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Home My WebLink About20190208Suez 1-22 to EWCG.pdf]TCT!VED i*i! FIB -8 PH S: tSMichael C. Creamer (ISB No. 4030) Preston N. Carter (ISB No. 8462) Givens Pursley LLP 601 W. Bannock St. Boise,lD 83702 Telephone: (208) 388-1200 Facsimile: (208) 388-1 300 mcc@ givenspursl e)r. com orestoncarter@ gi venspurslev. com Attorneys for SUEZ llater ldaho Inc. Iwt? l t15Xt57L1 IN THE MATTER OF THE JOINT APPLICATION OF SUEZ WATER IDAHO AND EAGLE WATER COMPAI.IY FOR THE ACQUISITION OF EAGLE WATER COMPAI{Y BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case Nos. SUZW-1t-02 EAG.W-I8{1 trhsr PRoDUCTToN Rnerrusr or SUEZ %tnn Iulxo INc. ro Elcr,r Wll'run CusronarnGnoup SUEZ Water Idaho Inc. (*SUEZ') requests that Eagle Water Customer Group ("EWCG") provide the following documents and information by March 1,2019. This Production Request is continuing, and EWCG is requested to provide additional documents that it or any person acting on its behalf may later obtain that will augme,nt the documents produced. Please answer each 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 31.01.01.228. Request No. 1: Please provide copies of any and all organizational documents pertaining to EWCG, including (without limitation) any and all articles of association, bylaws, resolutions or minutes, and other documents related to EWCG's participation in this proceeding. Fnsr PRoDUcrroN REeuEsrs oF SLrEZ To EWCG - I lri Request No.2: Please provide the names and business addresses of the officers and directors of EV{CG, 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 EWCG. Request No. 4: Please state the number of persons or entities who are members of EWCG. Please indicate whether each member is a current customer of Eagle Water Company and under which schedule or tariffthey take service. Request No. 5: Please state the number of EWCG members that also are members of another intervenor in this proceeding. For each, please identify which other intervenor the EWCG member is also a monber of. Request No. 6: Please describe the source of funds by which the activities of EWCG are supported. Request No. 7: Please identi$ the official channels of communication of EWCG. Please indicate, specifically (but without limitation) whether posts made by the Facebook Group named "Eagle Water Customers" are considered communications of EWCG. Request No. 8: Please state whether the flyers attached as Exhibit 1 and Exhiblt2 are official communications of EWCG. Request No. 9: Please state whether board mernbers or officers of EWCG have communicated with Homeowners Associations or similar organizations to request that they refuse to meet with SUEZ to discuss its proposed acquisition of Eagle Water Company assets, or have directed any members of EWCG to make such requests to these organizations. Fnsr PnooucuoN Rrqursrs oF SUEZTo EWCG - 2 Request No. l0: Please provide copies of any informational materials, pamphlets, statements, or other comrnunications that EWCG has published to its members or to the public regarding the subject matter of this proceeding. Request No. 11: Does EWCG contend that the 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. Request No. 12: Please identiff and describe, in detail, the o'other aspects of the public interest" that you contend could be impacted by the Joint Application as stated in EWCG's Petition to Intervene. Please also describe EWCG's position on how the Joint Application would impact aspects of the public interest and provide any and all relevant analyses, studies, or other documents supporting this position. Request No. 13: Has EWCG asserted to its members or to the public that "one of the biggest complaints . . . that existing Suez customers have is the taste (and even the smell) of their water because of all of the chemicals Suez adds to the water?o' If so, please describe, in detail, the factual basis for this assertion and provide all relevant analyses, studies, communications, or other documents supporting this position. Please also identify all persons to whom you attribute such complaints. Request No. 14: Has EWCG asserted that "Suez has a D- rating with the Better Business Bureau and a reputation for extremely poor customer service and maintenance, heavy chemicalization of their water and massive rate hikes in municipalities across the US?" Please see Exhibit 2. If so, please describe, in detail, the factual bases for each of these assertions and FIRST PRoDUCTION TTEQUESTS OF SLIEZ TO EWCG - 3 provide all relevant analyses, studies, communications, or other documents supporting these assertions. Request No. 15: Does EWCG admit that SUEZ Water Idaho Inc.