20260624Motion for Limited Exemption.pdf

RECEIVED
June 24, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF SOUTHSHORE 2 WATER COMPANY, LLC'S APPLICATION FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR WATER SERVICE
Case No. SSW-W-26-02
MOTION OF SOUTHSHORE 2 WATER COMPANY, LLC FOR LIMITED EXEMPTION OR DEVIATION
FROM ATTORNEY-REPRESENTATION REQUIREMENT UNDER IDAPA 31.01.01.043.02
Southshore 2 Water Company, LLC ("Company"), by and through its Managing Member, Ryan
Martin, respectfully moves the Idaho Public Utilities Commission ("Commission") for a limited
exemption, deviation, or clarification allowing Mr. Martin to appear, sign filings, respond to
production requests, submit factual information, participate in workshops or customer
proceedings, and otherwise act as the Company's representative in this matter without
requiring the Company to retain licensed counsel for each filing or appearance.
This Motion is made under IDAPA 31.01.01.013, IDAPA 31.01.01.041, IDAPA 31.01.01.043, and
IDAPA 31.01.01.056.
I. FACTS
1. Southshore 2 Water Company, LLC is a small regulated water utility serving fifteen
customers in the Southshore Subdivision No. 2 in Canyon County, Idaho.
2. The Company is managed by Ryan Martin, who is the Company's Managing Member and
the person with direct knowledge of the Company's operations, ownership records,
billing, expenses, maintenance, rate history, customer communications, and regulatory
filings.
3. This proceeding concerns a small water utility rate application. The Company expects
that much of the case will involve factual, accounting, operational, customer-notice,
tariff, and compliance information within Mr. Martin's direct personal knowledge.
4. The Company is not a large utility with in-house counsel or substantial, or any
administrative staff. Requiring the Company to retain counsel for every filing, production
response, Staff communication, workshop, customer hearing, or factual submission

would impose a material burden on the Company and, ultimately, on the small customer
base from which regulated costs must be recovered.
5. Commission materials provided for small water company rate cases state that "[a]ny
officer of the company may represent the company before the Commission" and that
legal counsel maybe retained to represent the company. The Company relied on that
practical guidance in preparing and pursuing regulatory filings before the Commission.
6. The Company does not seek to disregard the Commission's procedural rules. Rather,the
Company seeks a limited order allowing its Managing Member to represent the
Company for purposes of factual, operational, administrative, tariff,discovery-response,
customer-notice, workshop, modified-procedure, and rate-case participation unless and
until the Commission determines that licensed counsel is required for a particular
technical/evidentiary hearing, legal argument, contested motion, or other specific
portion of the proceeding.
II.APPLICABLE IDAPA RULES
7. IDAPA 31.01.01.043.01 recognizes that administrative filings before the Commission may
be made by a natural person pro se, a partner in a partnership, an employee or officer of
a corporation, or a licensed attorney.
8. IDAPA 31.01.01.043.02 provides that representation in quasi-judicial proceedings for the
purpose of adjudicating legal rights or duties is restricted and that a partnership,
corporation, municipal corporation; government agency, unincorporated association,
nonprofit organization, or other entity shall be represented by a licensed attorney.
9. IDAPA 31.01.01.013 provides that the Commission's rules will be liberally construed to
secure the just, speedy, and economical determination of all issues presented to the
Commission and that, unless prohibited by statute, the Commission may permit
deviation from its rules when compliance is impracticable, unnecessary, or not in the
public interest.
10. IDAPA 31.01.01.056 authorizes motions requesting Commission action and requires a
motion to state the facts, refer to the rule or legal authority relied upon, and request the
relief sought.
111. ARGUMENT
11.The Company recognizes that IDAPA 31.01.01.043.02 may apply to certain quasi-judicial
portions of this proceeding. The Company is not asking the Commission to eliminate that
rule or to allow non-attorney legal practice in matters where the Commission
determines counsel is required.

12. However, a limited exemption or deviation is appropriate under IDAPA 31.01.01.013
because strict application of an attorney-representation requirement to every aspect of
this small water utility proceeding would be impracticable, unnecessary, and not in the
public interest.
13. The Company's rate case will require submission of facts, records, workpapers, tariffs,
customer notices, operational explanations, and responses to Staff and party production
requests. Mr. Martin is the person most knowledgeable about those facts. Requiring
counsel to act as the conduit for each factual response would increase cost, slow the,
proceeding, and provide little practical benefit to the Commission, Staff, customers, or
the record.
14. The public interest is better served by allowing the Commission and Staff to obtain
prompt, complete, first-hand information from the Company's Managing Member while
preserving the Commission's authority to require licensed counsel for any specific
portion of the case where legal representation becomes necessary.
15. Granting this Motion would also support the purpose of the Commission's rules under
IDAPA 31.01.01.013 by promoting a just, speedy, and economical determination of the
issues.
16. The requested relief is limited. The Company requests permission for Mr. Martin to act
as the Company's representative in this proceeding for factual, operational,
administrative, discovery-response, tariff, workshop, customer-hearing, modified-
procedure, and compliance matters. The Company understands that the Commission
may later require licensed counsel for technical/evidentiary hearing, contested legal
motion, formal legal argument, settlement document, or any other specific matter the
Commission identifies.
IV. REQUESTED RELIEF
For the reasons stated above, Southshore 2 Water Company, LLC respectfully requests that the
Commission issue an order:
1. Granting a limited exemption, deviation, or clarification under IDAPA 31.01.01.013 and
IDAPA 31.01.01.043 allowing Ryan Martin, Managing Member of Southshore 2 Water
Company, LLC, to act as the Company's representative in this docket;
2. Confirming that Mr. Martin may sign and submit filings, respond to production requests,
communicate with Commission Staff and parties,participate in workshops or customer
proceedings, submit factual information, and file tariff, notice, workpaper, and
compliance materials on behalf of the Company;

3. Providing that this authorization remains subject to any later Commission order
requiring licensed counsel for any specific hearing, contested motion, formal legal
argument, settlement agreement, or other portion of the proceeding; and
4. Granting such other relief as the Commission deems just and reasonable.
DATED this 24th day of June, 2026.
Respectfully submitted,
Ryan Martin
Managing Member
Southshore 2 Water Company, LLC