Loading...
HomeMy WebLinkAbout20190301EWCG to Suez 1-22.pdfNorman M, Semanko,ISB #4761 PARSONS BEHLE & LATIMER 800 West Main Street, Suite 1300 Boise,Idatro 83702 Telephone: 208562.4900 Facsimile: 208562.4901 NSemanlco@parsonsbehle.com ecf@parsonsbehle.com Attorneys for Intervenor Eagle Water Customer Group BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION :i !i,!'r- - i Fll ?J iil',,\ I i rJ L IN THE MATTER OF THE JOINT APPLICATION OF SUEZ WATER IDAHO AND EAGLE WATER COMPAI{Y FOR THE ACQUISITION OF EAGLE WATER COMPANY cAsE NOS. SUZ-W-I8-02 EAG-W-I8-01 EAGLE WATER CUSTOMER GROUP'S RESPONSFS TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC. COMES NOW Eagle Water Customer Group ("EWCG'), by and through its attorney of record Norman M. Semanko of the firm Parsons Behle & Latimer, and hereby responds to Suez Water Company's First Production Request dated the 8th day of Febnrary,20l9,as follows: EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQLJEST OF SUEZ WATER IDAHO, INC. - Page I 4849-45M-7688v3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, tNC. - Page 2 4M9450&76EEv3 SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO. 1: Please provide copies of any and all organizational documents pertaining to EWCG, including (without limitation) any and dl articles of association, bylaws, resolutions or minutes, and other documents related to EWCG's participation in this proceeding. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: EWCG is an unincorporated nonprofit association, as defined under Idatro Code $ 30-27-rc2, and is not required to maintairb nor does it have, articles of association, bylaws, resolutions or minutes. A copy of EWCG's Unincorporated Nonprofit Association Agent Appointment and Employer Identification Number are attached hereto as Bates Nos. EWCG 000001-3. I tffir ililr ffi llillil llffi lll llll ililril fiil Iilffiffiilffiffiill rffir rllll lffiulllfl StrATEOF IDA}IO Ollico of tie secretary of state, Lrterene Denrcy UNINCORPORATED NONPROFIT ASSOCIATK)I{ AGENT APPOII{TIIET{T l(l nos.crutstydstlb PO8or83720 8&o,1O8e720tr0(208)$+aor FlfttgFocil.()0 tutCXtuUoaily -FILED- Frb *: oooisszs8s IDrto Fflcd: 12127 l2O1E g:21fr. pM t. nro artr. 0160snholo..H no@rrrodrlhb: EAGT.E WAIER CUSTOMER gRq'P 2"Ittc carpLb.MqlI.. CtlrDnndDd ofiob Pdndpal OlficeAdders 8770W. CHAPAITIIALRD. EAG|-E. Dg1616 3. lh. illtn &..of tm n.hd9.l dc. h ilalltlg166po l{one a. R.$or.d fgart Nattc r.i Add!.. RcglCor€dAeont NORMAN MSEMANKO ReddendAgetil Ftdc.lArlitol. 800 W [,lAlN ST., SlJm l30o BO|SE lD83T@ ilrfingAddr$s 5. Rqecd Aeqrt ffgr,lt slgn.rn! R€glstored Ag€nt ggn6tln:(_./, Dale Signed:4zlla tlarrocg5ilillu'- - 'Sipctm ola manrber,of lhenopofil assodalbn: Dablbned: A,/et/tA 4/4rb*A Pagc I ofl 1 EWcc_000001 t I From:..EmployerldentificationNumber,.<> Subject: EIN For Other Entities - Assigned EIN Date: January 8, 2019 at 6:23:35 PM MST To: ianet@buschert.com Dear Janet Buschert, The lnternal Revenue Service (lRS) has assigned the following Employer ldentification Number to Eagle Water Customer Group: 83-3067297 The EIN shown above will identify you, your business accounts, tax returns, and documents before the lnternal Revenue Service. The EIN is effective immediately and can be used right away. When you are filing any tax documents, payments, and related correspondence, it is important to use your assigned ElN, complete name and address exactly as you have entered into the EIN application. Any variation of information may cause a delay in processing, result in incorrect information in your account, or even cause you to be assigned more than one ElN. The IRS will mail you an official notice displaying your EIN within 2-4 weeks time. Keep this notice in your permanent records as the IRS does not generate duplicate copies. lt is issued one time only. lf you are asked to provide your EIN (for instance, to open a bank account), simply photocopy the official IRS EIN notice and provide it to the individual or entity requesting this information. lf applicable, the IRS will also inform you of any forms or returns in which you are required to complete by mail. Please contact us by email (info@emploveridentificationnumber.net) if you have any further questions. Thank you for your business. Yours truly, USGR Consultants lnc. *The information and services provided by USGR Consultants lnc.'s representatives and its website (www.emploveridentificationnumber.net) are intended to provide accurate and authoritative information with regard to the application for U.S. tax identification numbers. Any information, advice or opinions provided by USGR Consultants lnc.'s representatives or website are not a substitute for accounting, business, legal, tax or other EWCG_000002 professlonal advlce or seMces. Before taklng any accountlng, business, legal or tax action based on the informatlon provlded on our webshe or by one of our representatives, you should consuh a business, flnanclal, legal or tax professlonal who can provlde advlce based on your own personal or buslness situatlon. 2 EWCG_000003 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC. SPONSOR(S)r Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST N0.2: Please provide the names and business addresses of the officers and directors of EWCG, indicate whether these persons are customers of Eagle Water Company, and indicate which schedule or tariffunder which they take service. RESPONSE TO REQUEST fOR PRODUCTION NO. 2: EWCG does not have officers or directors. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 3 4E494504-76EEv3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC. SPONSOR(S): Shelley Brock, Janet Buchert and Jane Rohling, EWCG members. REQITEST NO. 3: Please describe the process by which a peson or entity is admitted to membership in EWCG. RESPONSE TO REQITEST FOR PRODUCTION NO. 3: As an unincorporated nonprofit association, as defined under Idaho Code $ 30-21-102(5), EWCO members are joined under an agreement that is oral, in a record, or implied from conduct for one or morc common, nonprofit putposes, including opposition to the proposed acquisition of Eagle Water Company by SI,JEZ and participation in the related PUC proceedings. EWCG membership is open to those who share in these common, nonprofit purposes. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF St EZ WATER IDAHO, tNC. - Page 4 4849450,t-?688v3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FrRST PRODUCTION REQUEST OF SUEZ WATER rDAHO rNC. SPONSOR(S): Shelley Brock" Janet Buschert and Jane Rohling EWCG members. REQUEST NO. 4: Please state the number of persons or entities who are members of EWCG. Please indicate whether each member is a current customer of Eagle Water Company and rurder which schedule or tariffthey take service. RESPONSE TO REQUES? FOR PRODUCTION NO. 4: EWCG currently has approximately 425 members, most of whom are Eagle, Water Company residential customers, along wittr some small commercial eustomers. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FTRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 5 4849-4504-768Ev3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER rDAHO rNC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO. 5: Please state the number of EWCG members that also are memben of another intervenor in this proceeding. For each, please identif which other intervenor the EWCG member is also a member of. RESPONSE TO REQUEST FOR PRODUCTION NO. 5: EWCG does not know who all of the members of the other intervenors in this proceeding are and therefore cannot provide a complete rcsponse to this request. EWCG members Shelley Brock and Jane Rohling are also members of Citizens Allied for Integrity and Accounability ("CAIA'), in intervenor in this matter. All EWCG membets living in Eagle are residents of the City of Eagle, also an intervenor in this matter. Some EWCG members live in Boise and are residents of the City of Boise, also an intervenor in this matter. EWCG is not awar€ of any of its members that also belong to Community Action Partrership Association of Idaho C'CAPAI'). EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SLJEZ WATER IDAHO, INC. - Page 6 48494504-76EEv3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FrRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO.6: Please describe the source of funds by which the activities of EWCG are supported. RESPONSE TO REQUEST FOR PRODUCTION NO. 6: EWCG is supported by individual donations. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 7 4849-4504-7688v3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTTON REQUEST OF SUEZ WATER IDAHO rNC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO. 7: Please identiff the official channels of communication of EWCC. Please indicate, specifically (but without limitation) whether posts made by the Facebook Group named "Eagle Water Customers" are considered communications of EWCG. RESPONSE TO REQUEST FOR PRODUCTION NO. 7: EWCG has identified its attorney Norman M. Semanko as the contact on its press releases. EWCG posts made on EWCG's Facebook Group page are commutications administered for EWCG by EWCG memberc Jane Rohling, Janet Buschert, and Shelley Brock. Individual cornments posted on the Facebook Group page are not considered communications of EWCG. EWCG identifies the documents attached hereto as EWCG 000004-5 as official channels of communications of EWCG, along with EWCG's Facebook Group page. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTTON REQUEST OF SLJEZ WATER IDAHO, INC. - Page 8 4E49-45M-76Etv3 PRESS RELEASE For lmmediate Release: l-18-19 Cus EWCG Ghallenges Proposed Purchase of Eagle Community's Water Resources by Multinational Suez Water IPUC Grants Non-Profit a Voice in Effottto ProtectWater Rafes and Seruices - Rules Citizens Group Can Formally lnteruene The ldaho Public Utilities Commission (IPUC) has formally granted a local non-profit association the right to intervene against French-based multinational conglomerate Suez Water's application to buy a local water syslem which has provided service to 4,200 Eagle homes and businesses for nearly half a century. Eagle Water Customers Group (EWCG) is a growing coalition of concerned citizens formed in direct response to the Joint Application filed by Suez and seller Eagle Water Company (EWC) in November, 2018. ln a petition filed on December 27, EWCG asserts their members stand to be impacted by significant rate increases resulting from the proposed acquisition, as set forth in the Joint Application. Suez proposes astronomical rate hikes for current EWC users in order to fund the diversion of massive volumes of water from Eagle to support future development in the arid northwest Boise foothills. Existing Suez customers across the Boise Valley would also see rate increases to support the sale. EWCG asserts this action would not be in the best interest of the public and would impose financial hardship on many Eagle residents and businesses while threatening the quantity and quality of their availaUe water and associated customer services. According to EWCG attorney Norm Semanko, "if this Joint Application is granted rate increases would exceed 200%tor residential customers and 300% for commercial customers, in just three years. This threatens to impose considerable 'rate shock' on Eagle Water customers and could also impact service to customers and other aspects of the public interest.' On January 12 an overflow crowd of concerned citizens packed the Eagle Library where EWCG organizers and Mr. Semanko shared details and answered questions about the IPUC process and how to most effectively oppose the sale. Many in the crowd voiced their alarm that Suez's already steep rates would climb even higher with this sale. Some were disturbed that a lot of senior water rights would be lost to a foreign company if the application is approved. lt was noted that a multitude of public comments about Suez on the IPUC website highlight unreasonably high rates and poor customer service from a company that focuses more on corporate profits and protecting the interests of shareholders than on taking care of their customers. EWCG members will attend the Eagle Cig Council meeting at Eagle City HallTuesday, January 22, at6 pm to voice their support for purchase of EWC by the city and to hear discussion of the 2008 lntertie Agreement which details the Right of First Refusal between the City of Eagle and Eagle Water Company. The press is encouraged to attend. A scheduling conference has also been set for January 30 between IPUC staff and the attorneys for EWCG and other intervenors in the case. EWCG is an unincorporated ldaho non-profit made up of ratepayers, taxpayers and concerned citizens including EWC customers who have come together to oppose the sale of this community's most vital natural resource to a foreign based for-profit corporation. For additional information please contact: Norman M. Semanko Parsons Behle & Latimer 800 West Main Street, Suite 1300, Boise, ldaho 83702 (208) 863-7e21 ,1,3o EWCG_000004 PRESS RELEASE For lmmedlete Release: 1-2G19 Eagle Water Customer Group Challenges The Proposed Purchase Of Eagle Commun:tys Water Resources By Muttinational suez Water The ldaho Publlc Utilities Commisslon Rules The Cltlzens Group Can Formally lntervene- It Grents A Voice To The NorProftt Efforts ln Protectlng Water Rates And Services The ldaho Public UtlUtles Commission (IPUC) has formally granted a local non-profit association the right to intervene agalnst French-based multinatlonal conglomerate Suez Wate/s apptication to buy a local water system and all water rights. The local water system has provlded servlce to 4,200 Eagle homes and businesses for nearly half a century. Eagle Water Customerc Group (ElirCG) ls a growing coalition oF concerned citizens formed in direct response to the Joint Appllcation fited by Suez and the seller Eagle Water Company (EWq in November. ln a petition filed on December 27, EWCG asserts their members stand to be impacted by dgnificant rate lncreases and terms resultlng from the proposed acquisition, as set forth ln the JolntApplication. The proposed plan dlverts a massive volume of Eagte wetl water to future devetopments ln the arid northwest Boise Foothills, instead of creating new sources of water. ln order to fund the diverslon of massive volumes of water out of Eagle, Suez is requesting IPUC permlsslon for astronomical rate hikes from current custohers. Exlstlng Suez customerc across the Bolse Va[ley would also see rate increases to support the sale. EWCG asserls this actlon is not in the best interest of the pubtlc tt woutd impose financial hardship on many Eagle residents and businesses while threatening the quantiU, quaUty and customer seMce for their water suppty. According to a report presented to the CiW of Eagle by Tim Farrell From Mountain Water Works, lf this application is granted by the IPUG the rates will increase 325% in the winter, when water usage is low and412%in the summer, when water usage is hlgh, comparlng price per ga[on rates. Due to the locatlon, most of the residents inigate with city water, so the price change wilt tikely reduce the lush landscape in Eagte. On January 12s an overftow crowd of concerned cltizens packed Eagl,e Library to discuss concerns about the sale and how to oppose the sale. The pubtic concerns lnctuded: steep rate increases, loosing water rights, adding ground water to wetl water requiring chlorine, [osing water rights to a foreign company, going trom a water company that focuses on the community to one that focuses on the bottom line. Many people posted their comments on the IPUC website, hightighting Suez's poor customer service, stating Suez only focuses on corporate profft and not the community interests. EWCG members will be attending the Eagte Gty Council meeting at Eagle CIU Hatl this Tuesday, January 22, at6 pm to voice their support for the Clty of Eagle to purchase the Eagle Water Company. The EWCG members are ancious to hear about the 2008 agreement between the City of Eagle and the Eagle Water Company which details the First Right of Refusal between the Gty of Eagle and the Eagte Water Company. Tte press ls encouraged to attend. A schedullng conference has been set for January 30. The conference wltl include IPUC staFF, attorneys for EWCG and other intervenors in the case. EWCG ls an unincorporaLed ldaho non-profit made up of ratepayers, taxpayes and concerned cltizens including EWC customers who have come together to oppose the sate of this community's mostvltat natural resource to a foreign based for-proflt corporation. For addlUonal inFormation please contact: Norman M. Semanko Parsons Behle & Latimer 800 West Maln Street, Suite 1300, Boise, ldaho 83702 (208) 863-7921 EWCG-000005 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTTON REQUEST OF SUEZ WATER IDAHO INC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO. E: Please state whether the flyers attached as Exhibit I and Exhibit2 are official communications of EWCG. RESPONSE TO REQT EST FOR PRODUCTION NO. 8: Yes. EWCG turther identifies the documents attached hercto as Bates Nos. EWCG 00000G9 as offrcial communications of EWCG. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SIrEZ WATER IDAHO, INC. - Page 9 4E49-4504-7688v3 o13C) -oo(€ tftl st Cus Concerned about changes coming to Eagle Water Company Customers? foin the crowd! Get the facts from Attorney Norm Semanko and find out how you can get involved. SATURDAY, |ANUARY 12, 10:00 AM - 12:00 PM Eagle Public Library meeting room Cet the facts from attorney Norm Semanko and find out how you can help stop this loss of local control over our most precious, irreplaceable natural resource! French-based multinational for-profit Suez Water has applied to the ldaho Public Utilities Commission (IPUC) to purchase the Eagle Water Company. lf they are successful rates will skyrocket by as much as 200-300% for thousands of Eagle residents and businesses. Other Suez customers across the Boise Valley will also see increases to pay for the diversion of massive volumes of Eagle's water for proposed northwest Boise development! This threatens not only the cost of our water but the quality and quantity of that resource and of the customer service associated with it. We are forming a coalition to stop this sale and have retained the services of experienced water attorney Norm Semanko to do just that. We have already been appointed intervenors by the IPUC - a major first step - but we need your help moving forward. Come to this meeting to learn how you can become involved! Please join our Facebook group to stay informed: w w w.f ac eboo k.co m / g ro u ps/ E agl eW ate rC u sto m e r s/ The Eagle Water Customers Croup is a nonprofit grassrools organization formecl specifically ta track and provide input inlo the ldaho Public Utilities Commission's process regarding the proposed sale of Eagle Waler CgX166 OOOOO6 Eagle's Water - A Vital Community Resource We Can't Afford To Sell Help us keep it under local control! Situation: After decades of quality water service Eagle Water Company (EWC) - which serves 4,200 Eagle homes and businesses - has decided to sell their water rights and system. French-based multinational for-profit corporation Suez Water is attempting to purchase this crucial utility system - with a stated goal being to divert water from Eagle to support proposed northwest Boise foothills development. They intend to fund this takeover by hiking rates for customers in the impact area by as much as 200 -300ot6, while also increasing rates for existing Suez customers across the valley. Suez has a D- rating with the Better Business Bureau and a reputation for extremely poor customer service and maintenance, heavy chemicalization of their water and massive rate hikes in municipalities across the US. Eagle Water Customer Group (EWCG) is an unincorporated non-profit association formed specifically to participate in the ldaho Public Utilities Commission (IPUC) process as advocates for maintaining local control and stable, affordable rates for our most critical natural resource. This coalition includes Eagle residents and Suez customers across the valley who will be impacted by the projected rate increases as well as other citizens who simply object to a foreign company coming in to take control of our utilities strictly for profit. Attorney Norm Semanko has generously agreed to represent EWCG on a contingency basis through the IPUC process Thanks to his excellent work, we have already been granted approval to intervene, which is an important first step. What you can do to help: Join our Facebook page - there is strength in numbers and this is the best way to keep up with developments as they occur httos://www.facebook.com/srouos/EasleWaterCustomers/ Submit written comments to the IPUC detailing why you object to Suez buying EWC and asking that the IPUC hold a meeting in Eagle allowing public testimony (Case number: SUZ-W-18-02) https://www. puc.idaho.gov/forms/casecomment.aspx a a a Contact local media to tell them what's happening and why you object a a Write letters to the editor and Op-Ed's about the situation Donate to EWCG to support printing costs, mailings, etc. Donations made payable to EaBle Water Customer Group can be sent to Janet Buschert at 235 W. Floating Feather Rd. in Eagle a a Sign up on our contact sheet so we can keep you informed as we move forward