-the Applicant in this proceeding-has an A+ rating with the Better Business Bureau as of February 2019? Request No. 16: Has EWCG asserted that "[w]ater conservation is going to be increasingly important as the Treaswe Valley continues to grow?" If so, please identiff any water conservation measures or programs currently implemented by the City of Eagle or Eagle Water Company. Request No 17: Does EWCG contend that the City of Eagle would not seek to move water under Eagle Water Company water .ights to other portions of the City's current or fufure service area if the City were to acquire Eagle Water Company? Request No. 18: Does EWCG contend that the Idaho Department of Water Resources does not have jurisdiction and authority over the place and purpose of the use of the water.ights that are currently owned by Eagle Water Company, even if those water rights are acquired by SUEZ? Request No. 19: Does EWCG contend that the City of Eagle would not chlorinate the water that would be provided to current Eagle Water Customers if ttre City were to acquire Eagle Water Companf Request No. 20: Does EWCG contend that the City of Eagle does not currently chlorinate the drinking water provided to its current customers? Request No.22: Please identiff each person or entity that EWCG 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. FrRsrPRoDUcTroN REQUESTS OF SUEZ rO EWCG - 4 DATED this 86 day of February,2019. SUEZ Water Idaho Inc. By:/1,e-r,-- Michael C. Creuner Preston N. Carter Givens Ptusley LLP Attomeysfor SUEZ Water ldaho btc. FrRsr PRoDUcmoN REeuEsrs oF SL,EZ To EWCG - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 8ft day of February,2Ol9, 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 Washin gton 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 Auorneysfor IPUC Molly O'Leary BizCounselor at Law 1775W. State St. #150 Boise, D 83702 Counselfor Eagle 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 Fmsr PRooucrroN Rrqunsrs oF SUEZ ro EWCG - 6 [ ] bvU.S. Mail [ ] bV Personal Delivery (Original & 3 copies) t I by Facsimile [X] bV E-Mail secretary(Epuc.idaho.sov diane.hanian(Epuc. idaho. sov [ ] bvU.S. Mail [ ] bV Personal Delivery t I bV Facsimile [X] by E-Mail brandon.karpenfdpuc.idaho. eov sean.:llo6mrc idaho sov [ ] bvU.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile [X] by E-Mail mol I ],(a) bizc ounsel oratlaw. com [x] bvU.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile t I bv E-Mail [ ] bvU.S. Mail t I bV Personal Delivery [ ] bV Facsimile [X] bV E-Mail nbangle(@h2o-solutionsllc.net [ ] bvU.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile [X] bV E-Mail sridseway(a)cityofeaele.ors sb ersmann(E c itvo fea q I e. o rs [ ] bvU.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile [X] by E-Mail cdm(rDmsbtlaw.com NormanM. Semanko Parsons Behle & Latimer 800 West Main Street, Suite 1300 Boise,Idaho 83702 Attorneys for Intervenor Eagle Water Customer Group Abigail R Germaine Deputy City Attorney Boise City Attorney's Office 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 Auorneysfor Interttenor, City of Boise James M. Piohowski PIOTROWSKI DURAND, PLrc P.O. Box 2864 1020 W. Main Street, Suite 440 Boise,ID 83701 Attorneys for Interuenor Citizens Allied for Integrity and A ccountability Brad M. Purdy Attorney at [,aw 2019 N. 176 Street Boise,ID 83702 Attorney for Community Action P artnership Association of Idaho t I bvU.S. Mail t ] bV Personal Delivery I I bV Facsimile [X] bV E-Mail NSemanko(a)I'e'sonsbehle.com ecf@oarsonsbehle.com [ ] bvU.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile [X] by E-Mail aeermainda)cityo fboise. org [ ] bvU.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile [X]bV E-Mail James(rDidunionlaw.com [ ] bvU.S. Mail [ ] bV Personal Delivery [ ] by Facsimile [X] bV E-Mail bmpurdv(rDhotmail.com 14 Preston N. Carter FrRsr PRoDUcrroN ltEeuEsrs oF SUEZ To EWCG - 7 - E.lHEHl+ltlrXr{ E D D ITl A -rr-t -I Eagle's Water - A Vital Community Resource We Can't Afford To Sel! Help us keep it under local control! Sltuatlon: After decades of quality water service Eagle Water Company (EWC) - which serues 4,2fl) Eagle homes and buslnesses - has declded to sellthelr water rfhts and system. Frcnchtsed muhlnadonal foraroflt corporatm Sucz Water ls attempting to purchase thls cruclal utllfi system - with a stated goal being to divert water from Eagh to support proposed northwest Boise bothills development. They intend to fund thls takeover by hlking rates for customem In the impact area by as much as 2fl) - 3fi1%, while also increasing rates for existing Suez customem across the valley. Suez has a reputatlon for poor customer servke, heavy chemlcallzatlon of their water and excessive rate hlkes in municipalltles across the country. A 2010 Food & Water Watch report, " " documents decades of problems resuhing ln several major cities cancelling Suez contracts.January 30 Ea3le Water Customer Group (EWCGI is an unincorporated