S. Mail
IDAHO PUBLIC UTILITIES COMMISSION ❑ Facsimile
P.O. Box 83720 ❑ Hand Delivery
Boise, ID 83720-0074 ❑ Overnight Delivery
® Email secretarygpuc.idaho.gov
Sarah B. McOwen ® U.S. Mail
Smith& McOwen, Attorneys at Law ❑ Facsimile
102 Superior Street ❑ Hand Delivery
P.O. Box C ❑ Overnight Delivery
Sandpoint, ID 83864 ® Email sarah(2smithmcowenlaw.com
Priest Lake Water LLC ® U.S. Mail
Jared Horlacher, Owner ❑ Facsimile
279 Tracy Lane ❑ Hand Delivery
Priest Lake, ID 83856 ❑ Overnight Delivery
® Email jaredhorlacher(&,yahoo.com
Norman M. Semanko
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