Contact Eagle City Council to let them know you support their efforts to buy Eagle Water Company http://www.citvofeaele.orslFormCenter/Contact-Us-11/Contact-the-Citv-59 a a Spread the word to others who may be interested in joining this growing coalition Let us know what other skills & resources you may have to contribute to our efforts EWCG 000007 Eagle's Water - A Vital Community Resource We Can't Afford To Sell Help us keep it under locol control! Situation: After decades of quality water service Eagle Water Company (EWC)-which serves 4,200 Eagle homes and businesses-has decided to sell their water rights and system. French-based multinational for-profit corporation Suez Water is attempting to purchase this crucial utility system- with a stated goal being to divert water from Eagle to support proposed northwest Boise foothills development. They intend to fund this takeover by hiking rates for customers in the impact area by as much as 200-300%, while also increasing rates for existing Suez customers across the valley. Suez has a D- rating with the Better Business Bureau and a reputation for extremely poor customer service and maintenance, heavy chemicalization of their water and massive rate hikes in municipalities across the US. Eagle Water Customer Group (EWCG) is an unincorporated non-profit association formed specifically to participate in the ldaho Public Utilities Commission (IPUC) process as advocates for maintaining local control and stable, affordable rates for our most critical natural resource. This growing coalition includes Eagle residents and Suez customers across the valley who will be impacted by the projected rate increases as well as other citizens who simply object to a foreign company coming in to take control of our utilities strictly for profit. Attorney Norm Semanko has generously agreed to represent EWCG on a contingenry basis through the IPUC process. Thanks to his excellent work, we have already been granted approval to intervene, which is an important first step. What you can do to help: Attend the Eagle City Council Meeting Tuesday, January 22, at 5 pm to show your support for the city purchasing EWC instead of Suez and to learn details of the city's Right of First Refusal Agreement with EWC. Submit written comments to the IPUC detailing why you object to Suez buying EWC and asking that the IPUC hold a meeting in Eagle allowing public testimony (Case number: SUZ-W-18-02). httos://www. ouc. ida ho.eov/forms/casecomment.asox Join our Facebook page-there is strength in numbers and this is the best way to keep up with developments as they occur. https://www.facebook.com/erou os/EasleWaterCustomers/ Donate to EWCG to support printing costs, mailings, etc. Donations made payable to Eagle Water Customer Group can be sent to Janet Buschert at 235 W. Floating Feather Rd., Eagle, lD 83616. o a Email Jane Rohling at imrohlins@email.com to get on our contact list so we can keep you informed. Contact local media, write letters to the editor and Op-Ed's about the situation Spread the word to other homeowners, HOA leaders, businesses, private well owners, current EWC and Suez customers-all of whom could be negatively impacted by Suez taking ownership of this critical water system. o a a a a EWCG 000008 - IrI Eagle's Water - A Vital Community Resource We Can't Afford To Sell Help us keep it under local control! Situation: After decades of quality water service Eagle Water Company (EWC) - which serves 4,200 Eagle homes and businesses - has decided to selltheir water rights and system. French-based multinational for-profit corporation Suez Water is attempting to purchase this crucial utility system - with a stated goal being to divert water from Eagle to support proposed northwest Boise foothills development. They intend to fund this takeover by hiking rates for customers in the impact area by as much as 200 - 3@%, while also increasing rates for existing Suez customers across the valley. Suez has a reputation for poor customer service, heavy chemicalization of their water and excessive rate hikes in municipalities across the country. A 2010 Food & Water Watch report, "Suez Environment's Poor Record in the U.S.," documents decades of problems resulting in several major cities cancelling Suez contracts. January 30 Eagle Water Customer Group (EWCGI is an unincorporated non-profit association formed specifically to participate in the ldaho Public Utilities Commission (IPUC) process as advocates for maintaining local control and stable, affordable rates for our most critical natural resource. This coalition includes Eagle residents and Suez customers across the valley who will be impacted by the projected rate increases as well as other citizens who simply object to a foreign company coming in to take control of our utilities strictly for profit. Attorney Norm Semanko has generously agreed to represent EWCG on a contingency basis through the IPUC process. Thanks to his excellent work, we have already been granted approval to intervene, which is an important first step. scheduling conference has been set for the !PUC attorney and staff, and the attorneys for the other parties, including EWCG. We'llshare new developments on our Facebook group page as soon as we hear from our attorney. What you can do to help: Submit written comments to the IPUC detailing why you object to Suez buying EWC and asking that the IPUC hold a meeting in Eagle allowing public testimony (enter case number: SUZ-W-18-02) www. puc. idaho.gov/forms/casecomment.aspx Join our Facebook page and email list to learn more and keep abreast of developments in the case. there is strength in numbers and knowledge! www.facebook.com./erouos/EasleWaterCustomers,/ EmailJane Rohling at imrohling@gmail.com to get on our contact list. Contact local media to tell them what's happening and why you object and send Op-Ed's and letters to the editor about the situation in Treasure Valley publications. Donate to EWCG to support printing costs, mailings, etc. Donations made payable to Eagle Water Customer Group can be sent to Janet Buschert at 235 W. Floating Feather Rd. in Eagle Volunteer: Let us know what other skills & resources you may have to contribute to our efforts. Spread the word to others who may be interested in joining this growing coalition. EWCG_000009 a a a a a a 7 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQIJEST NO. 9: Please state whether board memberc or officers of EWCG have communicated with Homeowners Associations or similar organizations to request that they refise to meet with SUEZ to discuss its proposed acquisition of Eagle Water Company assets, or have directed any members of EWCG to make such rcquests to these organizations. RESPONSE TO REQUEST FOR PRODUCTION NO. 9: No. EWCG has no board members or officers. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 10 4849-4504-7688v3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER rDAHO rNC. SPONSOR(S)I Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO. l0: Please provide copies of any informational materials, pamphlets, statements, or other communications that EWCG has published to its members or to the public regarding the subject matter of this proceeding. RESPONSE TO REQT EST FOR PRODUCTION NO. 10: EWCG identifies the documents attached hereto as Bates Nos. EWCG_000004-9, EWCG's Facebook Group page (excluding individual posts), see , and EWCG's Nextdoor notificatioru see httos://ios.nextdoor.com/eventdid/eagle/eagle-water- customers-crouFmeeting-with-norm-semanko-2661820. as communications distributed by or on behalf of EWCG. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page l l 4849.{5O4-7688v3 PRESS RELEASE For lmmediate Release: 1-18-19 EWCG Challenges Proposed Purchase of Eagle Community's Water Resources by Multinational Suez Water 11 ca IPUC Grants Non-Profit a Voice in Effortto ProtectWater Rates and Services - Rules Citizens Group Can Formally lnteruene The ldaho Public Utilities Commission (IPUC) has formally granted a local non-profit association the right to intervene against French-based multinational conglomerate Suez Water's application to buy a local water system which has provided service to 4,200 Eagle homes and businesses for nearly half a century. Eagle Water Customers Group (EWCG) is a growing coalition of concerned citizens formed in direct response to the Joint Application filed by Suez and seller Eagle Water Company (EWC) in November, 2018. ln a petition filed on December 27, EWCG asserts their members stand to be impacted by significant rate increases resulting from the proposed acquisition, as set forth in the Joint Application. Suez proposes astronomical rate hikes for current EWC users in order to fund the diversion of massive volumes of water from Eagle to support future development in the arid northwest Boise foothills. Existing Suez customers across the Boise Valley would also see rate increases to support the sale. EWCG asserts this action would not be in the best interest of the public and would impose financial hardship on many Eagle residents and businesses while threatening the quantity and quality of their available water and associated customer services. According to EWCG attorney Norm Semanko, "if this Joint Application is granted rate increases would exceed 200o/o for residential customers and 300% for commercial customers, in just three years. This threatens to impose considerable'rate shock'on Eagle Water customers and could also impact service to customers and other aspects of the public interest." On January 12 an overflow crowd of concerned citizens packed the Eagle Library where EWCG organizers and Mr. Semanko shared details and answered questions about the IPUC process and how to most effectively oppose the sale. Many in the crowd voiced their alarm that Suez's already steep rates would climb even higher with this sale. Some were disturbed that a lot of senior water rights would be lost to a foreign company if the application is approved. lt was noted that a multitude of public comments about Suez on the IPUC website highlight unreasonably high rates and poor customer service from a company that focuses more on corporate profits and protecting the interests of shareholders than on taking care of their customers. EWCG members will attend the Eagle City Council meeting at Eagle City Hall Tuesday, January 22, al6 pm to voice their support for purchase of EWC by the city and to hear discussion of the 2008 lntertie Agreement which details the Right of First Refusal between the City of Eagle and Eagle Water Company. The press is encouraged to attend. A scheduling conference has also been set for January 30 between IPUC staff and the attorneys for EWCG and other