20190319City of Eagle to Suez 1-20.pdf

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B. Newal Squyres (ISB #1621)
Murray D Feldman 0SB # 4097)
Holland & Hart llp
800 W. Main Street, Suite 1750
P.O.Box2527
Boise, ID 83702-2527
Telephone: [phone]
Facsimile: [phone]
Email : [e-mail]
mfeldman@ho I landhart. com
Attorneys for Intervenor City of Eagle
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 COMPAI\Y
CASE NOS. SUZ.W.I8.O2
EAG-W-18-01
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INTERYENOR CITY OF EAGLE'S
RESPONSE TO FIRST PRODUCTION
REQUEST OF SUEZ WATER rDAHO
INC.
The City of Eagle ("City") provides the following responses to the First Production
Request of SUEZ Water Idaho Inc. to the City of Eagle dated February 8, 2019.
As applicable to all of the following responses, the City notes that discovery in these
proceedings is just beginning. The City reserves its right to update, revise, correct, or
supplement these responses, including the identification of a sponsoring witness to testiff at the
hearing in these matters on any particular item, prior to the hearing and pursuant to any schedule
for the hearing and pre-hearing matters to be adopted by the Commission and entered in these
cases
Additionally, many of the requests in this First Production Request seek responses as to
what the City may do or intends to do based on future contingent events. The City, as a local
government entity in the State of Idaho, cannot establish public policy or make a substantive
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST. 1
decision in the present context of discovery responses in an administrative proceeding. The
City's responses to these requests in such situations as to future possible steps are necessarily
limited by the requirements for the City to take legislative action in a deliberate and public
proc€ss pursuant to regular prooedures and applicable law. Those matters of municipal
governance cannot be determined or made in the context of responses to a production request.
Also, in some instances the production requests are based on or seek information
conceming the statements of individual City Council members or City employees. However, the
statements of individual Council members do not necessarily represent the position or past or
intended decision of the City or City Council as a whole, and the same limitation applies to any
statements of individual City employees.
DATED this l5th of March,2019.
City of Eagle
D.
HOLLAN & HART r,r.p
Attorneysfor Intervenor Cily of Eagle
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 2
By 3
CITY OF EAGLE
CASE NOS. SU7-W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Stan Ridgeway, Mayor, City of Eagle
REQUEST NO. 1: At a January 22,2019 regular meeting of the Eagle City Council,
City Councilwoman Miranda Gold stated that "[t]he City's position through intervening with the
PUC has been that we want to purchase, the City wants to purchase the system." Please describe
what [sic] means or mechanism the City would use to finance the purchase of the Eagle Water
Company system.
RESPONSE TO REQUEST NO. 1: Subject to the foregoing stated limitations and
constraints applicable to these responses, if the City has an opportunity to purchase the Eagle
Water Company system, it might use any of the financing means or mechanisms identified in the
right of first refusal contained in the July 12,2008 Intertie Agreement between the City and
Eagle Water Company (seeParagraph 6 in Ex. 1 to judicial complaint submitted as attachment to
the City's Notice of Filing In Related Judicial Proceeding, filed in these PUC proceedings on
February 27,2019).
The financing options potentially available to the City would be similar to those available
to other municipal governments in the State of ldaho, including the Idaho Department of
Environmental Quality's Clean Water Revolving Loan Fund, the Water Infrastructure Finance
and Innovation Act (WIFIA), or the Idaho Bond Bank.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 3
CITY OF EAGLE
cAsE NOS. SU7-W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Stan Ridgeway, Mayor, City of Eagle
REQUEST NO. 2: At a January 22,2019 regular meeting of the Eagle City Council,
City Councilman Sean Bastian stated that
When the City of Eagle becomes an owner [of Eagle Water Company] the rates
will go up some. And what we could do is somehow divide the rates between
what we have in the City of Eagle and Eagle Water Company and somehow the
current rates in the City of Eagle could go down and the existing rates in the Eagle
Water Company could go up and there would be a kind of averaging of the costs.
That's probably what's likely to happen if we were able to purchase Eagle Water
Company.
With reference to the statement of Councilman Bastian quoted above, please describe in detail
the rates, charges, and/or fees would [sic] that current customers of Eagle Water Company would
pay to the City for water service if the City were to acquire Eagle Water Company. Please
provide any and all relevant analyses, studies, or other documents supporting your answer.
