HomeMy WebLinkAbout20190208Suez 1-22 to CAIA.pdfirr[] I ivIL)
Michael C. Creamer (ISB No. 4030)
Preston N. Carter (ISB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise,ID 83702
Telephone: (208) 388-1200
Facsimile: (208) 388-1300
rLqs@. g"i venspu rsl ey. com
prgstoncarter@ gi venspursley. corn
Attorneysfor SUEZ Water ldaho Inc.
[3Gr74] t4525179.4
IN THE MATTER OF THE JOINT
APPLICATION OF SUEZ WATER
IDAHO AND EAGLE WATER
COMPA}.IY FOR THE ACQUISITION
OF EAGLE WATER COMPAI\ry
f [il -8 Fi{ 5: l0
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case Nos. SUZ-W-fE-O2
EAG-W-I8-01
Flnsr PRoDUCTToN REeuEsr or SUEZ
WarBnlo.q,no INc. To CrrrznNs
Ar,r,rrp ron lxrncnrrY AIYD
Accouxtarrr,rry
SUEZ Water Idaho Inc. ("SUEZ") requests that Cidzens Allied for lntegrity and
Accountability (*CAIA") provide the following documents and information by March l,2AL9.
This Production Request is continuing, and CALA is requested to provide additional documents
that it or any person acting on its behalf may later obtain that will augment the documents
produced. Please answer eaeh question, provide the documentation requested, and provide
supporting workpapers (if applicable). Responses must include the name and phone number of
the person preparing the document, the name, location, and phone number of the record holder,
as well as the name of the person who will sponsor the answer at a hearing if needed. IDAPA
31.01.0r .228.
Fnsr PnonucrroN RJeuEsrs oF SUEZ ro CAIA - I
'rf t*lr^rF!.,rLrUlLrll
Request No. L: Please provide copies of any and all organizational documents pertaining
to CAIA, including (without limitation) any and all articles of association, bylaws, resolutions or
minutes, and other documents related to CAIA's participation in this proceeding.
Request No. 2: Please provide the names and business addresses of the officers and
directors of CAIA, indicate whether these persons are customers of Eagle Water Company, and
indicate which schedule or tariff under which they take service.
Request No. 3: Please describe the process by which a person or entity is admitted to
membership in CAIA.
Request No. 4: Please state the total number of persons or entities who are members of
CAIA. Please indicate whether each member is a current customsr of Eagle Water Company and,
if so, under which schedule or tariffthey take service.
Request No. 5: Please state the number of CAIA members that also are members of
another intervenor in this proceeding. For each, please identify which other intervenor the CAIA
member is also a member of.
Request No. 6: Please describe the source of funds by which the activities of CAIA are
supported.
Request No. 7: Please describe, in detail, the factual basis for CAIA's statement in its
Petition to Interuene that CAIA's participation in this case will further its interest "maintaining
high quality water resources." Please provide any and all relevant analyses, studies, or other
documents supporting your answer.
Request No. 8: Please describe, in detail, the factual basis for CAIA's statement in its
Petition to Intervene that CAIA's participation in this case will further its interest "maintaining
FTRSTPRoDUCTToN REeuEsrs or SUEZTo CAIA - 2
local control" of water. Please provide any and all relevant analyses, studies, or other documents
suppofiing your answer.
Request No. 9: Please describe, in detail, the factual basis for CAIA's statement in its
Petition to lntsrvene that thsre are "possible environmental harms stemming from the merger."
Please provide any and all relevant analyses, studies, or other documents concerning any
possible environmental harms that you athibute to the proposed Eagle Water Company asset
acquisition by SUEZ.
Request No l0: Please describe, in detail, the factual basis for CAIA's statement in its
Petition to lntervene that *the outcome of the proceedings regarding the Joint Application could
also impact service to customers." Please provide any and all relevant analyses, studies, or other
documcnts conceming any impacts on seryice to customers that you attribute to the proposed
Eagle Water Company asset acquisition by SUEZ.
Request No. 11: Please describe, in detail, the factual basis for CAIA's staternent in its
Petition to Intervene that "the outcome of the proceedings regarding the Joint Application could
also impact . . . water quality." Please provide any and all relevant analyses, studies, or other
documents concerning any impact to water quality that you attribute to the proposed Eagle Water
Company asset acquisition by SUEZ.
Request No. 12: Please describe, in detail, the factual basis for CAIA's statement in its
Petition to Intervene that "the outcome of the proceedings regarding the Joint Application could
also impact . . . chemical treatments." Please provide any and all relevant analyses, studies, or
other documents supporting your answer.
Request No. 13: Please describe, in detail, the factual basis for CAIA's statement in its
Petition to Intervene that "the outcome of the proceedings regarding the Joint Application could
FIRST PRoDUCTION REQUESTS OF SUEZ TO CAIA - 3
also impact . . . environmental concems." Please provide any and all relevant analyses, studies,
or other documents concerning any impact to environmental that you attribute to the proposed
Eagle Water Company asset acquisition by SUEZ.