intervenors in the case. EWCG is an unincorporated ldaho non-profit made up of ratepayers, taxpayers and concerned citizens including EWC customers who have come together to oppose the sale of this community's most vital natural resource to a foreign based for-profit corporation. For additional information please contact: Norman M. Semanko Parsons Behle & Latimer 800 West Main Street, Suite 1300, Boise, ldaho 83702 (208) 863-7921 EWCG_o00004 PRESS RELEASE For lmmedlate Release: 1-2G19 Eagle Water Customer Group Challenges The Proposed Purchase Of Eagle Community's Water Resources By Multinational suez Water The ldaho Public Utilities Commission Rules The Cltlzens Group Can Formatly lntervene - It Grants A Voice To The Non-Profit Efforts ln Protecting Water Rates And Services The ldaho Pubtlc UtiUties Commission (lPUq has tormally granted a local non-profit association the right to intervene agalnst French-based multinational conglomerate Suez Wate/s appllcation to buy a local water system and all water rights. The loca] water system has provided servlce to 4,200 Eagle homes and businesses for nearly half a century. Eagle Water Customers Group (EWCG) is a growing coalition of concerned citizens formed in direct response to the Joint Application filed by Suez and the seller Eagle Water Company (EWg in November. ln a petition fited on December 27,fltlCG asserts their members stand to be impacted by significant rate increases and terms resulting From the proposed acquisition, as set forth in the Joint Application. The proposed plan diverts a massive volume of Eagle we[[ water to future devetopments in the arid northwest Boise foothitts, instead of creating new sources of water. ln order to tund the diversion of masslve volumes of water out oF Eaglq Suez is requesting IPUC permission forastronomicaI rate hikes from current customers. Existlng Suez customers across the Boise Va[ey woutd also see rate increases to support the sate. EWCG asserts this acUon is not in the best interest of the public !t woutd impose financlal hardship on many Eagle residents and businesses whiJe threatening the quantlty, quality and customer seMce for thelr water suppty. According to a report presented to the City oF Eagle byTlm Farrell from Mountain Water Works, iF this applicaUon ls granted by the IPUC, the rates will increase 325% ln the winter, when water usage is low and 412% in the summer, when water usage is high, comparing price per galton rates. Due to the location, most oF the residents irrigate with city water, so the price change wilt likety reduce the lush [andscape in Eagle. On January 12h an overflow crowd of concerned citizens packed Eagle Library to discuss concerns about the sale and how to oppose the sale. The pubUc concerns included: steep rate increases, loosing water rights, adding ground water to wetl water requiring chlorine, losing water rights to a foreign company, going from a water company that focuses on the community to one that focuses on the bottom [ine. Many peopte posted their comments on the IPUC website, hightighting Suez's poor customer service, statlng Suez onty focuses on corporate profit and not the community interests. EWCG memberswitl be attending the Eagte City Council meeting at Eagte City Halt thisTuesday, January 22, at6 pm to voice their support for the City of Eagle to purchase the Eagle Water Company. The EWCG members are ancious to hear about the 2008 agreement between the City of Eagle and the Eagte Water Company which detaits the First Right of ReFusa[ between the City of Eagle and the Eagle Water Company. The prese is encouraged to attend. A scheduling conference has been set for January 30. The conterence witl inctude IPUC stafF, attorneys for ElnlCG and other intervenors in the case. EWCG is an unincorporated ldaho non-profit made up of ratepayers, taxpayers and concerned citizens including EWC customers who have come together to oppose the sale of this community's most vital natural resource to a foreign based tor-profit corporation. For additional information please contact: Norman M. Semanko Parsons Behle & Latlmer 800 West Main Street, Suite 1300, Boise, ldaho 83702 (208) 863-7e21 EWCG_o00005 oilo q)tsao(g Ur Cus Concerned about changes coming to Eagle Water Company Customers? foin the crowd! Cet the facts from Attorney Norm Semanko and find out how you can get involved. SATURDAY, f ANUARY 12, 10:00 AM - 12:00 PM Eagle Public Library meeting room Cet the facts from attorney Norm Semanko and find out how you can help stop this loss of local control over our most precious, irreplaceable natural resource! French-based multinational for-profit Suez Water has applied to the ldaho Public Utilities Commission (IPUC) to purchase the Eagle Water Company. lf they are successful rates will skyrocket by as much as 200-300% for thousands of Eagle residents and businesses. Other Suez customers across the Boise Valley will also see increases to pay for the diversion of massive volumes of Eagle's water for proposed northwest Boise development! This threatens not only the cost of our water but the quality and quantity of that resource and of the customer service associated with it. We are forming a coalition to stop this sale and have retained the services of experienced water attorney Norm Semanko to do just that. We have already been appointed intervenors by the lPUC - a major first step - but we need your help moving forward. Come to this meeting to learn how you can become involved! Please join our Facebook group to stay informed: w ww.f ac eboo k. co m / g ro u p s/ E agl eW ate r C u sto me r s/ The Eagle Water Cuslomers Croup is a nonprofil g,rassrools organization iormed specifically to track and provide input into the ldaho Public Utilities Commission's process regarding the proposed sale of Eag,le Water CSWU6 OOOOO6 Eagle's Water - A Vital Community Resource We Can't Afford To Sell Help us keep it under local control! Situation: After decades of quality water service Eagle Water Company (EWC) - which serves 4,200 Eagle homes and businesses - has decided to sell their water rights and system. French-based multinational for-profit corporation Suez Water is attempting to purchase this crucial utility system - with a stated goal being to divert water from Eagle to support proposed northwest Boise foothills development. They intend to fund this takeover by hiking rates for customers in the impact area by as much as 200 -3OOyo, while also increasing rates for existing Suez customers across the valley. Suez has a D- rating with the Better Business Bureau and a reputation for extremely poor customer service and maintenance, heavy chemicalization of their water and massive rate hikes in municipalities across the US. Eagle Water Customer Group (EWCGI is an unincorporated non-profit association formed specifically to participate in the ldaho Public Utilities Commission (IPUC) process as advocates for maintaining localcontroland stable, affordable rates for our most critical natural resource. This coalition includes Eagle residents and Suez customers across the valley who will be impacted by the projected rate increases as well as other citizens who simply object to a foreign company coming in to take control of our utilities strictly for profit. Attorney Norm Semanko has generously agreed to represent EWCG on a contingency basis through the IPUC process. Thanks to his excellent work, we have already been granted approval to intervene, which is an important first step. What you can do to help: Join our Facebook page - there is strength in numbers and this is the best way to keep up with developments as they occur Submit written comments to the IPUC detailing why you object to Suez buying EWC and asking that the IPUC hold a meeting in Eagle allowing public testimony (Case number: SUZ-W-18-02) htt os://www. ouc. idaho.sov/forms/casecomment.asox a a a a a Contact local media to tell them what's happening and why you object Write letters to the editor and Op-Ed's about the situation Donate to EWCG to support printing costs, mailings, etc. Donations made payable to Eagle Water Customer Group can be sent to Janet Buschert at 235 W. Floating Feather Rd. in Eagle a a Sign up on our contact sheet so we can keep you informed as we move fonruard Contact Eagle City Council to let them know you support their efforts to buy Eagle Water Company http://www.citvofeaele.orslFormCenter/Contact-Us-11/Contact-the-Citv-59 a Let us know what other skills & resources you may have to contribute to our efforts a Spread the word to others who may be interested in joining this growing coalition EWCG_000007 Eagle's Water - A Vital Community Resource We Can't Afford To Sell Help us keep it under local control! Situation: After decades of quality water service Eagle Water Company (EWC)-which serves 4,200 Eagle homes and businesses-has decided to sell their water rights and system. French-based multinational for-profit corporation Suez Water is attempting to purchase this crucial utility system- with a stated goal being to divert water from Eagle to support proposed northwest Boise foothills development. They intend to fund this takeover by hiking rates for customers in the impact area by as much as 200-300%, while also increasing rates for existing Suez customer across the valley. Suez has a D- rating with the Better Business Bureau and a reputation for extremely poor customer service and maintenance, heavy chemicalization of their water and massive rate hikes in municipalities across the US. Eagle Water Customer Group (EWCG) is an unincorporated non-profit association formed specifically to participate in the ldaho Public Utilities Commission (IPUC) process as advocates for maintaining local control and stable, affordable rates for our most critical natural resource. This growing coalition includes Eagle residents and Suez customers across the valley who will be impacted by the projected rate increases as well as other citizens who simply object to a foreign company coming in to take control of our utilities strictly for profit. Attorney Norm Semanko has generously agreed to represent EWCG on a contingency basis through the IPUC process. Thanks to his excellent work, we have already been granted approval to intervene, which is an important fimt step. What you can do to help: Attend the Eagle City Council Meeting Tuesdan January 22, at 6 pm to show your support for the city purchasing EWC instead of Suez and to learn details of the city's Right of First Refusal Agreement with EWC. Submit written comments to the IPUC detailing why you object to Suez buying EWC and asking that the IPUC hold a meeting in Eagle allowing public testimony (Case number: SUZ-W-18-02). htt os ://www. puc. ida