RESPONSE TO REQUEST NO.2: Subject to the foregoing limitations and
constraints, the City does not have a contemporary quantitative estimate of the rates, charges,
and/or fees that current customers of Eagle Water Company would pay to the City for water
service if the City were to acquire Eagle Water Company. As a general matter, the rates
currently paid by City of Eagle water customers and those paid by Eagle Water Company
customers are different. If the City were to acquire Eagle Water Company, the rates paid by all
users of an integrated City of Eagle municipal water utility would be similar for the same class of
customer (i.e. residential, industrial, business, etc. depending on the size of the water connection
and amount of consumption). No rates have yet been set or determined at this time for either
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST.4
what would be new City of Eagle municipal water utility customers or pre-existing and
continuing City of Eagle municipal water utility customers.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST.5
CITY OF EAGLE
CASE NOS. SU7,-W-18-02/EAG-W-1 8-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Ken Acuff, Superintendent, City of Eagle Water Department
REQUEST NO.3: With reference to the statement of Councilman Bastian quoted in
Request No. 2 above, please describe in detail the rates, charges, and/or fees that current
customers of the City of Eagle would pay for water service if the City were to acquire Eagle
Water Company. Please provide any and all relevant analyses, studies, or other documents
supporting your answer.
RESPONSE TO REQUEST NO.3: Subject to the foregoing limitations and
constraints, see Response to Request No. 2.
crTY oF EAGLE',S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 6
CITY OF EAGLE
CASE NOS. SUZW-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Ken Acuff, Superintendent, City of Eagle Water Department
REQUEST NO. 4: Please describe in detail any capital investments, upgrades, or other
changes that the City has identified would need to be made to Eagle Water Company's system
and estimated costs to implement if the City were to acquire it. Please provide any and all
relevant analyses, studies, or other documents the City has developed or obtained in connection
with any efforts at any time to acquire Eagle Water Company or its assets.
RESPONSE TO REQUEST NO. 4: Subject to the foregoing limitations and
constraints, the City has not yet had the opportunity to inspect all of the Eagle Water Company
system and has not had the opportunity to form a basis of understanding of detailed needs for
capital investments, upgrades, or other changes that would need to be made to the Eagle Water
Company system or to develop a detailed cost estimate to implement the same.
The City is generally aware of some existing limitations and inefficiencies in the present
Eagle Water Company system. Improvements may need to be made in the following general
areas to the Eagle Water Company system:
o Modern customer meters and meter reading technology;
o New booster stations, communications, and control systems for major plant facilities,
and electrical control equipment;
. Upgrades to existing well pump motors, mechanical pumping, and well facilities;
o Tie in to existing City of Eagle municipal water system and distribution system
interconnections (see, e.g., City Response to First Production Requests of the
Commission Staff, Response to Request No. 2 and attached map (Feb. 25,2019));
cITy oF EAGLE',S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 7
a Following inspections and appropriate determinations made during a due diligence
period and inquiry:
o Service line upgrades;
o Meter box upgrades;
o Addressing undersized or aging water mains.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST. S
CITY OF EAGLE
cAsE NOS. SUZ.W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER rDAHO rNC.
Preparer/Sponsoring Witness: Ken Acuff, Superintendent, City of Eagle Water Department
REQUEST NO. 5: Please describe in detail the options available to the City to finance
any capital investments, upgrades or other changes identified in response to Request No. 4 above
and who would pay for such financing?
RESPONSE TO REQUEST NO. 5: Subject to the foregoing limitations and
constraints, see Response to Request No. L
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST.9
CITY OF EAGLE
cAsE NOS. SUZ-W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Ken Acuff, Superintendent, City of Eagle Water Department
REQUEST NO. 6: Does the City intend to change the currently authorized place of use
of any water right currently owned by Eagle Water Company if the City were to acquire Eagle
Water Company? Please describe any such actions in detail, and provide any relevant supporting
documents.
RESPONSE TO REQUEST NO. 6: Subject to the foregoing limitations and
constraints, the City recognizes that if it should acquire Eagle Water Company that both the
present Eagle Water Company and City of Eagle water rights may require administrative
updating, consistent with Idaho Department of Water Resources procedures and statutory and
regulatory provisions, to revise the place of use for both systems' water rights to include all of
the service area of an integrated and expanded City of Eagle municipal system.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 10
CITY OF EAGLE
CASE NOS. SUZ.W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Ken Acuff, Superintendent, City of Eagle Water Department
REQUEST NO. 7: Please describe, in detail, how the City of Eagle would resolve Eagle
Water Company's current peak hour demand shortfall under the Company's existing water right
portfolio identified atpage 5 of the Direct Testimony of SUEZ witness Cathy Cooper if the City
were to acquire Eagle Water Company.