non-profit association formed specifically to partlclpate in the ldaho Public Utllities Commission (IPUC) process as advocates for malntalnlng localcontrol and stable, affordabh rates fior our most critka! natural rEsource. Thls coalltlon lncludes Eagle resldents and Suez customers across the valley who will be impacted by the projected rate increases as we!!as other cltizens who simply obiect to a foreign compeny coming in to take control of our utlllties strlctly fior profit. Attorney Norm Scmanko has generously agreed to represent EWCG on a contlngency basb through the IPUC process. Thanks to his excelhnt wo*, we have already been granted approvalto lntervene, which ls an lmpoilant flrst step. schedullng conference has been set for the IPUC attorney and staff, and the attorneys for the other parties, lncludlng EWCG. We'll share new derelopments on oul Facebook $oup page as soon as we hear from our attorney. What you can do to help: Submlt wrltten comments to the IPUC detalllng wlry you obfect to Suez buylng EWC and asklng that the IPUC hold a meetlng ln Eagle allowlng publk testimony (enter case number: SUZ-W-18{2) www. ouc. ida ho.sov/forms/casecomment.asox Joln our Facebook page and emal! llst to learn more and keep abreast of developments ln the case. there is strength in numbers and knowledgelwww.facebook.com/srouos/EasleWaterCustomers/ Emall lane Rohllng at lmrohllns@cmall.com to get on our contact list. Gontact loca! medla to tell them what's happenlng and whyyou object and send Op-Ed's and letters to the editor about the sltuatlon in Treasure Valley publications. Donatc to EWCG to support printlng costs, mailings, etc. Donatlons made payablc to Eagle Water Customcr Group can be sent to Janet BuschGrt at 235 W. Floadng Feadrer Rd. In Eagle a a Volunteer: Let us know what other skills & resources you may have to contribute to our efforts. Spread the word to others who may be interested ln pining this growing coalition, a a a a t#'II -ar-I-I Eagle's Water - A Vital Community Resource We Can't Afford To Sell Help us keep it under locdl control! Sltntion: After decade of quality water service Eagle Water Company {EWC} - which serres 4,200 Eagk homes and h:sinesses - has decided to sell their water rights and q,stem. Frenctrbaecd rnultindiosnl tor-proftt oorpcatlm Soa SrbEr is atterngir,rg to purchase this crucial utility system - with a stated goal being to dwert water from Eagle to support pmposed northwest Boise foothills &velopment. They intend to fund this takeorer by hiking rates for ctstdn€rs in the impact area bV as much as 2O0 -:X)096, while also increasirg rates for existing Suez custoraers acrocs the valley. Strez has a D rating with the Better Businese &rreau and a reputation for extrernely poor customer service and rnaintenance, heatry chernicalization of their water and massive rate l$kes in municipalities acroes the US. Eagh WeterCustorner Group (RlrCGl is an unincorporated non-profit association formed specifically to participate in the ldaho Public Utilities Cor-rxnr:ssion (IPUC) proceas as advocates fior maintaining local cmtrol and staUe, affordable rates for our most critical natural resource. This coalition includes Eagle residents and Suez customeE across the valley who will be impacted by the projected rate ancreas€s as rell as other citizens who simply object to a foreign company coming in to take control of our utilities strictly fo'r profit. Attomery l{orm Sa,manh has generously agreed to represent EWCG on a contingency basis through the IPUC process. Thanks to his excellent wsrk, we harre aheady been grarlted apprwa{ to inteflrene, which is an ireportant first step. What you cando to help: toin our Facebook pqe * there 's strength in numbers and thls is the best way to keep up with developnrents as tl'rery occur httos://www.facebook.com/erouos/EacleWaterCustomers/ Subn{t written comm€nts to the lPtlC detailiry why you object to Srrcz buyine EWC and asking that the IPUC hold a rneetlng in Eagb alkxing publk testimony (Case number: SUZ-W-18-02) httos: //www. ouc. ida ho.qov/fo rms/casecom ment.asox a a a a a Contact local media to tellthem what's happening and why you object Write letters to the editor and Op-Ed's about the situation Donate to EWCG to support printing costs, mailings, etc. Donatiom made payabb to Eagle Water Custoracr Granp caa b€ sefit to Janet EusdErt at 235 W. Flo.tint Fdher Rd. in Eagle a a Sittrt up on our oontxt sheet so h€ can keep you informed as *€ move forward Contact Eagle City Council to let them know you sttpport their efforts to buy Eagb Water Company htto://www.citvofeasle.orelFormCenter/Contact-Us-11/Contact-the{itv-59 a a Let us know what other skitls & resources you rnay have to contrribute to our efforts Spread ttre word to others who may be interested in joining this growing coalition