ho.eov/forms/casecom ment.asox Join our Facebook pate-there is strength in numbers and this is the best way to keep up with developrnents as they occur. httos://www.facebook.com/groups/EasleWaterCustomers/ Donate to EWCG to support printing costs, mailings, etc. Donations made payable to Eagle Water Customer Group can be sent to Janet Buschert at 235 W. Floating Feather Rd., Eagle, ID 83615. EmailJane Rohling at imrohline@email.com to get on our contact list so we can keep you informed. a a Contact local media, write letters to the editor and Op-Ed's about the situation. Spread the word to other homeowners, HOA leaders, businesses, private well owners, current EWC and Suez customers-all of whom could be negatively impacted by Suez taking ownership of this critical water system. EWCG_000008 o a a a Cus Eagle's Water - A Vital Community Resource We Can't Afford To Sell Help us keep it under local control! Situation: After decades of quality water service Eagle Water Company (EWC) - which serves 4,200 Eagle homes and businesses - has decided to sell their water rights and system. French-based multinational for-profit corporation Suez Water is attempting to purchase this crucial utility system - with a stated goal being to divert water from Eagle to support proposed northwest Boise foothills development. They intend to fund this takeover by hiking rates for customers in the impact area by as much as 200 -3OO%, while also increasing rates for existing Suez customers across the valley. Suez has a reputation for poor customer service, heavy chemicalization of their water and excessive rate hikes in municipalities across the country. A 2010 Food & Water Watch report, "Suez Environment's Poor Record in the U.S.." documents decades of problems resulting in several major cities cancelling Suez contracts.January 30 Eagle Water Customer Group (EWCG) is an unincorporated non-profit association formed specifically to participate in the ldaho Public Utilities Commission (IPUC) process as advocates for maintaining local control and stable, affordable rates for our most critical natural resource. This coalition includes Eagle residents and Suez customerc across the valley who will be impacted by the projected rate increases as well as other citizens who simply object to a foreign company coming in to take control of our utilities strictly for profit. Attorney Norm Semanko has generously agreed to represent EWCG on a contingency basis through the IPUC process. Thanks to his excellent work, we have already been granted approvalto intervene, which is an important first step. scheduling conference has been set for the IPUC attorney and staff, and the attorneys for the other parties, including EWCG. We'llshare new developments on our Facebook group page as soon as we hear from our attorney. What you can do to help: Submit written comments to the IPUC detailing why you object to Suez buying EWC and asking that the IPUC hold a meeting in Eagle allowing public testimony (enter case number: SUZ-W-18-02) www. puc. ida ho. eovlforms/casecomment.asox Join our Facebook page and email list to learn more and keep abreast of developments in the case. there is strength in numbers and knowledgel www.facebook.com/erouos/EasleWatercustomers/ EmailJane Rohling at imrohline@email.com to get on our contact list. Contact local media to tell them what's happening and why you object and send Op-Ed's and letters to the editor about the situation in Treasure Valley publications. Donate to EWCG to support printing costs, mailings, etc. Donations made payable to Eatle Water Customer Group can be sent to Janet Buschert at 235 W. Floating Feather Rd. in Eagle a a Volunteer: Let us know what other skills & resources you may have to contribute to our efforts. a a a a Spread the word to others who may be interested in joining this growing coalition. EWCG_000009 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC. SPONSOR(S): Shelley Brcck, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO. 11: Does EWCG contend that the rate incrcases 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. RESPONSE TO REQUEST FOR PRODUCTION NO. ll: Yes. EWCG has no knowledge or information indicating that the City of Eagle would raise the existing Eagle Water Company rates by more than 200% for residential customers and more than 300% for commercial customers within 3 years, like SUEZ has proposed to do. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 12 4849-{$4-7688v3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FrRST PRODUCTTON REQUEST OF SUEZ WATER IDAHO INC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO. 12: Please identify and describe, in detail, the "other aspects of the public interesf' that you contend could be impacted by the Joint Application as stated in EWCG's Petition to Intervene. Please also describe EWCG's position on how the Joint Application would impact aspects of the public interest, and provide any and all relevant analyses, studies, or other documents supporting this position. RESPONSE TO REQUEST FOR PRODUCTION NO. 12: SUEZ's proposal to ship Eagle Water Company's supply to other parts of SUEZ's service area, to require people to drink chlorinated surface water, to force the acquisition of Eagle Water Company notrvithstanding the City of Eagle's contactual right of first refusal, to wrest away local control, and to impose "rate shock" on existing residents and businesses through its proposed rate hikes are all contrary to the public interest. Without limitation, EWCG also incorporates and adopts all of the public interest grounds included in the public comments submitted in this matter, which are posted on the PUC's website, in opposition to the SUEZ proposal, and also reserves the right to assert additional public interest grounds as they are discovered in these proceedings. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQLJEST OF SUEZ WATER IDAHO, INC. - Page 13 4E494504-7688v3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF'SUEZ WA,TER IDAHO INC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQT EST NO. 13: Has EWCG asserted to its members or to the public that'bne of the biggest complaints ... that existing Suez customers have is the taste (and even the smell) of their weter because of all of the chemicals Suez adds to the water?" If so, please describe, in detail, the factual basis for this assertion and provide all relevant analyses, studies, communications, or other documents supporting this position. Please also identifr all persons to whom you attribute such complaints. RESPONSE TO REQLIEST FOR PRODUCTION NO. 13r EWCG is not aware of the source of the quote 'bne of the biggest complaints . . . that existing Suez customers have is the taste (and even the smell) of their water because of all of the chemicals Suez adds to the water," nor does the request identiff the source. EWCG is therefore without sufficient knowledge to respond to this specific request. EWCG is aware, however, of concerns with the taste, smell and appearance of water supplied by SUEZ, as reported in local news stories and public comments submitted to the PUC in this matter. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 14 4E494504-76EEv3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FrRST PRODUCTION REQUEST OF SUEZ WATER IDAHO rNC. SPONSOR(S): Shelley Brock, Janet Busehert and Jane Rohling, EWCG members. RBQITEST NO. 14: Has EWCG asserted that *Suez has a D- rating with the Better Business Burcau and a reputation for extnemely poor cruilomer service and maintenance, heavy chemicalization of their water and massive rate hikes in municipalities acro$ the US?' Please see Exhibit 2. If so, please describe, in detail, the factual bases for each of these assertions and provide all relevant analyses, studies, communications, or other documents supporting these assertions. RESPONSE TO REQITEST trOR PRODUCTION NO. 14: Yes. EWCG identifies the documents attached hereto as Bates Nos. EWCG_000010-20 in response to this rcquest. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 15 48494504-768Ev3 Suez Water ldaho. Inc. I Conrplaints I Better Business Bureau@ Profile Complaints Suez Water ldaho, lnc. Page I of2 I AZae W Victory Rd Boise,lD 83709-4165 O http://www.mvsuezwat er.com/ E Emailthis Business J l2oal362-7304 Better Business Bureau' Home > ldaho > Boise > Utilitv Water Company > Suez Water ldaho. lnc. > Complaints ComplaintType:Billing/Collection lssues Status:Answered 04t0612017 Jan 2017 I received my water bill and it was $66.13 which was $28.05 higher than the highest bill in the last 7 years during the same time frame. I paid the bill thinking it was a lot higher, but had thought maybe they had raised the rate per unit or something. Then I got my March 2017 bill and it is exactly 3 times more than normal $109.34. The previous years had been around $35 for 2 months. I opened the water cover and found that the meter was counting sporadic numbers then it would stop and start again for no reason. I finally shut the water valve off and it made the meter stop, when lturned the water back on the meter began working correctly and has been working correctly for 3 days now. I called SUEZ and they are unwilling to change the bill as they said I must have had a leak, even though the technician came out a left a card stating it didn't have a leak. I had contacted the company 3 times to check into the problem and they told me that they would send sorneone to my ho... w25/2017 ComplaintType:Billing/Collection lssues Status:Answered Complaint Details Unavailable https://wu"rv.bbb.org/us/id/boise/profile/utility-water-company/suez-rvater-idaho-inc- l 296-EWCG OOOOzil4t20r910 Suez Water ldaho, Inc. lComplaints I Better Business Bureau@ Profile PageZ of? @ 2019, Council of Better Buslness Bureaus, lnc., separately lncorporated Better Buslness Bureau organlzations ln the US, Canada and Mexlco, and BBB lnstltute for Marketplace Trust. AllRlghts Reserued. https:/Avww.bbb.org/uVid/boise/profile/utility-water-company/suez-water-idaho-inc- l 29G... fl1ri8d0001 1 SUEZ Water New York, Inc. I Complaints I Better Business Bureau@ Profile Page I of5 Better Business Bureau' Home > New York > West Nvack > Utilitv Water Comoanv > SUEZ Water New York. lnc. > Com; Complaints SUEZ Water New York, lnc. I :eo w Nyack Rd West Nyack, NY 10994-1743 O htto://www.mvsuezwat er.com/ J ptql637-s337 Complalnt Type: Problems with ProducUService Status: Answered 12tO4t2018 Suez shut off my water with any notice before, I live there for over a year, and they claim that they sent a notice to the old owner of the building, and they believe that the Apartment is vacant. When this is a Living apartment with a family of 7 