RESPONSE TO REQUEST NO. 7: Subject to the foregoing limitations and
constraints, the City of Eagle does not agree at this time that there is an actual-as opposed to
hypothetical, theoretical, or calculated----current peak hour demand shortfall under the Eagle
Water Company's existing water right portfolio. In a combined Eagle Water Company and City
of Eagle municipal water system, the City would have adequate water resources available,
including a storage tank/reservoir, to meet peak hour demands if such resources are necessary
based on the City's review following acquisition and combination of the two water systems.
cITy oF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 11
CITY OF EAGLE
cAsE NOS. SUZ"W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Stan Ridgeway, Mayor, City of Eagle
REQUEST NO. 8: Please describe any discussions or meetings the City has had with
any third party, including staff of the Public Utilities Commission, regarding the City's possible
acquisition of Eagle Water Company, or any discussions or meetings concerning any
arrangement under which Eagle Water Company would provide water or other services to the
City of Eagle. Please include the dates, times and locations where such discussions or meetings
occurred and the names of all persons who were in attendance.
RESPONSE TO REQUEST NO. 8: Subject to the foregoing limitations and
constraints, on approximately March 1,2018, Mayor Stan Ridgeway, counsel Cherese Mclain,
engineer Mike Davis of HECO Engineers, and Norm Bangle, met with PUC staff regarding the
City's possible acquisition of water resources from Eagle Water Company. This meeting took
place with Idaho PUC staff at the offices of the Idaho Public Utilities Commission.
Other discussions or meetings are referenced in the documents to be provided in response
to Request No. 10.
CITY OF EAGLE',S RESPONSE TO SUEZ'S FrRST PRODUCTION REQUEST - 12
CITY OF EAGLE
CASE NOS. SUZ-W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Stan Ridgeway, Mayor, City of Eagle
REQUEST NO. 9: Please provide any document the City of Eagle or its
Councilmembers, Mayor, or other officers have made, drafted, or released regarding any
proposed or potential acquisition of Eagle Water Company by the City of Eagle.
RESPONSE TO REQUEST NO. 9: Subject to the foregoing limitations and
constraints, see Response to Request No. l0 where the scope of Request No. l0 encompasses
this Request No. 9.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST. 13
CITY OF EAGLE
CASE NOS. SUZ-W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAIIO INC.
Preparer/Sponsoring Witness: Stan Ridgeway, Mayor, City of Eagle
REQUEST NO. 10: Please provide any documents (including communications) the City
of Eagle or its Councilmembers, Mayor, or other offrcers have created, drafted, or provided
among themselves or to the public regarding the proposed acquisition of Eagle Water Company
by SUEZ or the by the City.
RESPONSE TO REQUEST NO. 10: Subject to the foregoing limitations and
constraints, and as agreed between counsel for the City and SUEZ, documents responsive to this
Request No. l0 will be provided in a supplemental response to this request.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST. 14
CITY OF EAGLE
cAsE NOS. SUZ,W-18-02/EAG-W-I8-01
FrRST PRODUCTION REQUEST OF SUEZ WATER IDAHO rNC.
Preparer/Sponsoring Witness: Ken Acuff, Superintendent, City of Eagle Water Department
REQUEST NO. 11: Please describe all programs the City has to assist those of its water
customers who have low or fixed incomes in paying their water bills.
RESPONSE TO REQUEST NO. 11: Subject to the foregoing limitations and
constraints, none at this time.
cITy oF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 15
CITY OF EAGLE
CASE NOS. SUZ,W-18-02/EAG-W-18-01
FrRST PRODUCTTON REQUEST OF SUEZ WATER rDAHO rNC.
Preparer/Sponsoring Witness: Ken Acuff, Superintendent, City of Eagle Water Department
REQUEST NO. 12: Please describe all water-conservation programs the City has with
respect to its provision of water service to the City's water customers.
RESPONSE TO REQUEST NO. 12: Subject to the foregoing limitations and
constraints, the Eagle City Code requires a separate source of irrigation water for all new homes
and developments.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 16
CITY OF EAGLE
CASE NOS. SUZ"W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Ken Acuff, Superintendent, City of Eagle Water Department
REQUEST NO. 13: Please state whether the City currently uses chlorine or other
chemicals to treat the drinking water it provides to the City's water customers and whether the
City would disinfect drinking water it provides to its water customers if it acquired the Eagle
Water Company system.
