20190124Staff 2-8 to Eagle Water.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
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SSIO
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT
APPLICATION OF SUEZ WATER IDAHO AND
EAGLE WATER COMPANY FOR THE
ACQUISITION OF EAGLE WATER COMPANY SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
EAGLE WATER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Eagle Water Company
(Eagle Water) provide the following documents and information as soon as possible, but no later
than THURSDAY, FEBRUARY 14,2019.
This Production Request is continuing, and Eagle Water is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may later
obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Eagle Water is reminded that responses pursuant to
Commission Rules of Procedure must include the name and phone number of the person preparing
the document, and the name, location and phone number of the record holder and if different the
witness who can sponsor the answer at hearing if need be. Reference IDAPA 31.01.01.228.
SECOND PRODUCTION REQUEST
TO EAGLE WATER COMPANY
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CASE NO. SUZ-W-18-02/
EAG-W-I8-01
I JANUARY 24,2019
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO.2: Please provide a copy of the "Original Agreement" between Eagle
Water Company and H2O Eagle Acquisition LLC dated May 14, 2018 as stated on page I under
"Definitive Asset Purchase Agreement".
REQUEST NO.3: Please provide a list of names of current Eagle Water Company
shareholders, date they became shareholders, and the number of shares they own.
REQUEST NO. 4: Please provide a list and detailed descriptions of the near term Eagle
Water Company system upgrades referenced by Robert DeShazo in Section X, on page 4 of the
Application. Within the description, please include any drivers necessitating the upgrade, how the
customer would benefit, and an estimate of the cost.
REQUEST NO. 5: Please provide a detailed description for all capital improvements over
$50,000 made in the last 3 years. Details should include a narrative description of the
improvement, a description of the need(s) driving the capital expenditure, and a breakdown of the
project costs.
REQUEST NO. 6: Please provide a detailed description for all planned capital
improvements exceeding $50,000 in the next 3 years. Details should include a narrative
description of the improvement, a description of the driver(s) for each project illustrating why each
are necessary, a cost/benefit analysis for each project, and a breakdown ofthe project costs.
REQUEST NO. 7: Is Eagle Water Company involved in any lawsuits that may interfere
or affect the acquisition? If so, please provide all information and documentation related to each
lawsuit and how it will affect the acquisition.
REQUEST NO. 8: Are there any liens on any of the assets being acquired by SUEZ
Water Idaho through the acquisition? If so, please provide all information and documentation
related to each lien.
SECOND PRODUCTION REQUEST
TO EAGLE WATER COMPANY 2 JANUARY 24,2019
DATED at Boise, Idaho, this 2|frauyof January 2019.
Lcc*
Sean Costello
Deputy Attorney General
i:umisc:prodreq/suzwl8.2_eagwl8.lsctnc prod req 2 to Eagle Water
SECOND PRODUCTION REQUEST
TO EAGLE WATER COMPANY J JANUARY 24,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24Th DAY OF JANUARY 2019, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
TO EAGLEWATERCOMPANY, N CASE NOS. SUZ-W-I8-02/EAG-W-18-01, By
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GIVENS PURSLEY LLP
601 W. BANNOCK ST.
BOISE,ID 83702
E-MAIL : rncc(g), givenspursley. com
prestoncarter@ gi venspu rsl e.v-. cont
ROBERT DESHAZO
EAGLE WATER COMPANY. INC.
188 W. STATE ST.
EAGLE,IDAHO 83616
E-MAIL: eaglewatercorOqniail.com
MOLLY O'LEARY
BIZCOLINSELOR AT LAW PLLC
1775 W STATE STREET, #150
BOISE ID 83702
E-MAIL : rnol l)r(rDbi zcounseloratiau'.com
MAYOR STAN zuDGWAY
CITY OF EAGLE
660 E CIVIC LANE
EAGLE ID 83616
E-MAIL : srid sewir),(irci typt'eagle. org
sber: grn ann (lci t)'o f ba gl e. or g
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE TD 83702
E-MAIL: bn:purdy(0hotmail.com
MARSHALL THOMPSON
SUEZ WATER IDAHO, INC.
8248 W. VICTORY RD.
BOISE,IDAHO 83709
E-MAIL : rnarshal l. thornrrson{abqqz,.qeltl
N.L. BANGLE
H2O EAGLE ACQUISTION, LLC
188 W. STATE ST.
EAGLE, IDAHO 83716
E-MAIL : nban qle@)h2o-solutionsl lc.net
CHERESE D. McLAIN
MSBT LAW, CHTD.
7699 W RIVERSIDE DR
BOISE ID 83714
E-MAIL: cdrn(a)msbllauqam
JAMES M PIOTROWSKI
PIOTROWSKI DURAND PLLC
I O2O W. MAIN STREET, SUITE 440
PO BOX 2864
BOISE ID 8370I
E-MAIL :,i ames(('Di duni onlaw.com
NORMAN M SEMANKO
PARSON BEHLE & LATIMER
8OO W MAIN STREET, SUITE I3OO
BOISE ID 83709
E-MAIL: [e-mail]:
ecf"(g) p arsons behle. corn
CERTIFICATE OF SERVICE
ABIGAIL R GERMAINE
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
150 N. CAPITOL BLVD.
PO BOX 500
BOrSE ID 83701-0500
E-MAIL : a gennaine(1.)cityotboi se. org
CERTIFICATE OF SERVICE