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Home My WebLink About20190208Suez 1-22 to CAIA.pdfirr[] I ivIL) Michael C. Creamer (ISB No. 4030) Preston N. Carter (ISB No. 8462) Givens Pursley LLP 601 W. Bannock St. Boise,ID 83702 Telephone: (208) 388-1200 Facsimile: (208) 388-1300 rLqs@. g"i venspu rsl ey. com prgstoncarter@ gi venspursley. corn Attorneysfor SUEZ Water ldaho Inc. [3Gr74] t4525179.4 IN THE MATTER OF THE JOINT APPLICATION OF SUEZ WATER IDAHO AND EAGLE WATER COMPA}.IY FOR THE ACQUISITION OF EAGLE WATER COMPAI\ry f [il -8 Fi{ 5: l0 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case Nos. SUZ-W-fE-O2 EAG-W-I8-01 Flnsr PRoDUCTToN REeuEsr or SUEZ WarBnlo.q,no INc. To CrrrznNs Ar,r,rrp ron lxrncnrrY AIYD Accouxtarrr,rry SUEZ Water Idaho Inc. ("SUEZ") requests that Cidzens Allied for lntegrity and Accountability (*CAIA") provide the following documents and information by March l,2AL9. This Production Request is continuing, and CALA is requested to provide additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced. Please answer eaeh 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 31.01.0r .228. Fnsr PnonucrroN RJeuEsrs oF SUEZ ro CAIA - I 'rf t*lr^rF!.,rLrUlLrll Request No. L: Please provide copies of any and all organizational documents pertaining to CAIA, including (without limitation) any and all articles of association, bylaws, resolutions or minutes, and other documents related to CAIA's participation in this proceeding. Request No. 2: Please provide the names and business addresses of the officers and directors of CAIA, 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 CAIA. Request No. 4: Please state the total number of persons or entities who are members of CAIA. Please indicate whether each member is a current customsr of Eagle Water Company and, if so, under which schedule or tariffthey take service. Request No. 5: Please state the number of CAIA members that also are members of another intervenor in this proceeding. For each, please identify which other intervenor the CAIA member is also a member of. Request No. 6: Please describe the source of funds by which the activities of CAIA are supported. Request No. 7: Please describe, in detail, the factual basis for CAIA's statement in its Petition to Interuene that CAIA's participation in this case will further its interest "maintaining high quality water resources." Please provide any and all relevant analyses, studies, or other documents supporting your answer. Request No. 8: Please describe, in detail, the factual basis for CAIA's statement in its Petition to Intervene that CAIA's participation in this case will further its interest "maintaining FTRSTPRoDUCTToN REeuEsrs or SUEZTo CAIA - 2 local control" of water. Please provide any and all relevant analyses, studies, or other documents suppofiing your answer. Request No. 9: Please describe, in detail, the factual basis for CAIA's statement in its Petition to lntsrvene that thsre are "possible environmental harms stemming from the merger." Please provide any and all relevant analyses, studies, or other documents concerning any possible environmental harms that you athibute to the proposed Eagle Water Company asset acquisition by SUEZ. Request No l0: Please describe, in detail, the factual basis for CAIA's statement in its Petition to lntervene that *the outcome of the proceedings regarding the Joint Application could also impact service to customers." Please provide any and all relevant analyses, studies, or other documcnts conceming any impacts on seryice to customers that you attribute to the proposed Eagle Water Company asset acquisition by SUEZ. Request No. 11: Please describe, in detail, the factual basis for CAIA's staternent in its Petition to Intervene that "the outcome of the proceedings regarding the Joint Application could also impact . . . water quality." Please provide any and all relevant analyses, studies, or other documents concerning any impact to water quality that you attribute to the proposed Eagle Water Company asset acquisition by SUEZ. Request No. 12: Please describe, in detail, the factual basis for CAIA's statement in its Petition to Intervene that "the outcome of the proceedings regarding the Joint Application could also impact . . . chemical treatments." Please provide any and all relevant analyses, studies, or other documents supporting your answer. Request No. 13: Please describe, in detail, the factual basis for CAIA's statement in its Petition to Intervene that "the outcome of the proceedings regarding the Joint Application could FIRST PRoDUCTION REQUESTS OF SUEZ TO CAIA - 3 also impact . . . environmental concems." Please provide any and all relevant analyses, studies, or