RESPONSE TO REQUEST NO. 13: Subject to the foregoing limitations and
constraints, the response to part one is yes, and the response to part two is that it depends on the
quality of the water produced from the current Eagle Water Company wells and where that water
would flow in an integrated system. At this time, the City's goal would be that any treatment of
water produced from the present Eagle Water Company wells would be managed to balance the
maintenance and protection of water quality with the requirement to meet regulatory standards
for a public drinking water supply system.
cITy oF EAGLE',S RESPONSE TO SUEZ',S FIRST PRODUCTION REQUEST - 17
CITY OF EAGLE
CASE NOS. SUZ-W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Stan Ridgeway, Mayor, City of Eagle
REQUEST NO. 14: Please confirm that the document attached as Exhibit No. I
(entitled "Water Rate Study Report") is a documents [sic] developed, obtained or created at the
request of, or funded by, the City of Eagle.
RESPONSE TO REQUEST NO. 14: Subject to the foregoing limitations and
constraints, yes. See also attached document of the City's task order to HECO Engineers for the
referenced study.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 18
TASK ORDER REQUEST FOR
CITY OF EAGLE ENGINEERING SERVICES
City Task Oder No*--1frQ!
Eagle Water Department Rate Analysis, 1&0058A
THIS TASK ORDER, entered into between the Gity of Eagle, herelnafier refened to as EAGLE, and
Holladay Engineering, City Engineer, hereinafter refened
provisions of the Agreement for Engineering Services, City
27.2O1O , hereinafter refened to as the AGREEMEiIT.
to as HOLI-ADAY, ls subJed to the
Engineering SeMces dated Oc'tober
WTNESSETH:
WHEREAS. EAGLE intends have HOLIJDAY undertake work as follows:
Perform a Water Rate Analysis based on the information gathered in the 2015 Water Master Plan,
and upon any ufiated budget and rate information provided by the Eagle Water Deparhent.
Prepare a summary Rate Report with recommendalions for rate adjustments.
A detailed Scope of Work outline is attached as Exhibit A.
ClrY OF EAGLE INFORIATION Ai.IO RESPONSIBILIIIES:
EAGLE will provide to HOLI-ADAY the data and/or servioes specified in the AGREEMENT.
EAGLE shallbe represented by Ken Acuff, Water Department Diredor.
SCHEDULE OF SERVICES TO BE PERFORMED:
HOLLADAY will perform said services within 90 calendar days of the date of this TASK
ORDER.
FEES AND BILLING SCHEDULE:
EAGLE will pay HOLIADAY for seMces on the basis of:
A Lump Sum amount of $6,500, per the quote from Augusl 14,2015 in a Water Department
meeting on master planning, budgets, capital improvement planning, and possible rate issues for
operations and maintenance.
lN WTIIESS WHEREOF, the parties hereto have executed this TASK ORDERAGREEMENT
as of the day and yearfirst above written.
llPage
CigEagle_00001
OWi{ER: City of Eagle
616 E. Civic Lane
Eagle, ldaho 83616
CITY EI{GINEER: Hotladay Engineering Co.
32 N. Main Street
Payette, lD ffi66f
ctw
By:/l4r;t*,1 A. darA
Ken Acufi, Director MichaelW. Davis, PE, City Engineer
Date:0-A4- lU Date: ?-(1'16
ATTEST:
City
2tPage
CityEagle_00002
CITY OF EAGLE
CASE NOS. SUZ-W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Stan Ridgeway, Mayor, City of Eagle
REQUEST NO. 15: Has the City of Eagle adopted or implemented any of the changes
recommended in the Water Rate Study Report attached as Exhibit I ? If so, please provide the
relevant document adopting or implementing the change or changes.
RESPONSE TO REQUEST NO. 15: Subject to the foregoing limitations and
constraints, yes.
The changes implemented were to the base rate charged for City of Eagle municipal
water system customers. The change was adopted in City of Eagle City Council Resolution No.
17-31, which is publicly available from the City's website or from the City Clerk's office, and a
copy of which is attached together with Resolution No. 17-23. The changed base rate was
implemented as a four-phase increase, with the first increase becoming effective on January l,
2018, the second increase on October 1,2018, the third increase scheduled to take effect on
October 1,2019, and the fourth phased increase to take place on October 1,2020.
cITy oF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 19
RESOLUTTON t{O. 17-3r
A RESOLUTION OF THE CITY COUNCIL OF THE CTTY OF EAGLE. ADA COUNTY, IDAHO,
ESTABLISHING CITY WATER SYSTEM CUSTOMER BASE RATE CHARGES. AND PROVIDING
AN EFFECTIVE DATE.
