20210827Staff 15-18 to Eagle Water.pdf

DAYN HARDIE (ISB No. 9917)
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 20 I -A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE TDAHO 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 FIFTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
EAGLE WATER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Eagle Water Company ("Eagle Water")
provide the following documents and information as soon as possible, but no later than FRIDAY,
SEPTEMBER 10, 2021.1
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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s attorney
at [phone].
FIFTH PRODUCTION REQUEST
TO EAGLE WATER COMPANY
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CASE NO. SUZ-W-18-02/
EAG-W-18-0r
4!, . t :. , t g.* I + r...._,:- * f i it l. r+-t
AUGUST 27,2021
person preparing the documents. Please also identifu the name, job title, location, and telephone
number of the record holder.
ln 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. 15: For each meter size, please provide the number of connections,
monthly consumption, and monthly revenue that was charged to customers using less than or
equal to the allowable minimum cubic feet.
REQUEST NO. 16: For each meter size, please provide the number of connections, the
monthly consumption, and the monthly revenue that was charged to customers using more than
the allowable minimum cubic feet.
REQUEST NO. 17: Please provide the number of connections and monthly revenue for
all non-metered customers.
REQUEST NO. 18: Please provide bank statements for July 2018 through July 2021, for
the following three accounts: account 132.5 - IFB Surcharge: account 132.6 - IFB Well
Construction: and account 132.7 - IFB Engineering. Please provide detailed notes of each deposit
or withdrawal.
#*,DATED at Boise, Idaho, this
i:umisc:prodreq/suzwl8.2_eagwlS.lsctnc prod req 5 to Eagle Water
FIFTH PRODUCTION REQUEST
TO EAGLE WATER COMPANY
of August 2021
Deputy Attomey Geneial
2 AUGUST 27 ,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF AUGUST 2021, SERVED
THE FOREGOING FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
TO EAGLEWATERCOMPANY; IN CASE NOS. SUZ-W-I8-02/EAG-W-18-01, BY
E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GIVENS PURSLEY LLP
601 W. BANNOCK ST.
BOISE, ID 83702
E-MAIL: mcc@givenspursle)'.com
presto ncafter@ givenspursle)--. conl
ROBERT DESHAZO
EAGLE WATER COMPANY, INC.
188 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 : mollv CD,bizcou nse loratlaw. com
ELECTRONIC ONLY
MAYOR JASON PIERCE
CITY OF EAGLE
660 E CIVIC LANE
EAGLE ID 83616
E-MAIL: i [e-mail]
to sborn@c ity o feae I e. o r g
MARSHALL THOMPSON
SUEZ WATER IDAHO, INC.
8248 W. VICTORY RD.
BOISE, IDAHO 83709
E-MAIL : marshal l.thompson@suez. com
N.L. BANGLE
H2O EAGLE ACQUISTION, LLC
188 W. STATE ST.
EAGLE, IDAHO 83716
E-MAIL : nbanslelOh2o-soh-rtionsllc. net
B NEWAL SQUYRES
MURRAY D FELDMAN
HOLLAND & HART LLP
PO BOX2527
BOISE tD 83702-2527
E-MAIL: [e-mail]
mtb I d m an @ ho I I andhart. co m
JAMES M PIOTROWSKI
MARY DURAND
PIOTROWSKI DURAND PLLC
1O2O W. MAIN STREET, SUITE 440
PO BOX 2864
BOISE ID 83701
E-MAIL : i ames(r?.idunionlaw.com
[e-mail]
CERTIFICATE OF SERVICE
SCOTT B. MUIR
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
I5O N. CAPITOL BLVD.
PO BOX 500
BOrSE ID 83701-0500
E-MAIL : [e-mail]
CERTIFICATE OF SERVICE