other documents concerning any impact to environmental that you attribute to the proposed Eagle Water Company asset acquisition by SUEZ. Request No. 14: Please describe, in detail, the factual basis for CAIA's statement in its Petition to lntervene that Eagle Water Company has "many'' customers who "are single parents, elderly, or living with disabilities on fixed and limited incomes.o'As part of your answer, please provide an approximate estimate ofthe number of such customers. Please also provide any and all relevant analyses, studies, or other documents that form the basis of your estimate. Request No. 15: Please identiff any existing programs or other arangement by which the City of Eagle can or does provide assistance on water bills to single parents, the elderly, those living with disabilities; or low-income customers. Request No. 16. Please state whether CAIA is aware of SUEZ's low-income assistance programs. Request No. 17: Please provide copies of all informational materials, pamphlets, statements, or other communications that CAIA has provided to its members or to the public regarding the subject matter of this proceeding. Request No. 18: Does CAIA contend that the phased-in 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. FRST PRoDUCTON TGQUESTS oF SUEZ To CAIA - 4 Requect No. 19: Does CAIA conte,nd that the City of Eagle would not seek to move water under Eagle Water Company water rights to other portions of the Crty's current or future service area if the City were to acquire Eagle Water Company? Request No. 20: Does CALA contend that the Idaho Departnent of Water Resources does not have juridiction and authority over the place and purpose of the use of the water ridrts that are currently owned by Eagle Water Company, even if those water rights arc acquired by SUEZ? Request No. 21: Does CAIA contend that the City of Eagle would not chlorinate the water that would be provided to curent Eagle Water Customers if the City were to acquire Eagle WaterCompany? Request No. 22: Does CAIA contend that the City of Eagle does not currently chlorinate the drinking water pnovided to its current customers? Request No. 22: Please identiff each person or entity that CALA 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. DATED this 8s day of Febnuary, 2019. SLrEZ Water Idaho Inc. By: C. Creamer Preston N. Carter Givens Pursley LLP Anorneysfor SUEZ Water ldaho Inc. FrRsr PRoDUcrroN REQrrEsm or SUEZ ro CAIA - 5 fa*{ CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 8ft day of February,2}l9, 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 Washington 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 Attorneysfor IPUC Molly O'Leary BizCounselor at law 1775W. State St. #150 Boise, D 83702 Counselfor Eagk 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 Fnsr PRoDUCTToN REeuEsrs oF SUEZ ro CAIA - 6 I I bvU.S. Mail t I bV Personal Delivery (Original & 3 copies) [ ] bV Facsimile [X] bV E-Mail secretary(Dpuc.idaho. gov diane.hanian@puc.idaho. t I bvU.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile [X] bV E-Mail brandon.karpen@puc.idaho.eov sean.costello@puc. idaho. sov [ ] byU.S. Mail [ ] bV Personal Delivery t I bV Facsimile [X] bV E-Mail molly(dbizcounseloratlaw.com lxl bvU.S. Mail t I bV Personal Delivery [ ] bV Facsimile [ ] bvE-Mail t I bvU.S. Mail [ ] bV Personal Delivery [ ] bV Facsimile [X] by E-Mail nbanele(a)h2o-solutionsllc.net t I bvU.S. Mail t I bV Personal Delivery t I bV Facsimile [X] bV E-Mail srideeway(Dcityo feaele. ore sbersmann@cityo feasle.ors [ ] byU.S. Mail t I bV Personal Delivery [ ] by Facsimile [X] by E-Mail cdm(@msbtlaw.com Norman M. Semanko Parsons Behle & Latimer 800 West Main Sheet, Suit€ 1300 Boise, tdaho 83702 Attorneys for Intentenor Eaqle llater Customer Group Abigail R Gemtaine Deputy City Attomey Boise City Attorney's Office 150N, Capitol Blvd. P.O. Box 500 Boise, Idaho 83701 -0500 Attorneysfor Intervenor, City of Boise James M. Piotrowski PIOTROWSKI DURAI{D, PLrc P.O. Box 2864 1020 W. Main Street, Suite 440 Boise,ID 83701 Attorneys for Intentenor Citizens Allied for Integrity and Accountability Brad M. Purdy Attorney at Law 2019 N. 17th Shcet Boise,ID 83702 Auorney for Community Action Partnership Association of ldaho [ ] bvu.s. Mail [ ] bV Personal Delivery [ ] bV Facsimile [X] bV E-Mail NSemanko(dnarsonsbchle.com ecf@f arsonsbehle.com [ ] bv U.S. Mail t I by Personal Delivery [ ] bV Facsimile [X] by E-Mail aeermaindg)cityofboise.ore [ ] bvU.S. Mail [ ] byPersonalDelivery [ ] bV Facsimile [X]by E-Mail James(didunionlaw.com [ ] byu.s. Mail [ ] bV Personal Delivery [ ] bV Facsimile [X] bV E-Mail bmpurdy(4hotmail.com L Preston N. Carter FIRST PRoDUcTIoN REQUESTS oF SUEZ To CAIA . 7