WHEREAS, the City of Eagle, Ada County, ldaho (the'Ot/), ls a munldpal corporatlon
dulyorganized and openating underthe laws of tho Slab of ldaho; and
WHEREAS, tho City Coundl of the CIty of Eqh ls authorized by Sec{ions 6+9 and 6S
24, Eagle City Cods, to eetablbh uater user cfiargres for the Oty of Eagle rvater systcm; and
WHEREAS, the water user cfrarges set forth herein are rcasonable ard roflect, as closely
as roasonably possible, the costs aseoclated wlth the actualoperaUon, expanslon, maintenance,
replacement, financlng expens€s and the totalwater usag€ pertalnlng to the Ci$'s water system
pursuant to Sec-tlons 6-$9 and 6-524, Eagle Oty Code; and
WHEREAS, the proposed cfianges ref,ect an hcrrase of lGi% or more and the Oty
Coundl of Eagle hEs choeen to phase the lncrcase ovBr a pGriod of four budgst yearc; and
WHEREAS, a public hearing, duly noticed as required by law, was held on Decembdr 12,
2017, for consideration of increaslng water user charges.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF EAGLE, ADA
COUNTY, lDAllO, as follows:
Secdion 1: That, pursuant to Eagle City Code. the Eagle City Council hereby establishes the
follouing water user charges for the base monthly fee as shown ln Exhibit A:
Section 2: The actiw customer of record shall be billed monthly the base rate, the water
safety fee, the system enhanoement fee, the volume charge and other additional feas as are
pertinent to the seMces rcceived. The volume charge is based on all metered vuater for the bllling
period. The base rate wlll be prorated whenetor the customer has not been a customer for the
entire bllling podod.
Section 3: When no active customer of record is being bllled, lhe owner of the property
shall be billed monthly the unoccupied dwelling rate.
SecUon 4: This resolution shalltake efiecil and be in force from and after its passaga and
approval.
DATED this LA "I\day of Dt ,. c ,nYatrzol7.
ATTEST:
OF CIW OF EAGLE
Ada County, ldaho
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Exhlbit A- lncrease illonthly Base RaEforWater Usage Customers
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Cunent Monthly Bage Ratc lu a74' Bcrvlco, E9.60
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RESOLUflOITI NO. l7-2?
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EAGLE, ADA COUNTY,
IDAHO, ESTABLISHING CITY WATER SYSTEM CUSTOMER CHARGES AND
VOLUME CHARGES, AND PROVIDING AN EFFECTIVE DATE.
WHEREAS, the Og of Eagle, Ada Coun$, ldaho (the "Oty"), ls a munlcipal
orporaUon duly organized and operatlng under the laws of the State of ldaho; and
WHEREAS, the City Gouncil of the Glty of Eagle is authorized by Sections 6-$9
and 6-*24, Eagle City Code, to establish water user charges for the Clty of Eagle water
system:and
WHEREAS, the fees set forth hereln are reasonable and reflec-t, as closely as
reasonably possible, the costs associated with the ac{ual operation, expansion,
maintenance, replacement, financing exponses and the totalwater uaeg6 pertraining to the
City's water system pursuant to Sections &$9 and &$'24, Eagle City Code; and
WHEREAS, the proposed fee sctredule ctanges reflect less than a 5% increase.
NOW. THEREFORE, BE IT RESOLVED BY THE C]TY COUNCIL OF THE CITY OF
EAGLE, ADA @uNTY, IDAHO, as tullowr:
Sec'tion 1: That, pursuant to Eagle Clty Code, the Eagle Gity Councilheraby
establishes the bllowing water user ctrarges as shoum ln Exhlblt A:
Section 2: The ac{iw customer of record shell b6 billed monthly the base rate, the
water safety fee, the system enhancement fue, the vdume clrarge and other addltlonal
fees as are pertlnent to the services reoeh€d. The volume cfiarge is based on all metered
nrater for the bllling period. The base rate will be prorated whenewr the q.ptomer has not
been a customerfor the enUre billing perbd.
Section 3: When no active customer of record is being billod, the orner of the
property shall be bllled monthly the unoccupied duelllng rate.