Request No. 14: Please describe, in detail, the factual basis for CAIA's statement in its
Petition to lntervene that Eagle Water Company has "many'' customers who "are single parents,
elderly, or living with disabilities on fixed and limited incomes.o'As part of your answer, please
provide an approximate estimate ofthe number of such customers. Please also provide any and
all relevant analyses, studies, or other documents that form the basis of your estimate.
Request No. 15: Please identiff any existing programs or other arangement by which
the City of Eagle can or does provide assistance on water bills to single parents, the elderly,
those living with disabilities; or low-income customers.
Request No. 16. Please state whether CAIA is aware of SUEZ's low-income assistance
programs.
Request No. 17: Please provide copies of all informational materials, pamphlets,
statements, or other communications that CAIA has provided to its members or to the public
regarding the subject matter of this proceeding.
Request No. 18: Does CAIA contend that the phased-in rate increases proposed by
SUEZ in the Joint Application are higher than any rate increases that would be necessary if the
City of Eagle acquired Eagle Water Company? If so, please describe, in detail, the factual basis
for this position and provide any and all relevant analyses, studies, or other documents
supporting this position.
FRST PRoDUCTON TGQUESTS oF SUEZ To CAIA - 4
Requect No. 19: Does CAIA conte,nd that the City of Eagle would not seek to move
water under Eagle Water Company water rights to other portions of the Crty's current or future
service area if the City were to acquire Eagle Water Company?
Request No. 20: Does CALA contend that the Idaho Departnent of Water Resources
does not have juridiction and authority over the place and purpose of the use of the water ridrts
that are currently owned by Eagle Water Company, even if those water rights arc acquired by
SUEZ?
Request No. 21: Does CAIA contend that the City of Eagle would not chlorinate the
water that would be provided to curent Eagle Water Customers if the City were to acquire Eagle
WaterCompany?
Request No. 22: Does CAIA contend that the City of Eagle does not currently chlorinate
the drinking water pnovided to its current customers?
Request No. 22: Please identiff each person or entity that CALA intends to call as a
witness in any technical hearing in this matter. For each, please state the subject matter of their
testimony and provide any documents they considered or relied upon in forming their testimony.
DATED this 8s day of Febnuary, 2019.
SLrEZ Water Idaho Inc.
By:
C. Creamer
Preston N. Carter
Givens Pursley LLP
Anorneysfor SUEZ Water ldaho Inc.
FrRsr PRoDUcrroN REQrrEsm or SUEZ ro CAIA - 5
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8ft day of February,2}l9, a true and correct copy of the
foregoing document was served on the following in the manner indicated:
Diane M. Hanian
Commission Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise,Idaho 83702
IPUC
Brandon Karpen
Sean Costello
Deputy Attorneys General
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise, Idaho 83702
Attorneysfor IPUC
Molly O'Leary
BizCounselor at law
1775W. State St. #150
Boise, D 83702
Counselfor Eagk Water Company
Robert DeShazo
Eagle Water Company, lnc.
188 W. State Street
Eagle,Idaho 83616
Petitioner
N.L. Bangle
188 W. State Street
Eagle,ID 83616
Petitioner
Stan Ridgeway, Mayor
City of Eagle
660 E. Civil Lane
Eagle,ID 83616
Intervenor City of Eagle
Cherese D. Mclain
MSBT Law, Chtd.
7699 W. Riverside Drive
Boise,Idaho 83714
Attorneys for Intervenor City of Eagle
Fnsr PRoDUCTToN REeuEsrs oF SUEZ ro CAIA - 6
I I bvU.S. Mail
t I bV Personal Delivery (Original & 3 copies)
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diane.hanian@puc.idaho.
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sean.costello@puc. idaho. sov
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[X] by E-Mail cdm(@msbtlaw.com
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Sheet, Suit€ 1300
Boise, tdaho 83702
Attorneys for Intentenor Eaqle llater
Customer Group
Abigail R Gemtaine
Deputy City Attomey
Boise City Attorney's Office
150N, Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701 -0500
Attorneysfor Intervenor, City of Boise
James M. Piotrowski
PIOTROWSKI DURAI{D, PLrc
P.O. Box 2864
1020 W. Main Street, Suite 440
Boise,ID 83701
Attorneys for Intentenor Citizens Allied for
Integrity and Accountability
Brad M. Purdy
Attorney at Law
2019 N. 17th Shcet
Boise,ID 83702
Auorney for Community Action Partnership
Association of ldaho
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L
Preston N. Carter
FIRST PRoDUcTIoN REQUESTS oF SUEZ To CAIA . 7