Children, the youngest is 15 Months, they did not care when i explained that to them. I asked them to tell me the amount and i will pay it off first, and i should have water, and will than open the account for now on. but they did not agree. ComplaintType:BillingiCollection lssues Status:Answered 11tO712018 I have been trying to resolve this issue with Suez for over 3 years now speaking with Suez employees and writing letters about this issue.. I contacted the state regulator for Utilities who said I need to take Suez to court for violating bankruptcy laws but I did not. I was trying to be patient hoping this issue would be resolved. I recently was told by the White Plains Bankruptcy division to contact the BBB because my account has gone into collection. The collection department now has the information showing my coverage in bankruptcy and said it is being investigated and I have 30 days. I am supposed to contact them, not them contacting me in thirty days. THIS CAN AFFECT MY CREDIT, WHO IS GOING TO HELP ME? PLEASE HURRY, ITS SUEZ'S ISSUE THAT THEY ARE PUTTING ON ME!. THEY WERE GIVEN THE PROPER DOCUMENTATION YEARS AGO! I SENT THEM NUMEROUS LETTERS AND THEY AGREE THAT IAM RIGHT HOWEVER, THEY SAID THEY HAVE A COMPUTER ISSUE ON THEIR END. NOW MY ACCOUNT IS IN COLLECTIONS AND... https://www.bbb.orglus/ny/west-nyack/profileiutility-water'company/suez-water-new-york... 2t1tflP28Fr000012 suEz waterNew York, Inc. I complaints I Better Business Burcau@ profile Page 2 of5 Gomplaint Type: Billlng/Collection lssues Status: Unanswered 1011112018 I had an lssue wlth receivlng a shut off notice. I did not recelve a shut ofr notce 10 days prlor to my water belng shut offtherefore I had called up customer seMce and asked to speak to a manager. I was never put on when I manager rather I was put on hold whlle the customer seMce representative spoke to a manager and came back on the phone to tell me that theywould not remove the $5O charge. I have pald my bllt In full mlnus that $5O charge. Over the past few weeks I have pald hundreds of dollars to this water company. I had recelved a shut off notlce back in July but then had made a payment and never recelved a new shut off notice. My water was shut off ln September over two months later. After speaklng to the regresentatlve,ltwas made to seem as though I should be luckythat I had a 6O day grace period. Thafs not how shut ofi notlces work They have a certaln date that they are supposed to shut you off by and once you make a payment there is no more pending shut off in ... Complaint Type: Problems with ProducUService Status: Unanswered oBt2012018 We llve for 30 years in our home, promptly paying our bllls. The issue is with the water company, now callSuez that used to be called United water. Our monthly bills were about $4O a month untll Suez took over United water. Since Suez took over our bills had doubled, and we pald or bllls promptly. Then we started getting smaller blll, llke $10 to $4O a month. One daywe get a correctlon blll, which was an estlmate of around $600. We called the company asking what is thls new charge and they said that the meter wasn't functlonlng properly. We tried to dlspute thls amount to no avall, they wouldn't listen nor would they negotiate the amount. For lack of cholce we had to agree, othenrise theyll disconnect our water. So since we couldn't pay such a large amount we asked for payments - and they agreed to set the payments at $45 per month - which we diligently pald. On August', we come home and there is no water. Called Suez to be told that for lack of payments they shut our water. 1a... Complaint Type: Problems with ProducUServlce Status: Unanswered 08/13/2018 https://www.bbb.org/us/ny/west-nyack/profile/utility-water-company/suez-water-new-york. .. frYlh8r1000013 SUEZ WaterNew York, Inc. I Complains I Better Business Bureau@ Profile Page 3 of5 I have been waiUng over a year and a half for the water company to change the water meter... when they cEme to change lt lnitially the tech sald he has to tum off the water outslde because the lnslde value ls to old. he sald he would replace the value when he changed the meter. he went outslde to turn of the outside valve and the valve was broken and needed to be done at the street. He said he would put the order ln and lwould be noUfled. I have been calllng for a year and a half. about 5 months ago a crew showed up to change the outside valve and sald they needed to open up the street and that ls a dlfferent crew.. they were suppose to do thls today (Aug ", 2018) after me calling once a week for the past year and a half... only person who came todaywas to mark the spot he had no ldea when theywould come back.. I called today and spoke to Jonathan, he told me they were only suppose to mark the spot for the person to turn lt offthe change the meter... thls ls not correct... GomplalntType:Billing/Collection lssues Status:Unanswered 1il2712017 We have a meter wlth thls water company slnce 2015. We are paylng our water blll on tlme every month. This house has two unlts and each unlt has a separate water meter. Everythlng was golng flne. All of a sudden, ! recelve another blllshowlng that we owed an amount of 1786.77 dollars. lt was shocldng for me to see that big bill. So I contacted their office using thls number #$$4##4###. I spoke to thelr representaUve and he explained to me me that they made a mistake by mixlng up the tvro mete6 and they have corrected that mlstake now. And they want to collect the dlfference ln thls wrltten amount from approxlmately last three years. lfs shocklng for me to have to pay thls amount when I have no ldea what ls going on. lt was thelr mlstake that they mlxed up everythlng and messed up. ! am unable to pay thls amount as lt came all of a sudden on my head. The company made a mlstake I shouldn't have to sufrer for that Please resolve thls matter and help me out as l'm not ln a posltlon ... Complalnt Type: Bllling/Collectlon lssues Status: Unanswered 1111712017 ff'nOfl Dear Slr or Madam, I am reachlng out to you today to address an lssue that has not been resolved, desplte my conslstent attempts to do so. Simply Fut my water bill is carrying a past due balance that ls not from nry account The balance, from another person enUrely unrelated to me, was mlstakenly added to my account around the time Unlted Water was transltlonlng lnto Suez and, desplte the fact that I outrlght proved this by shotrlng them the sodal securlty number and phone number of that account was not mine (as well as the fact that I never Ilved at the address they clalm I accrued the past due balance a$. they contlnue to send me bllls wlth these past due balance and flnal termlnatlon notices threaUng to shut off my water. Thls has been happening now since I moved from my former resldence at'""''t in htps://www.bbb.orglus/ny/west-nyack/profile/utility-water-company/suez-water-new-yr*... 2FIX88[800014 SUEZ WaterNew Yorlg Inc. I Complaints I Better Business Bureau@ Profile Page 4 of5 Tappan, NY, two years ago. I have slnce llved at s .*s' 4"." "' ln Congers, Ny and now at "' ''as" rr " .offi NY and every fe... ComplalntType: Billing/Collection lssues Status: Unanswered 07n212016 Suez has removed the meter on a commerclal property but ls refuslng to give the demolltion letter slnce the last tenant left a balance on the accounl As a representative forthe landlord, I have glven Suez all of the lnformaUon they requested. First, they wanted proof of tenancy, then they sald they want proof of address slnce the 911 address has changed(which I had already send 3 months ago when I needed somethlng else.). I got the proof but they refused to look at it stating, 'as the owner, if you rlnnt the demolltlon letteryou must pay the balance.' lfeel thls is blackmalllng the LL to pay for a prevlous and dellnquent tenant I asked to speak to a supervlsor and wes told she ls on the phone, when I asked for her to call me back the representatlve decllned to agree to have her retum my call. she said she would give a message but dld not take my contact lnfo. ComplalntType: Billing/Collection lssues Status: Unanswered 0610912016 ln 2015 I was advlsed by Suez that the water meter needed to be updated so that lt could be read automatically. I followed all instructlons as I was threatened with fines lf meter couldn't be updated. They send I company to update the meter. Slnce then I had to call Suez almost monthly as I was charged repeatedly a $25 surcharge for an estlmated readlng. I called on a monthly basls to have the fee removed and to lnqulre why the automatlc readlng dld not happen. I had a servlce agent come to my house and check the eguipment, and was assured that everythlng was ln order. t was told that the truck wlto drives by to take the readlng wlll be asked to go slower to recognize the reading. lwas assured that everythlng was ln ordet but I continued to recelve estimated bills. My May bill agaln lists a $25 surcharge for an estlmated readlng, although lwas assured thls should not happen agaln. Complalnt Type: Problems with ProducUService Status: Unanswered o411412016 I have scheduled a yvater meter removal lor 2f'116. I was told that the meter at t he curb needs to be cleaned. lt has been over 2 months. I call on an almost daily basis https://www.bbb.org/uVny/west-nyack/profile/utility-water-company/suez-water-new-york... #l[881800015 SUEZ WaterNew Yorb Inc.lComplains I BetterBusincss Bureau@ Profile Page 5 of5 and am told that the supeMsor ls busy, the meter shop is on lunch... although I made sure to call at various tlmes. I have spoken to Margarit who promlsed me she would resolve the issue and have not heard from her in 3 weeks. When I ask for her 1 am to6 that she is on the phone. The demollilon for thls bulldlng Is waltlng on the meter removal and lt ls causlng the buslness a lot of anqulsh. Load More @ 2019, Council of Better Buslness Bureaus, lnc., separately lncorporated Better Buslness Bureau organlzations in the US, Canada and Mexlco, and BBB Institute for Marketplace Trust All Rlghts Reserved. https://www.bbb.org/us/ny/west-nyaclc/profile/utility-water-company/suez-water-new-york... f1fli8l800016 SUEZ North Anrerica I Better Business Bureau@ Profile Page I of2 Better Business Bureau' Home > Delaware > Wilminoton > Utilitv Water Companv > SUEZ North America SUEZ North America Utility Water Company Accredlted BBB Ratlng Customer Reviews Customer Complalnts This business is not BBB Accredited ***** 5 complaints closed in last 3 years l complaints closed in last 12 monthsD. Averaoe of 8 Customer Reviews Customer Complaints 5 Customer Complaints Customer Reviews 8 Customer Reviews Business Details BBB File Opened:10t1t1969 https://rvu,w.bbb.org/us/de/wilmington/profi1e/utility-water-company/suez-north-america-0... 