20210713Staff 11-14 to Eagle Water.pdf

DAYN HARDIE (ISB No. 9917)
MATT HUNTER (tSB No. 10665)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03t2
[phone]
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Street Address for Express Mail:
1 I331 W CHINDEN BLVD, BLDG 8, SUTTE 2OI-A
BOISE, TD 837I4
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 FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
EAGLE WATER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of record,
Dayn Hardie and Matt Hunter, Deputy Attorneys General, request that Eagle Water Company
("Eagle Water") provide the following documents and information as soon as possible, but no later
than TUESDAY, AUGUST 3,2021.
This Production Request is to be considered as 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of the
person preparing the documents. Please also identify the name, job title, location, and telephone
number of the record holder.
FOURTH PRODUCTION REQUEST
TO EAGLE WATER COMPANY
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CASE NO. SUZ.W-I8.02I
EAG-W-18-01
1 JULY I3,2O2I
In addition to the written copies provided in response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. l1: In OrderNo. 34265, CaseNo. EAG-W-I5-01, the Commission
approved a Joint Settlement Stipulation in which Eagle Water Company was to deposit $45,288
in overearnings annually into the surcharge line-of-credit account beginnin gin20l6. What is the
current balance ofthe surcharge line-of-credit account?
REQUEST NO. 12: Has Eagle Water Company used the surcharge line-of-credit
account to make any plant investments? If so, please provide details of the plant investments
REQUEST NO. 13: If plant investments have been made from the surcharge line-of-
credit account, has the account been repaid?
REQUEST NO. 14: How does Eagle Water Company plan to account for the balance of
the surcharge line-of-credit account as part of the sale to SUEZ Water of ldaho?
DATED at Boise, Idaho, tfris [3Sday of July 2021.
Dayn
Deputy Attorney General
i:umisc:prodreq/suzw 18.2_eagwlS.lsctnc prod req 4 to Eagle Water
FOURTH PRODUCTION REQUEST
TO EAGLE WATER COMPANY 2 JULY I3,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l3th DAY OF ruLY 2021, SERVED
THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
TO EAGLE WATER COMPNAY; IN CASE NOS. SUZ-W-18-02IEAG-W-18-01, BY
E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GIVENS PURSLEY LLP
60I W. BANNOCK ST.
BOISE, ID 83702
E-MAIL: [e-mail]
presto ncarter@ givenspursley. corn
ROBERT DESHAZO
EAGLE WATER COMPANY, INC.
I88 W. STATE ST.
EAGLE, IDAHO 83616
E-MAIL: [e-mail]
MOLLY O'LEARY
BIZCOUNSELOR AT LAW PLLC
1775 W STATE STREET, #150
BOISE ID 83702
E-MAIL: [e-mail]
ELECTRONIC ONLY
MAYOR JASON PIERCE
CITY OF EAGLE
660 E CIVIC LANE
EAGLE ID 83616
E-MAIL: i [e-mail]
to sbo rn@,c ity o fea gl e. o rg
BRAD M PURDY
ATTORNEY AT LAW
2019 N ITTH STREET
BOISE ID 83702
E-MAIL: [e-mail]
MARSHALL THOMPSON
SUEZ WATER IDAHO, INC.
8248 W. VICTORY RD.
BOISE, TDAHO 83709
E-MAIL : marshall.thompsonfDsuez.com
N.L. BANGLE
H2O EAGLE ACQUISTION, LLC
188 W. STATE ST.
EAGLE, IDAHO 83716
E-MAIL : [e-mail]
B NEWAL SQUYRES
MURRAY D FELDMAN
HOLLAND & HART LLP
PO BOX2527
BOISE tD 83702-2527
E-MAIL: [e-mail]
mf-e I drn an@ho I landhart. co m
JAMES M PIOTROWSKI
PIOTROWSKI DURAND PLLC
IO2O W. MAIN STREET, SUITE 440
PO BOX 2864
BOISE ID 83701
E-MAIL: [e-mail]
NORMAN M SEMANKO
PARSON BEHLE & LATIMER
8OO W MAIN STREET, SUITE 13OO
BOISE ID 83709
E-MAIL: [e-mail]
ecf-@ p arsonsbehl e. co m
CERTIFTCATE OF SERVICE
SCOTT B. MUIR
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
150 N. CAPITOL BLVD.
PO BOX 500
BOISE ID 83701-0500
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE