20210122Staff 152-155 to Suez.pdf

DAYN HARDIE (ISB No. 9917)
MATT HUNTER (ISB No. 10665)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
[phone]
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Street Address for Express Mail:
1 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF SUEZ WATER IDAHO
INC.'S APPLICATION FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
CASE NO. SUZ.W.2O.O2
NINTH 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
THURSDAY, FEBRUARY 8, 2021.r
This Production Request is to be considered as continuing, and Suez Water Idaho, Inc. is
requested to provide, by way of supplementary responses, additional documents that it, or any
person acting on its behalf, may later obtain that will augment the documents or information
produced.
I Staff it requesting an expedited response. If responding by this date will be problematic, please call Staffs attorney
at [phone].
NINTH PRODUCTION REQUEST
TO SUEZ WATER JANUARY 22,2021
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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 identifu the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
EXCEL spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 152: Please provide the statistical residual measures of the lowa curves
that were derived for the following accounts:
a. 331. Transmission and Distribution
b. 333. Services
c. 334. Meters
REQUEST NO. 153: As a follow up to Production Request 68, regarding the revised
list of work orders and projects, please provide the source documents, including but not limited
to invoices, contracts, bids, change orders, timesheets, job costing information, budgeted
amounts, and changes to the initial cost, and all other source documents and information
pertaining to the decision and implementation of each project and work order.
REQUEST NO. 154: Regarding Production Request 69, for the revised list of work
orders and projects, please provide the cost-benefit analysis, internal rate of return calculations,
and any other metrics considered. Please also explain how that project was the least cost/least
risk alternative. Include the approval signatures with the associated documentation for each
project.
REQUEST NO. 155: Please provide a listing of all booster stations-by location-
placed in service from 2016 through 2020. Please also include the cost of each project and any
associated Contributions in Aid of Construction and whether the project was a developer project
or Company project. Include in your response the initial documentation of the project and who
initiated the installation of the booster pump.
NINTH PRODUCTION REQUEST
TO SUEZ WATER JANUARY 22,20212
dDATED at Boise,Idaho, this day ofJanuary 2021
Deputy Attomey General
i:umisc:prodreq/suzw20.2dhmhtrc prod req 9
NINTH PRODUCTION REQUEST
TO SUEZ WATER aJ JANUARY 22,2021
CERTIFICATE OF SBRVICE
I HEREBY CERTIFY THAT I HAVE THIS 22"d DAY OF JANUARY 2021,
SERVED THE FOREGOING NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO SUEZ WATER IDAHO, INC., IN CASE NO. SUZ-W-20-02,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GTVENS PURSLEY LLP
PO BOX 2720
BOISE D 83701-2720
E-MAIL: mcc@si vensDurslev.com
prestoncarter @ gi venspurslelu.com
LORNA K. JORGENSEN
JOHN C. CORTABITARTE
ADA COUNTY PROSECUTING
ATTORNEY'S OFFICE
CTVL DTVISION
2OO W. FRONT STREET, ROOM 3191
BOISE, TD $702
E-MAIL: civilpafiles @ adaweb.net
MARY R. GRANT
SCOTT B. MUIR
DEPUTY CITY ATTORNEY
BOISE CMY ATTORNEY'S OFFICE
150 N. CAPITOL BLVD.
P.O. BOX 500
BOISE,ID 83701-0500
E-MAIL: boisecitlrattorney @cityofboise.org
BRAD M. PURDY
2019 N. 17rH ST.
BOISE, D 83702
E-MAIL: [e-mail]
DAVID NJUGUNA
MGR _ REGULATORY BUSINESS
SUEZ WATER MGMNT & SERVICES CO
461 FROM ROAD SUITE 4OO
PARAMUS NJ 07052
E-MAIL: David.njuguna @ suez.corn
NORMAN M. SEMANKO
PARSONS BEHLE & LATIMER
8OO W. MAIN ST., STE.I3OO
BOISE, TD 83702
E-MAIL: NSemanko @parsonsbehle.com
Boi sedocket @ parsonsbehle. com
MARTY DURAND
PIOTROWSKI DURAND PLLC
1O2O MAIN ST., STE. 440
P.O. BOX 2864
BOISE,ID 8370I
E-MAIL: [e-mail]
KEN NAGY
ATTORNEY AT LAW
P.O. BOX 164
LEWISTON, ID 83501
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF
THORVALD A. NELSON
555 17rH ST., STE. 3200
DENVER, CO 80202
E-MAIL: darueschhoff @ hollandhart.com
tnelson @ hollandhart.com
aclee @ hollandhart.com
gl garganomari @ hollandhart.com
JIM SWIER
GREG HARWOOD
MICRON TECHNOLOGY, INC.
SOOO S. FEDERAL WAY
BOISE, D 83707
E-MAIL: [e-mail]
[e-mail]
SECRETAR
CERTIFICATE OF SERVICE