271{8818000" SUEZ North America I Better Business Bureau@ Profile Page 2 of2 Mr. Larry Finnicum, Manager of Operations for Delaware Addltlonal Contact lnformation Fax Numbers (3O2)633-s921 (302) 633-s910 Phone Numbers (302)633-s90s Addresses V emaitthis Business Website Addresses htto://www. u n itedwater.com/delawa relindex.as ox Business Categories Utilitv Water Comoanv c 2019, Council of Better Business Bureaus, lnc., separately incorporated Better Business Bureau organlzations in the US, Canada and Mexico, and BBB lnstitute for Marketplace Trust. All Rights Reserved. https://www.bbb.org/us/de/wilmington/profile/utility-water-company/suez-north-america-0... r7lflPr8Joootg Suez Water ldaho. lnc. I Better Business Bureau@ Protile Page I of2 Better Business Bureau, Home > ldaho > Boise > Utilitv Water Comoanv > Suez Water ldaho, lnc. Suez Water ldaho, lnc. Utility Water Company Accredited BBB Rating Customer Revlews Customer Complalnts This business is not BBB Accredited ***** 2 complaints closed in last 3 years l complaints closed in last 12 monthsA+Averaoe of 1 Customer Review Customer Complaints 2 Customer Complaints Customer Reviews l Customer Reviews Business Details BBB Flle Opened: 41111969 hups://rvwrv.bbb.org/us/id/boise/profile/utiliry-water-company/suez-water-idaho-inc- rzF#.9G298?ftlrgq Suez Water ldaho. lnc. I Better Business BureaudD Profile Page 2 of2 Additlonal Contact lnformation Phone Numbers (208)362-1300 Addresses V emaitthis Business Llcenslng lnformatlon This business is an industry that may require professional licensing, bonding or registration. BBB encourages you to check with the appropriate agency to be certain any requirements are currently beinq met. Business Categories Utilitv Water Companv icr 2019, Council of Better Business Bureaus, lnc., separately incorporated Better Business Bureau organizations in the US, Canada and Mexico, and BBB lnstitute for Marketplace Trust. All Rights Reserved. hups://rvww.bbb.org/us/idlboise/profile/utility-water-company/suez-water-idaho-inc- rzf#.9c298?fo2Pq EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQIJEST OF SUEZ WATER rDAHO INC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO. 15: Does EtilCG admit that SUEZ Water Idatro Inc.-the Applicant in this proceeding-has an A+ rating with the Better Business Bureau as of February 2019? RESPONSE TO REQUEST FOR PRODUCIION NO. 15: Yes. EWCG also admits the one-star rating and negative customer comment, subsequently listed next to the BBB rating for SUEZ Water ldaho Inc., and SUEZ North America's D- listing with the BBB, as set forth in the documents attached hereto as Bates Nos. EWCG 000017-20. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 16 4E49-4504-7688v3 SUEZ North America I Bener Business Bureau@ Profile Page I of2 Better Business Bureau' Home > Delaware > lljlgiloton > Utilitv Water Comoanv > SUEZ North America SUEZ North America Utility Water Company Accredited BBB Ratlng Customer Reviews Customer Complaints This business is not BBB Accredited ***** 5 complaints closed in last 3 years l complaints closed in last'12 monthsD. Averaqe of 8 Customer Reviews Customer Complaints 5 Customer Complaints Customer Reviews 8 Customer Reviews Business Details BBB File Opened:10t1t1969 hups://wmv.bbb.org/us/de/wilmington/profile/utility-water-company/suez-north-america-0... z7ltPr8rfoo017 SUEZ North Arnerica I Better Business Bureau,O Profile Page 2 of2 Mr. Larry Finnicum, Manager of Operations for Delaware Additlonal Contact lnformation Fax Numbers (302) 633-5921 (302)633-5910 Phone Numbers (302)633-s90s Addresses V Emaitthis Business Website Addresses http://www. unitedwater.com/delaware/index.asox Business Categorles Utilitv Water Comoanv e 2019, Council of Better Business Bureaus, lnc., separately incorporated Better Business Bureau organizations in the US, Canada and Mexico, and BBB lnstitute for Marketplace Trust. All Rights Reserved. https://wwu,.bbb.org/us/de/wilmingtoniprofile/utility-water-company/suez-north-america-0...2FI188d00018 Suez Water ldaho. lnc. I Better Business Bureau@ Profile Page I of2 Better Business Bureau' Home > ldaho > Boise > Utilitv Water Comoanv > Suez Water ldaho, lnc. Suez Water ldaho, lnc. Utility Water Company Accredited BBB Ratlng Customer Reviews Customer Complalnts This business is not BBB Accredited ***** 2 complaints closed in last 3 years l complaints closed in last 12 monthsA+Averaoe of 1 Customer Review Customer Complaints 2 Customer Complaints Customer Reviews 1 Customer Reviews Business Details BBB Flte Opened: 41111969 hrrps://rvu,rv.bbb.org/us/id/boise/protileiutility-water-company/suez-water-idaho-inc- I zq%ry.9c20287f0119q Suez Water ldaho. Inc. I Better Business Bureau@ Profile Page 2 of2 Additlonal Contact lnformation Phone Numbers (208)362-1300 Addresses V emaitthis Business Licenslng lnformatlon This business is an industry that may require professional licensing, bonding or registration. BBB encourages you to check with the appropriate agency to be certailr any requirements are currently being met. Business Categories Utilitv Water Companv el 2019, Council of Better Business Bureaus, lnc., separately incorporated Better Business Bureau organizations in the US, Canada and Mexico, and BBB lnstltute for Marketplace Trust. All Rights Reseryed. https://wu.r,r'.bbb.org/us/idlboise/profile/utility-water-company/suez-water-idaho-inc- nF{3Gn0z2?!&Pq EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FrRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQT EST NO. 16: Has EWCG asserted that *[w]ater conservation is going to h increasingly important as the Treasure Valley continues to grow?" If so, please identify any water conservation measures or programs currently implemented by the City of Eagle or Eagle Water Company. RESPONSE TO REQUEST FOR PRODU€IION NO. 16: EWCG is not aware of the source of the quote "[w]ater conservation is going to be increasingly impoftant as the Treasurc Valley continues to grow," nor does the request identifr the source. EWCG is therefore without sufticient knowledge to respond to this specific request. EWCG is aware, however, of The City of Eagle, Comprehensive PlarU attached hereto as Bates Nos. EWCG_000021-25, which outlines certain water conservation objectives. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTTON REQUEST OF SUEZ WATER IDAHO, INC. - Page l7 4E494504-7688v3 Comp Iensrve Plan a oI I aI I -rr<,I } THECITYOF \,7l 7/j / / t, I v b- FI ,7 J J .U at J &ft TT-Ia I J' a Eagle is lflf (DN4flE l" "'*i I ACKNOWLEDG EM ENTS MAYOR Stan Ridgeway CITY COUNCIL Stan Bastianr+ Jeff Kunzt' Naomi Preston Craig Soelberg Kathryn Almberg Phil Bandy Megan Basham Charlie Baun Matt Blandford Thomas Brengle Matt Brookshier Patrick Calley Mark Caragio Tom Ferch Steve Guerber Liisa ltoknen Rhonda Jalbert Theresa Johnson Jane Kramer Diane McLaughlin EAGLE IS HOME COMMITTEE Citizen Boise River Enhancement Network Ada County Development Services Park, Pathways, & Recreation Commission Citizen Citizen Citizen Eagle Police Citizen Ada County Highway District Eagle Planning & Zoning Commission COMPASS Valley Regional Transit Citizen Citizen Citizen D.L. "Mac" Mcomber Citizen Randy Mendiola Eagle Chamber Mark Miller Eagle Transportation Committee Jill Mitchell Eagle Library Board Lynn Moser Eagle Sewer District Ami Myers Citizen Shawn Nickel Historic Preservation Conrmission Kenneth Pittman Citizen Mike Ryan Citizen Tess Romani Youth Representative 8ob Schafer Eagle Design Review Board Deanna Smith ldaho Smart Growth Mark Tate BCA of SW ldaho Karen Towne Citizen Mark Wasdahl ldaho Transportation Department Blake Watson ldaho Power Mick Ysursa Citizen '*members of the Eagle is HOME Committee CONSULTANTS Kittelson & Associates: Transoortation Chaoter Nick Foster, AICP, Laurence Lewis, PE, AICP, LEED AP, lamie Markosian, Deanna Dupuy SPECIAL THANKS Eagle Urban Renewal Agency for funding the Economic Development Chapter Eagle Camera Club for photo contributions Studio Cascade: Economic Develooment Chaoter Emily Adams, William Grimes, AICP, Ryan Hughes, AICP Leland Consulting Group: Economic Development Chaoter Alisa Pyszka EAGLE IS HOME EWCG_000022 CHAPTER 4: UTILITIES, FACILITIES & SERVICES 4.6 Domestic water within the City of Eagle is provided by three primary service providers: Eagle Water Company (EWC), Suez Water of ldaho (formerly United Water ldaho (UWl)), and the City of Eagle (City) (see li4ap 4.1). A few small residential subdivisions own and operate their own water systems or have domestic wells, but many of these systems are aging and with redevelopment to urban development, these systems are being abandoned and connected to the domestic systems. According to Eagle City Code, domestic water service is required for all developments with a density of 1 unit per 2 acres or greater. Suez and Eagle Water Company, as privately-owned utilities, are regulated through the ldaho Public Utilities Commission. The City of Eagle water system, as a publicly owned system, is managed consistent with the Water Service Master Plan and in consultation with the ldaho Department of Environmental Quality (IDEQ and ldaho Department of Water Resources (IDWR). The City water system includes the City's current service area and all lands within the City's comprehensive plan that are not in an existing water service area. 4.6,1 DOMESTIC WATER GOALS PROVIDE SAFE, RELIABLE AND COST-EFFICIENT WATER SERVICE TO THE RESIDENTS OF THE CITY BY CONSTRUCTING AND MAINTAINING A WATER SUPPLY AND DISTRIBUTION SYSTEM WITH STORAGE FACILITIES THAT WILL MEET THE WATER DEMANDS OF CURRENT AND FUTURE WATER CUSTOMERS AS OUTLINED IN THE EAGLE COMPREHENSIVE PLAN. 4.6.2 OBJ E CTIVES A. Protect groundwater quality by requiring, when feasible, the use of municipal wells constructed to federal, State, and City standards. B. Promote groundwater conservation through the use of surface water sources and treated wastewater effluent for irrigation in combination with the development of water rates that encourage conservation. C. Ensure that municipal water facilities provide water pressure and flows that meet or exceed state and local requirements. EAGLE COMPREHENSIVE PLAN26 EWCG-000023 DOMESTIC WATER d !"-II r I a t Z L CHAPTER 4: UTILITIES, FACILITIES & SERVICES E. Promote the utilization and reuse of surface water sources for non-potable uses such as irrigation and water amenities to decrease reliance on groundwater and to preserve the resource, F. Protect current residents from paying for facilities that principally benefit new development. Require new developments to pay for new and upgraded water facilities to minimize impacts of growth on existing users. 