20210713Staff 50-51 to Suez.pdf

DAYN HARDIE (lSB No. 9917)
MATT HI-INTER (lSB No. 10665)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
(208) 334-03r8
IN THE MATTER OF THE JOINT
APPLICATION OF SUEZ WATER IDAHO AND
EAGLE WATER COMPANY FOR THE
ACQUISITION OF EAGLE WATER COMPANY
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NOS. SUZ-W-18-02/
EAG-W-18-01
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
SUEZ WATER IDAHO INC
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of record,
Dayn Hardie and Matt Hunter, Deputy Attorneys General, request that Suez Water Idaho, Inc.
provide the following documents and information as soon as possible, but no later than
TUESDAY, AUGUST 3, 2021.
This Production Request is to be considered as continuing, and Suez Water ldaho, Inc. is
requested to provide, by way of supplementary responses, additional documents that it, or any
person acting on its behall may later obtain that will augment the documents or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of the
person preparing the documents. Please also identiff the name, job title, location, and telephone
number of the record holder.
FOURTH PRODUCTION REQUEST
TO SUEZ WATER
: : ,1 r,_r1l ,. . :, ,f- --i iru irr rJ",V
ruLY 13,2021
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 50: In OrderNo. 34265, Case No. EAG-W-15-01, the Commission
approved a Joint Sefflement Stipulation in which Eagle Water Company was to deposit $45,288
in overeamings annually into the surcharge line-of-credit account beginning in20l6. How does
SUEZ Water of Idaho intend to refund to Eagle Water Company customers the surcharge line-of-
credit balance that resulted from Case No. EAG-W-15-01?
REQUEST NO.51: In seeking recovery of acquisition and closing costs, SUEZ Water
Idaho witness Jarmila Cary states in her Supplemental Testimony, Page 6 Line 14 through 16,
"The Commission has previously allowed recovery of such prudent acquisition costs in prior case
filings." Please provide all examples, including case numbers, that Ms. Cary relied on in making
that statement.
Bt!Dated at Boise, Idaho, this day of July 2021.
Dayn
Deputy Attomey General
i : umisc:prodreq/suzw I 8.2_eagw I 8. I sctnc prod req4 to SUEZ
FOURTH PRODUCTION REQUEST
TO SUEZ WATER 2 ruLY t3,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l3th DAY OF JULY 2021, SERVED
THE FOREGOING F'OURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
TO SUEZ WATER IDAHO INC.; IN CASE NOS. SUZ-W-18-02/EAG-W-18-01, BY
E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GIVENS PURSLEY LLP
60I W. BANNOCK ST.
BOISE, ID 83702
E-MAIL : mcc@ givenspursle)'.corn
prestoncafi er@ givenspLlrsley. com
ROBERT DESHAZO
EAGLE WATER COMPANY, INC.
I88 W. STATE ST.
EAGLE, IDAHO 83616
E-MAIL : eagl [e-mail]
MOLLY O'LEARY
BIZCOUNSELOR AT LAW PLLC
1775W STATE STREET, #150
BOISE ID 83702
E-MAIL: [e-mail]
ELECTRONIC ONLY
MAYOR JASON PIERCE
CITY OF EAGLE
660 E CIVIC LANE
EAGLE ID 83616
E-MAIL : i [e-mail]
to sborn(dtc ity o fea gl e. o r g
BRAD M PURDY
ATTORNEY AT LAW
20I9 N ITTH STREET
BOISE ID 83702
MARSHALL THOMPSON
SUEZ WATER IDAHO, INC.
8248 W. VICTORY RD.
BOISE,IDAHO 83709
E-MAIL : [e-mail]
N.L. BANGLE
H2O EAGLE ACQUISTION, LLC
I88 W. STATE ST.
EAGLE, TDAHO 83716
E-MAIL : nbangle@h2o-sol r-rtionsllc.net
B NEWAL SQUYRES
MURRAY D FELDMAN
HOLLAND & HART LLP
PO BOX2527
BOrSE rD 83702-2527
E-MAIL : [e-mail]
mfbldman@hoI landhart.com
JAMES M PIOTROWSKI
PIOTROWSKI DURAND PLLC
1O2O W. MAIN STREET, SUITE 440
PO BOX 2864
BOISE ID 8370I
E-MAIL: iames@,idunionlaw.com
NORMAN M SEMANKO
PARSON BEHLE & LATIMER
8OO W MAIN STREET, SUITE 13OO
BOISE ID 83709
E-MAIL: [e-mail]
[e-mail]
E-MAIL: bmpurdy Lcom
CERTIFICATE OF SERVICE
SCOTT B. MUIR
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
I5O N. CAPITOL BLVD.
PO BOX 500
BOrSE ID 83701-0500
E-MAIL: boisecityauonre],@citvofboise.orq
CERTIFICATE OF SERVICE