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Home My WebLink About20210914Eagle Water to Staff 15-18.pdfEAGLE WATER COMPANY’S RESPONSE TO PUC STAFF’S 5TH PRODUCTION REQUEST - 1 MOLLY O’LEARY BizCounselor@Law, PLLC 1775 W. State Street #150 BOISE, IDAHO 83702 208.453.6106 IDAHO BAR NO. 4996 Molly@BizCounselorAtLaw.com Attorneys for Eagle Water Company, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION EAG-W-18-01 FIFTH COMES NOW, Applicant Eagle Water Company, Inc., by and through undersigned counsel, and provides the following Responses to the Commission Staff’s Fourth Production Request. 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. EAGLE WATER COMPANY’S RESPONSE TO REQUEST NO. 15: Please see attached CONFIDENTIAL EXCEL attachments titled: RECEIVED 2021 SEP 14 AM 8:00 IDAHO PUBLIC UTILITIES COMMISSION EAGLE WATER COMPANY’S RESPONSE TO PUC STAFF’S 5TH PRODUCTION REQUEST - 2 a. 09.13.21 – Request No. 15 – 01 Min Usage (CONFIDENTIAL) b. 09.13.21 – Request No. 15 – 02 Min Usage (CONFIDENTIAL) c. 09.13.21 – Request No. 15 – 03 Min Usage (CONFIDENTIAL) d. 09.13.21 – Request No. 15 – 04 Min Usage (CONFIDENTIAL) e. 09.13.21 – Request No. 15 – 07 Min Usage (CONFIDENTIAL) f. 09.13.21 – Request No. 15 – 15 Min Usage (CONFIDENTIAL) The attached documents are filed in accordance with IPUCRP 233.02, and are subject to the Protective Agreement entered into by the Company and the Commission Staff. The information provided is deemed confidential under IPUCRP 67 and IPUCRP 233; the Idaho Trade Secret Act, Title 48, Chapter 8, Idaho Code; and the Idaho Public Records Act, Title 74, Chapter 1, Idaho Code. This Response was prepared by Eagle Water Company Office Manager Julie Chatterton. Telephone: 208.939.0242 Address: 188 W. State Street, Eagle, ID 83616 Record Holder (if different): NA Witness to sponsor testimony regarding: Julie Chatterton 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. EAGLE WATER COMPANY’S RESPONSE TO REQUEST NO. 16: Please see attached CONFIDENTIAL EXCEL attachments titled: a. 09.13.21 – Request No. 16 – 01 Max Usage (CONFIDENTIAL) b. 09.13.21 – Request No. 16 – 02 Max Usage (CONFIDENTIAL) c. 09.13.21 – Request No. 16 – 03 Max Usage (CONFIDENTIAL) d. 09.13.21 – Request No. 16 – 04 Max Usage (CONFIDENTIAL) e. 09.13.21 – Request No. 16 – 07 Max Usage (CONFIDENTIAL) EAGLE WATER COMPANY’S RESPONSE TO PUC STAFF’S 5TH PRODUCTION REQUEST - 3 f. 09.13.21 – Request No. 16 – 15 Max Usage (CONFIDENTIAL) Please also see attached CONFIDENTIAL EXCEL attachment titled “Requests Nos. 15 & 16 Response, re: 6” connections, Minimum & Maximum Usage.” The attached documents are filed in accordance with IPUCRP 233.02, and are subject to the Protective Agreement entered into by the Company and the Commission Staff. The information provided is deemed confidential under IPUCRP 67 and IPUCRP 233; the Idaho Trade Secret Act, Title 48, Chapter 8, Idaho Code; and the Idaho Public Records Act, Title 74, Chapter 1, Idaho Code. This Response was prepared by Eagle Water Company Office Manager Julie Chatterton. Telephone: 208.939.0242 Address: 188 W. State Street, Eagle, ID 83616 Record Holder (if different): NA Witness to sponsor testimony regarding: Julie Chatterton REQUEST NO. 17: Please provide the number of connections and monthly revenue for all non-metered customers. EAGLE WATER COMPANY’S RESPONSE TO REQUEST NO. 17: Eagle Water Company only provides non-metered service to a single mobile home park on Floating Feather Road in Northwest Eagle: Monthly Revenue May through October: $11.75/Customer (75) $11.75 x 75 = $881.25/month November through May: $19.75/Customer (75) $19.75 x 75 = $1,481.25/month Customer count can vary, but has remained at 75 since March of 2018. EAGLE WATER COMPANY’S RESPONSE TO PUC STAFF’S 5TH PRODUCTION REQUEST - 4 This Response was prepared by Eagle Water Company Office Manager Julie Chatterton. Telephone: 208.939.0242 Address: 188 W. State Street, Eagle, ID 83616 Record Holder (if different): NA Witness to sponsor testimony regarding: Julie Chatterton 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. EAGLE WATER COMPANY’S RESPONSE TO REQUEST NO. 18: A. Please see attached CONFIDENTIAL PDF folders titled: 1. 09.10.21 - Request No. 18 - 132.5 IFB Surcharge Account 2. 09.10.21 - Request No. 18 - 132.6 IFB Well Construction Account 3. 