4.5.3 IMPLEMENTATION A. Limit groundwater use in shoulder seasons to essential public landscaped areas such as schools, playgrounds, parks, and pathways. B. lnvestigate surface water supply options to meet potable needs for the expanded foothills area while protectinB the water sources supplying existing water users. C. Develop separate irrigation and water reuse requirements for the foothills including the use of native and drought-tolerant vegetation and low water use landscaping options. D. Develop policies and procedures to create local improvement districts to fund a centralized distribution/fire protection system that will extend fire protection to developed areas that are served by individual wells. E. ln conjunction with IDWR, develop well construction standards and guidelines to assist developers with cost-effective means of meeting water demands for individual systems. F. Assist with funding options to provide developers with various means of meeting standards for water supply systems. G. Promote low water use irrigation practices and drought-tolerant landscape options in areas that rely on groundwater for irrigation. H. Develop policies and procedures for assuring that flowing artesian groundwater wells are controlled within the City boundaries. l. Require groundwater monitorinB wells and easements sufficient to monitor groundwater levels in the service area. l. Continue to work with other water service providers to maintain a safe and sufficient water supply across jurisdictional boundaries. K. Maintain a Water Department and trained staff to meet the demands of water system operations in accordance with the IDEQ requirements and applicable federal rules and regulations. L. Ensure that the administration of the water systems for all new development within the Western Planning Area (west of Linder Road) and any foothill areas annexed by the City will be managed by the EAGLE IS HOME EWCG_000024 27 D. lnvestigate the City's purchasing of Eagle Water Company. CHAPTER 4: UTILITIES, FACILITIES & SERVICES City of Eagle municipal water facilities, though this would not necessarily be a completely integrated system. M. Periodically review the costs and benefits of the City water system to ensure that rates and fees are sufficient to provide adequate capital to fund needed improvements, including a reserve fund for infrastructure replacement and evaluation of local groundwater trends. N. Evaluate future water system needs and develop an operating budget for operation and maintenance and a capital budget for water infrastructure improvements for the City-owned water facilities. O. Require the construction of dry-line water facilities and fire hydrant stub-outs in developments anticipated to be served by the municipal system as identified in the Water Master Plan and the Comprehensive Plan. P. Provide public education on water conservation. 28 EWCG 000025 EAGLE COMPREHENSIVE PLAN EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER rDAHO rNC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO 17: Does EWCG contend that the City of Eagle would not seek to move water under Eagle \ilater Company water rights to other portions of the City's curent or future service area if the City were to acquire Eagle Water Company? RESPONSE TO REQUEST FOR PRODUCTION NO. l7t EWCG is without sufticient knowledge to know what the City of Eagle would do once it acquired Eagle Water Company's assets, but assumes that the City of Eagle would continue to provide water service to its residents, not ship the water to other areas, as proposed by SUEZ. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 18 4t49-4$4-7688v3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER rDAHO rNC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG mernbers. REQUEST NO. 18: Does EWCG contend that the Idatro Department of Water Resources does not have jruisdiction and authority over the place and purpose of the use of the water rights that are cunently owned by Eagle Water Company, even if those water rights are acquired by SUEZ? RESPONSE TO REQUEST FOR PRODUCTION NO. 18: No, but IDWR's authority to approve changes in places and purposes of use of the water rights is subject to the right of parties to protest the proposed changes, and is further subject to satisfaction of the statutory criteria for such changes, including that there be no injury to other water rights and that the proposed changes are in the local public interest among other considerations. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 19 48494504-7688v3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO. 19: Does EWCG contend that the City of Eagle would not chlorinate the water that would be provided to current Eagle Water Customers if the City were to acquire Eagle Water Company? RESPONSE TO REQUEST FOR PRODUCTION NO. 19: EWCG is without sufficient knowledge to know what the City of Eagle would do once it acquired Eagle Water Company's assets, but assumes that the City of Eagle would not force people to drink chlorinated surface water, as SUEZ proposes to do. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 20 4E494504-76Etv3 EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER rDAHO rNC. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FTRST PRODUCTION REQLTEST OF SUEZ WATER IDAHO, INC. - Page2l 4849.4504-76E8v3 SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling EWCG memberc. REQIIEST NO. 20: Does EWCG contend that the City of Eagle does not currently chlorinate the drinking water provided to its current customers? RESPONSE TO REQUEST fOR PRODUCTION NO. 20: EWCG docs not know what the City of Eagle's current chlorination practices are, if any, but do not believe they include chlorinated surface water, like SIJEZ. EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FrRST PRODUCTION REQUEST OF SUEZ WATER IDAHO INC. SPONSOR(S): Shelley Brock, Janet Buschert and Jane Rohling, EWCG members. REQUEST NO.22: Please identify each person or entity that EWCG intends to call as a witness in any teshnical hearing in this matter. For eacl\ please state the subject matter of their testimony and provide any documents they considered or relied upon in forming their testimony. RESPONSE TO REQUEST FOR PRODUCTION NO. 22: At this time, EWCG does not intend to call any witnesses in any technical hearing in this matter, but reserves the right to cross-examine all witnesses at any technical hearing in this matter. EWCG reseryes the right to provide written testimony, and call sponsoring witnesses, consistent with any deadlines set by the PUC and the PUC's Rules of Procedure. DATED this lst day of March,2019. PARSONS & LATIMER By: M. Semanko EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SLJEZ WATER IDAHO, INC. - Page22 4E494504-768Ev3 CERTIFICATE OF SERVICE I hereby certiry that a tnre and correct copy of the foregoing document was served on the following on this lst day of March, 2019 by the following method: Diane M. Hanian Commission Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, lD 83702 IPUC secretan lA.Duc.idaho. sov diane. hanian@ouc. idatro. gov Brandon Karpen Sean Costello Deputy Attorney General Idaho Public Utilities Commission 472 W est Washington Steet Boise,lD83702 IPUC Brandon. karpen@nuc. idaho. Bov Sean.Costello@nuc. idalro. eov James M. PioEowski Piorowski Duran, PLLC P.O. Box 2864 1020 West Main Street, Suite 400 Boise,lD 83701 Attorneys for Internenor Citizens Allied for Inte grity and Accountab ility James@idunionlaw.com Michael C. Creamer Preston Carter Givens Pursley LLP 601 West Bannock Steet Boise,ID 83702 Attorneysfor Applicant Suez llater ldaho Inc. mcc@eivensoursley. com prestoncarter@givenspursley. com U.S. First Class Mail, Postage Prepaid U.S. Certified Mail, Postage Prepaid Federal Express Hand Delivery Electronic Mail or CIWECF U.S. First Class Mail, Postage Prepaid U.S. Ce*ified Mail, Postage Prepaid Federal Express Hand Delivery Electronic Mail or Clvl/ECF U.S. First Class Mail, Postage Prepaid U.S. Certified Mail, Postage Prepaid Federal Express Hand Delivery I Electronic Mail or CTWECF U.S. First Class Mail, Postage Prepaid U.S. Certified Mail, Postage Prepaid Federal Express Hand Delivery Electronic Mail or CM/ECF EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQTJEST OF SUEZ WATER IDAHO, INC. - Page}3 4E494504.76EEv3 rIx Marshall Thompson Suez Water Idaho, Inc. 8248 West Victory Road Boise, ID 83709 Applicant Marshal l.thomoson@suez.com Robert DeShazo Eagle Water Company, Inc. 188 West State Street Eagle,ID 83616 eag lewaterco@gmail. com Jolnt Applicant N. L. Bangle 188 West State Steet Eagle,ID 83616 Joint Applicant nbangle@h2o-solutionsl lc.net B. Newal Squyres Munay D. Feldman Holland & Hart 800 W. Main Street, Suite 1750 P.O.Box2527 Boise, lD 83702-2521 Attorneyfor Intervenor City of Eagle nsquvres@hollandhart.com mfeldman@hollandhart. com Abigail R. Germaine Deputy City Attorney Boise City Attorney's Oflice 150 North Capitol Blvd. P.O. Box 500 Boise,ID 83701-0500 Attorneyfor Intentenor City of Boise aeermaine(Acitvofboise. ore U.S. First Class Mail, Postage Prepaid U.S. Certified Mail, Postage Prepaid Federal Express Hand Delivery Electronic Mail or CIWECF U.S. First Class Mail, Postage Prcpaid U.S. Certified Mail, Postage Prepaid Federal Express Hand Delivery Electonic Mail or CI{/ECF U.S. First Class Mail, Postage Prepaid U.S. Certified Mail, Postage Prepaid Federal Express Hand Delivery Electronic Mail or C}vI/ECF U.S. First Class Mail, Postage Prepaid U.S. Certified Mail, Postage Prepaid Federal Express Hand Delivery Electonic Mail or CTWECF U.S. First Class Mail, Postage Prepaid U.S. Certified Mail, Postage Prepaid Federal Express Hand Delivery Electronic Mail or Ctvl/ECF EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page24 4849450{-76Etv3 Stan Ridgeway, Mayor City of Eagle 660 East Civic lane Eagle,ID 83616 sridsewav@sitvofeade.ors sberemann@ cityofeagle. ore Intemenor U.S. First Class Mail, Postage Prepaid U.S. Certified Mail, Postage Prepaid Federal Express Hand Delivery Electronic Mail or CIWECF Brad M. Purdy 2019 North lTth Steet Boise, lD 83702 bmourdv(Ohotmail.com Attorney for Intervenor Community Actlon Potnership Association of ldaho U,S. First Class Mail, Postage Prepaid U.S. Certified Mail, Postage Prepaid Federal Exprcss Hand Delivery Electronic Mail or CIVI/ECF Molly O'Leary BizCounselor@Law, PLC 1775 W. State Sfteet #150 Boise,ID 83702 Mollv@bizcounseloratlaw.com Attorneyfor Eagle Water Co, U.S. First Class Mail, Post4ge Prepaid U.S. Certified Mail, Postage Prepaid Federal Express Hand Delivery Elecronic Mail or CIWECF M. Semanko EAGLE WATER CUSTOMER GROUP'S RESPONSES TO FIRST PRODUCTION REQUEST OF SUEZ WATER IDAHO, INC. - Page 25 4849450&76EEv3 rIIIx