Section 4: This resolutlon shall take efiect and be ln force from and after lts
passago and approval.
DATED this . /o19- day of S. te*rV.'lOtt.
aaraa..
Ea CITY OF EAGLE
Ada County, ldaho
Stan , Mayor
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CityEagle_00006
CITY OF EAGLE
CASE NOS. SUZ-W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Kellie Rekow, Utility Billing Supervisor, City of Eagle Water
Department
REQUEST NO. 16: Please describe any loan(s) or other obligation(s) the City of Eagle
has incurred or assumed to fund any part of its water system. For each, please describe the
principal amount of the loan(s) or obligation(s), the current principal balance(s), the term of the
loan(s)/obligation(s), the applicable interest rate(s), all other material commercial terms, and
when the loan(s) or obligation(s) are expected to be paid off.
RESPONSE TO REQUEST NO. 16: Subject to the foregoing limitations and
constraints, the City of Eagle has one outstanding loan from the Idaho Department of
Environmental Quality (DEQ) for the City of Eagle's municipal water system. The amount of
the loan is $2,590,000. It is 2}-year loan at 3.25 percent interest per annum with no prepayment
penalty. The first payment on the loan was made by the City on October 30,2012, and the City
has been making two payments per year. As of October 30,2018, the remaining balance is
$1,811,785.02. The loan is scheduled to be paid in full by October 30,2031. See also attached
DEQ Loan Ledger document (Mar. 13, 2019).
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 20
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CITY OF EAGLE
cAsE NOS. SUZ,W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Ken Acuff, Superintendent, City of Eagle Water Department
REQUEST NO. 17: With reference to any loan or other obligation identified in your
response to Request No. 16 above, please state how the funds to satisff the repayment are
collected by the City.
RESPONSE TO REQUEST NO. 17: Subject to the foregoing limitations and
constraints, funds to satisff the repayment of the DEQ loan are collected by the City through its
monthly water bills to City of Eagle municipal water utility customers. The loan repayment is
listed as a separate line item on those invoices. The line item amount, per month, for the DEQ
loan for a base residential customer for the City of Eagle municipal water system is $10.93. ^See
generally HECO Engineers study report attached to SUEZ's First Production Request to the
City, Study Report at2,8,9, App'x A & n.3, App'x C at3.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST.2l
CITY OF EAGLE
CASE NOS. SUZ"W-18-02/EAG-W-18-0 I
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Stan Ridgeway, Mayor, City of Eagle
REQUEST NO. 18: If the City of Eagle acquires Eagle Water Company, will the
current customers of Eagle Water Company be required to pay for any part of the City of Eagle's
current outstanding loans or obligations identified in your response to Request No. l6 above?
RESPONSE TO REQUEST NO. 18: Subject to the foregoing limitations and
constraints, the amount to be paid by current customers of Eagle Water Company for any
outstanding loan amount has not yet been determined.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 22
CITY OF EAGLE
CASE NOS. SUZ-W-18-02/EAG-W-18-01
FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC.
Preparer/Sponsoring Witness: Stan Ridgeway, Mayor, City of Eagle; Kellie Rekow, Utility
Billing Supervisor, City of Eagle Water Department
REQUEST NO. 19: During his February 7,2019 "State of the City" address to the
Eagle Chamber of Commerce, the City's Mayor asserted that the average monthly bill for
customers that take water from the City was $31.50; that the average monthly bill for customers
that take water from SUEZ was $42.34; and that the average monthly bill for customers that take
water from Eagle Water Company was $7.84 + consumption. Please describe, in detail, the
factual bases for each ofthese assertions. Please provide any and all relevant analyses, studies,
spreadsheets, work papers or other documents related to your answer.
RESPONSE TO REQUEST NO. 19: The City objects to this request as it
mischaracterizes statements made during the referenced "State of the City" address. Subject to
the foregoing limitations and constraints, and notwithstanding this objection, the Mayor did not
assert during that presentation that current average monthly billings for the customers of various
water suppliers in the City of Eagle were as stated in this request. Instead, according to the
transcript of the referenced State of the City presentation, available at
https://www.cityofeagle.org/DocumentCenter/Viewll42llState-of-the-City-2019-Transcript-
PDF, the Mayor stated that: "In March of 2017 at the state of the city we discussed Domestic
Water Services in Eagle. On the screen is a copy of the slide used to outline water companies
and customers." The attached PowerPoint slide was displayed at the time the text in the
transcript was presented.
