20250924Petition for Leave to Intervene.pdf

RECEIVED
SEPTEMBER 24, 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: BoiseCityAttomey(ic,cityofboise.org
mr rg ant&cityofboise.org
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CAPITOL WATER Case No. CAP-W-25-02
CORPORATION'S APPLICATION FOR CITY OF BOISE CITY'S
AUTHORITY TO INCREASE ITS RATES AND PETITION FOR LEAVE TO
CHARGES FOR WATER SERVICE IN THE INTERVENE
STATE OF IDAHO
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 the Application of Capitol Water Corporation for
Authority to Increase its Rates and Charges for Water Service in the State of Idaho("Application")
filed on August 14, 2025; and the Notice of Application, Notice of Suspension of Proposed
Effective Date,Notice of Intervention Deadline,and Order No. 36746, filed on September 3,2025,
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, 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: BoiseCityAttomey( ,,cityofboise.org
mr rg antkcityofboise.org
and
Steve Hubble, Climate Action Senior Manager
Robin Lee-Beusan, Water Resources Program Coordinator
Email: shubblegcityofboise.org
rleebeusanAcityofboise.org
Pursuant to Order 36746, 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 Capitol Water Corporation (the "Company). The
Company is proposing a six,point zero zero four percent(6.004%)rate increase. This rate increase
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE -2

will affect rate payers in the community and Boise City would like to better understand the purpose
for the rate case and how it factors into the near and long-term future of the Company.
5. Without the opportunity to intervene herein, Boise City will be without any means
of participation in this proceeding, which may have an 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, 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 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 the right to file for intervenor funding, depending
upon the amount of time and resources involved in this matter,pursuant to IDAPA 31.01.0L161-
165.
WHEREFORE, Boise City, respectfully requests that this Commission grant this Petition
for Leave to Intervene.
DATED this 24th day of September 2025.
Mary R. Gra
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 24th day of September 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:
secretgakpuc.idaho._og_v
H. Robert Price, President ❑ U.S. Mail
Kathy Stockton, Consultant ❑ Personal Delivery
Capitol Water Corporation ❑ Facsimile
2626 Eldorado St. 0 Electronic
Boise, ID 83704-5926 ❑ Other:
infogcapitolwatercorp.c om
waterconsultantklsgemail.com
Michelle Steel,
Paralegal
CITY OF BOISE CITY'S PETITION FOR LEAVE TO INTERVENE -4