20210208Gannon 1-6 to Suez.pdf

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Marty Durand
PIOTROWSKI DURAND PLLC
P.O. Box 2864
1020 Main Street Suite 440
Boise, Idaho 83701
[phone]
[phone]
[e-mail]
Attorney for Intervenors Gannon,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF SUEZ WATER ) Case No. SUZ-W-20-02
IDAHO INC’S APPPLICATION FOR )
AUTHORITY TO INCREASE ITS ) Intervenors Gannon, et al.,
RATES AND CHARGES FOR WATER ) First Combined Discovery
SERVICE IN IDAHO ) Request to Suez Water, Inc.
__________________________________ )
Intervenors Gannon, et al., by and through their attorney of record Marty Durand submit
to Suez Water Idaho, Inc. and its attorneys of record the Interrogatories and Request for
Production described below pursuant to IDAPA §31.01.01.225.
The Intervenors submit these Interrogatories to be answered separately and fully in
writing within twenty-one (21) days from the date of service. In responding to these
Interrogatories, you are required to furnish such information as is available to you. These
Interrogatories are continuing in nature and the Intervenor requests that any information coming
into the possession of you, your agents, or your counsel that would change the answers in any
way be promptly furnished to the undersigned counsel.
Furthermore, the Intervenor requests that you produce the documents identified in the
Request for Production within twenty-one (21) days after service of this document. The terms
“document” and “documents” include but are not limited to all handwritten, typed, or printed or
RECEIVED
2021February 8, PM 3:18
IDAHO PUBLIC
UTILITIES COMMISSION
.
2. Interrogatories and Requests for Production
and drafts, duplicates or any other copies thereof, in the possession, custody or control of you or
your counsel. Your response to these discovery requests shall be mailed or otherwise delivered
to the undersigned Marty Durand, PIOTROWSKI DURAND, PLLC, P.O. Box 2864, Boise,
Idaho 83701.
For purposes of these requests, “brown water” is described as water delivered by Suez
through its pipes and other structures which is discolored, unpleasant and not fit for drinking or
other domestic use such as cooking, laundry, household cleaning or bathing.
For purposes of these requests, “Boise Bench’ is described as the area south of
Downtown Boise between Vista Avenue and Cole Road extending from Boise Depot to
Interstate 84.
INTERROGATORY NO. 1: Please estimate the number of customers located on the
Boise Bench who have received brown water delivered by you. Please describe your method of
estimation.
INTERROGATORY NO. 2: Please estimate the number of days in each calendar year
(2017 through 2021) Boise Bench customers have received brown water. Please describe your
method of estimation.
INTERROGATORY NO. 3: Please describe any efforts you have made to alleviate, or
cure, the brown water delivered to Boise Bench customers.
INTERROGATORY NO. 4: Please describe and quantify any rate reduction, or credit,
you have provided to Bench customers for delivery of brown water.
INTERROGATORY NO. 5: Please identify the cause of the brown water delivered to
Boise Bench customers and identify any and all minerals or metals causing the discoloration.
.
3. Interrogatories and Requests for Production
INTERROGATORY NO. 6: Please describe any plans or surveys you have undertaken
or adopted to address or cure brown water delivery to Boise Bench customers.
REQUEST FOR PRODUCTION NO. 1. Please provide a copy of any survey
documents you have prepared or received regarding delivery of brown water to Boise Bench
customers.
REQUEST FOR PRODUCTION NO. 2: Please provide a copy of any plan documents
you have prepared, considered or received to alleviate, or cure, your delivery of brown water to
Boise Bench customers.
Dated this 8th day of February, 2021.
/s/ Marty Durand
MARTY DURAND
.
4. Interrogatories and Requests for Production
CERTIFICATE OF SERVICE
I hereby certify that on the 8th day of February, 2021, 1served the foregoing documents
on all parties as follows:
Jan Noriyuki, PUC Secretary [e-mail]
Michael C. Creamer, Attorney for Suez [e-mail]
Preston Carter, Attorney for Suez [e-mail]
David Njuguna, Suez Regulatory Manager [e-mail]
Dayn Hardie, DAG [e-mail]
Matt Hunter, DAG [e-mail]
Lorna K Jorgenson, Attorney for Ada County [e-mail]
John C Cortabitarte, Attorney for Ada County [e-mail]
Scott Muir, Attorney for City of Boise [e-mail]
Mary Grant, City of Boise [e-mail]
Norman Semanko, Attorney for Customer Groups [e-mail]
Brady Purdy, Attorney for CAPAI [e-mail]
Ken Nagy, Attorney for IFHC [e-mail]
Jim Swier, Attorney for Micron [e-mail]
Greg Harwood, Attorney for Micron [e-mail]
Austin R Austin Rueschhoff , Attorney for Micron [e-mail]
Thorvald Nelson, Attorney for Micron [e-mail]
By /s/ Marty Durand
MARTY DURAND