The development of the information in that slide for 2017 average monthly bill levels was
developed by the Cify of Eagle's Water Department billing staff using information for SUEZ
CITY OF EAGLE'S RESPONSE TO SUEZ',S FIRST PRODUCTION REQUEST - 23
customers from the SUEZ tariff on file with the Idaho Public Utilities Commission. The average
monthly bill amount for City of Eagle municipal water customers was determined from the
City's billing records for such customers. The average monthly bill for Eagle Water Company
customers was taken from information provided by Eagle Water Company in its annual brochure
of operations and rates. Copies of the SUEZ tariff, the Eagle Water Company brochure, and the
City resolution setting City water customer rates at the time these estimates were prepared are
attached to this response.
CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST.24
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RESOLUTTON r{O. 16-24
A RESOLUTION OF THE CITY COUNCIT OF THE CITY OF EAGLE, ADA COUNTY,
IDAHO, ESTABLISHING CITY WATER SYSTEM CUSTOMER CHARGES AND
VOLUME CHARGES. AND PROVIDING AN EFFECTIVE DATE.
WHEREAS, the City of Eagle, Ada County, ldaho (the'City'), is a municipal
corporation duly organized and operating under the laws of the State of ldaho; and
WHEREAS, the City Councll of the City of Eagle is authorized by Sec-tions S5-9
and 6-S24, Eagle City Code, to establish water user charges forthe City of Eagle water
system; and
WHEREAS, the fees set forth herein are reasonabte and reflect, as closely as
reasonably possible, the coets associated with th€ actual operation, expansion,
maintenance, replacement, financing expenses and the total water usago pertainlng to the
Crty's watsr system pursuant to Seciions 6€-9 and 6-5-24, Eagle City Code; and
WHEREAS, the proposed fee schedule oharges rellec{ less than a 5% increase.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF
EAGLE, ADA COUNTY, IDAHO, as follows:
Section 1: That, pursuant to Eagle City Code, the Eagle City Council hereby
establishes the folloring water user charges as shown in Exhibil A:
Section 2: The ac{ive customer of record shall be billed monthly the base rate, the
water safety fee, the system enhancement fee, the volume charge and other additional
fees ag are pertinent to the services received. The volume charge is based on allmetercd
water for the billing period. The base rate will be prorated whenever the customer has not
been a customer for the entire billing period.
Seclion 3: When no ahive customer of record is being billed, the owner of the
property shall be billed monthly the unoccupied drelling rate.
Section 4: This resolution shalltake effed and be in force from and after its
passage and approval.
DATED this J?A day ofA,fuk-,2016.
CITY OF EAGLE
Ada County, ldaho
Stan
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Sheet No. 3
Replacing all Previrus Sheets
SUET WATER IDAHO INC.
roAHo PuBLtc UT|LIT|ES COtI|ISSIONApprovcd Elfec{ive
Dcc, 16, 2015 Dcc. 22,2015
Per O.ll. 33't36
Jean D. Jcwell Secretary
SCHEDULE NO. 1
GENERAT TIETERED SERVICE
Availability: To all mebred c.ustorners nd served under a separate schedule.
Cusmer Charges: HHH
Itileter Sze Charge
trlebr Size
5/8"-Y4
1'
l-114'ilvl l-1lT
2- or multiple rneiersof eq.ivalent capacity
3'or muttiple meters d €$ivdenl capacrty
4'or mulliple metersof eqivalent capaoty
6'or muhiple melersof eqivalenl capaoty
8'or muttiple meters of e$rivalent capcrty
l0'or multiple meters of eryivdent capaoty
Volume Charge
For all v*ater used less ftan 3CCF (lfil crtic
Feet) (CCF[ 1 trF=l 18 ganms):
Forall mter used gneaterthm 3CCF
Volume CharEe
For all mter used less han 3CCF (1fi) o$ic
FeeQ (CCF[ 1 &F =l 18 gdluts]:
For all water used grealerthan 3CCF
Bi-tt onlhly
Per trleEr
Charge
$22.36
s28.s8
s48.90
$75.87
s147.98
$276.07
$460.91
$602.98
$859.29
Wnter
$1.sru
Suwurcr
Rales
$1.sru
$1.9673
Rates
$r.5738
Conditims d Cortrad:
The cr.rstonrer strall pay the tdal d tre cudoner charge plus the vdume charge. The vdume
ctrarge is based on all nretered mter for the btfing p6rk d. Conwmptim is expressed in
hudred a.rt*c foot uniB or tulsand gallon mib as determined by the nreter installed by the
Conpany. The ctrstorer charge uill be praated urfienever the custorner has not been a
anstorner for lhe enlire talltrg perird.