09.10.21 - Request No. 18 - 132.7 IFB Engineering Account B. Please see attached CONFIDENTIAL PDF titled “09.13.21 – Request No. 18 – Deposit & Withdrawal Details for IFB Accounts 132.5, 132.6 and 132.7” No withdrawals were made from the 132.5 IFB Surcharge Account. The attached documents are filed in accordance with IPUCRP 233.02, and are subject to the Protective Agreement entered into by the Company and the Commission Staff. The information provided is deemed confidential under IPUCRP 67 and IPUCRP 233; the Idaho Trade Secret Act, Title 48, Chapter 8, Idaho Code; and the Idaho Public Records Act, Title 74, Chapter 1, Idaho Code. This Response was prepared by Eagle Water Company Office Manager Julie Chatterton. Telephone: 208.939.0242 Address: 188 W. State Street, Eagle, ID 83616Record Holder (if different): NA Witness to sponsor testimony regarding: Julie Chatterton EAGLE WATER COMPANY’S RESPONSE TO PUC STAFF’S 5TH PRODUCTION REQUEST - 5 DATED at Boise, Idaho, this 13th day of September, 2021. By: ______________________________ Molly O’Leary BizCounselor@Law, PLLC Attorney for Eagle Water Company, Inc. EAGLE WATER COMPANY’S RESPONSE TO PUC STAFF’S 5TH PRODUCTION REQUEST - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 13th day of September, 2021, a true and correct copy of the foregoing document was served on the following in the manner indicated: Jan Noriyuki Commission Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83702 SUEZ WATER IDAHO, INC. Applicant Marshall Thompson Suez Water Idaho, Inc. 8248 W. Victory Road Boise, Idaho 83709 Michael C. Creamer Preston N. Carter Givens Pursley, LLP 601 W. Bannock St. Boise, ID 83702 Attorneys for Suez Water Idaho, Inc. EAGLE WATER COMPANY, INC. Applicant Robert V. DeShazo, Jr. Eagle Water Company, Inc. 188 W. State Street Eagle, Idaho 83616 [ ] by U.S. Mail [X] by Personal Delivery (Original & 3 copies) [ ] by Facsimile [ ] by E-Mail: Secretary@puc.idaho.gov Jan.Noriyuki@puc.idaho.gov [ ] by U.S. Mail [ ] by Personal Delivery [ ] by Facsimile [X] by E-Mail: Marshall.Thompson@Suez.com [ ] by U.S. Mail [ ] by Personal Delivery [ ] by Facsimile [X] by E-Mail: mcc@givenspursley.com PrestonCarter@givenspursley.com [ ] by U.S. Mail [ ] by Personal Delivery [ ] by Facsimile [X] by E-Mail: EagleWaterCo@gmail.com EAGLE WATER COMPANY’S RESPONSE TO PUC STAFF’S 5TH PRODUCTION REQUEST - 7 N.L. Bangle H20 Eagle Acquisition, LLC 188 W. State Street Eagle, ID 83616 COMMISSION STAFF Dayn Hardie Matt Hunter Deputy Attorneys General Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, Idaho 83720-0074 Attorneys for IPUC [ ] by Personal Delivery [ ] by Facsimile [X] by E-Mail: NBangle@H20-solutionsllc.net [ ] by U.S. Mail [ ] by Personal Delivery [ ] by Facsimile [X] by E-Mail: dayn.hardie@puc.idaho.gov matt.hunter@puc.idaho.gov INTERVENORS City of Eagle Jason Pierce, Mayor B. Newall Squyres Murray D. Feldman Holland & Hart, LLC 800 W. Main Street, Suite 1750 P. O. Box 2527 Boise, ID 83702-2527 Attorneys for City of Eagle E-mail Service Only: jpierce@cityofeagle.org tosborn@cityofeagle.org [ ] by U.S. Mail [ ] by Personal Delivery [ ] by Facsimile [X] by E-Mail: nsquyres@hollandhart.com mfeldman@hollandhart.com EAGLE WATER COMPANY’S RESPONSE TO PUC STAFF’S 5TH PRODUCTION REQUEST - 8 Citizens Allied for Integrity and Accountability James M. Piotrowski Marty Durand PIOTROWSKI DURAND, PLLC P.O. Box 2864 1020 W. Main Street, Suite 440 Boise, ID 83701 Attorneys for Citizens Allied for Integrity and Accountability [ ] by U.S. Mail [ ] by Personal Delivery [ ] by Facsimile [X] by E-Mail: James@idunionlaw.com Marty@idunionlaw.com Association of Idaho Brad M. Purdy Attorney at Law 2019 N. 17th Street Boise, ID 83702 Attorney for Community Action Partnership Association of Idaho [ ] by U.S. Mail [ ] by Personal Delivery [ ] by Facsimile [X] by E-Mail: BMPurdy@hotmail.com Norman M. Semanko Parsons Behle & Latimer 800 West Main Street, Suite 1300 Boise, Idaho 83702 Attorneys for Eagle Water Customers Group [ ] by U.S. Mail [ ] by Personal Delivery [ ] by Facsimile [X] by E-Mail: NSemanko@parsonsbehle.com ECF@parsonsbehle.com EAGLE WATER COMPANY’S RESPONSE TO PUC STAFF’S 5TH PRODUCTION REQUEST - 9 City of Boise Mary Grant Scott B. Muir Deputy City Attorney Boise City Attorney's Office 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 [ ] by U.S. Mail [ ] by Personal Delivery [ ] by Facsimile [X] by E-Mail: boisecityattorney@cityofboise.org By: ______________________________ Molly O’Leary