SunmerPedod-
The zummer rate wil! appty to water consumed between ilay 1 and Septernber 30. irhter
readings stladdlirg these daEs will be proraled.
lssued Per IPUC Order No.
Effective - Decerber n.,2016
lssued by SUEZ WATER IDAHO lNC.
Gregory P. Wyatt, Mce President
8248 West Vlctory Road, 8olse, lD
0,0-013
CITY OF EAGLE
CASE NOS. SUZ"W-18-02/EAG-W-18-01
FrRST PRODUCTTON REQUEST OF SUEZ WATER rDAHO rNC.
Preparer/Sponsoring Witness: Stan Ridgeway, Mayor, City of Eagle
REQUEST NO.20: Please identiff each person or entity that the City 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.
RESPONSE TO REQUEST NO. 20: Subject to the foregoing limitations and
constraints, the City has not yet identified each person or entity that it intends to call as a witness
in any technical hearing in this matter. The City will provide such identifications prior to the
hearing and pursuant to any schedule for the hearing and prehearing matters to be adopted by the
Commission and entered in these cases.
CITY OF EAGLE',S RESPONSE TO SUEZ',S FIRST PRODUCTION REQUEST - 25
Certificate of Service
I hereby certify that on this l5th day of March,2019,I caused to be served a true and
correct copy of the foregoing by the method indicated below, and addressed to the following:
Diane M. Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W . Washington Street
Boise, ID 83702
Email : secretary@puc. idaho. gov
[e-mail]
Commission
Sean Costello
Deputy Afforneys General
Idaho Public Utilities Commission
472W. Washington Street (83702)
P.O. Box 83720
Boise, lD 83720-0074
Emai I : brandon.karpen@puc. idaho. gov
sean.costello@puc. idaho. gov
Attorneys for Commission Staff
Michael C. Creamer
Preston N. Carter
Givens Pursley LLP
601 W. Bannock Street
P.O.Box2720
Boise, ID 83701-2720
E-mail : [e-mail]
[e-mail]
Attorneys for Petitioner SUEZ Water ldaho
Inc.
Marshall Thompson
SUEZ Water Idaho, Inc.
8248 W. Victory Road
Boise,ID 83709
Email : [e-mail]
Petitioner
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U.S. Mail
Hand Delivery
Overnight Mail
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Electronic Mail
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U.S. Mail
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U.S. Mail
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CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST - 26
Molly O'Leary
BizCounselor at Law
1775W. State St. #150
Boise, ID 83702
E-mai I : molly @bizcounse loratlaw. com
Attorneyfor Petitioner Eagle Water Co.
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U.S. Mail
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Electronic Mail
Robert DeShazo, Jr.
President
Eagle Water Company, Inc.
188 W. State Street
P.O. Box 455
Eagle,ID 83616-0455
Emai I : [e-mail]
Petitioner
U.S. Mail
Hand Delivery
Overnight Mail
Telecopy (Fax)
Electronic Mail
N.L. Bangle
H2O Eagle Acquisition, LLC
188 W. State Street
Eagle,lD 83616
Email : nbangle@h2o-solutionsl lc.net
Petitioner
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James M. Piotrowski
Piotrowski Durand, PLLC
1020 W. Main Street, Suite 440
P.O. Box 2864
Boise,ID 83701
Email : [e-mail]
Attorney for Intervenor CAIA
U.S. Mail
Hand Delivery
Overnight Mail
Telecopy (Fax)
Electronic Mail
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, lD 83702
Email : [e-mail]
Attorney for Intervenor CAPAI
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Abigail R. Germaine
Boise City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701-0500
Email : [e-mail]
Attorney for Intervenor City of Boise
U.S. Mail
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Electronic Mail
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CITY OF EAGLE'S RESPONSE TO SUEZ'S FIRST PRODUCTION REQUEST .27
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main Street, Suite 1300
Boise, lD 83702
Emai I : [e-mail]
[e-mail]
Attorney for Intervenor EWCG
U.S. Mail
Hand Delivery
Overnight Mail
Telecopy (Fax)
Electronic Mail
tu
for Holland LLP
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cITy oF EAGLE'S RBSPONSE TO SUEZ',S rrRST PRODUCTION REQUEST - 2E