20210211Gannon 1-2 to Suez.pdf

RECEIVED
202lFebruary I, PM 3:18
IDAHO PUBLIC
ATILITIES COMMISSIONMarty Durand
PIOTROWSKI DURAND PLLC
P.O. Box 2864
1020 Main Street Suite 440
Boise, Idaho 83701
[phone]
(208) 863-85e1
[e-mail]
Attorney for lntervenors Gannon,
IN THE MATTER OF SUEZ WATER
IDAHO [NC'S APPPLICATION FOR
AUTHORITY TO INCREASE ITS
RATES AND CHARGES FOR WATER
SERVICE IN IDAHO
BEFORE THE IDAHO PI.JBLIC UTILITIES COMMISSION
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Case No. SUZ-W-20-02
lntervenors Gannon, et al.,
First Combined Discovery
Request to Suez Water, [nc.
lntervenors 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 931.01.01.225.
The lntervenors submit these lnterrogatories to be answered separately and fully in
writing within twenty-one (21) days from the date of service. In responding to these
lnterrogatories, 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 o'documents" include but are not limited to all handwritten, typed, or printed or
and drafts, duplicates or any other copies thereof in the possession, custody or control ofyou 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, o'brown water" is described as water delivered by Suez
through its pipes and other structures which is discolored, unpleasant and not frt 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 quantiff any rate reduction, or credit,
you have provided to Bench customers for delivery of brown water.
INTERROGATORY NO. 5: Please identiff the cause of the brown water delivered to
Boise Bench customers and identifu any and all minerals or metals causing the discoloration.
2. lnterrogatories 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 8ft day of February,21}I.
/s/ Martv Durand
MARTY DURAND
3. Interrogatories and Requests for Production
CERTIFICATE OF SERVICE
I hereby certify that on the 8ft day of February,2}2l,lserved the foregoing documents
on all parties as follows:
Jan Noriyuki, PUC Secretary [e-mail]
Michael C. Creamer, Attorney for Suez [e-mail]
Preston Carter, Attomey for Suez [e-mail]
DavidNjuguna, Suez Regulatory Manager [e-mail]
Dayn Hardie, DAG [e-mail]
Matt Hunter, DAG [e-mail]
Loma K Jorgenson, Attorney for Ada County civilpafilesr2adaweb.net
John C Cortabitarte, Attorney for Ada County [e-mail]
Scott Muir, Attomey for City of Boise boiseci
Mary Grant, City of Boise [e-mail]
Norman Semanko, Attorney for Customer Groups [e-mail]
Brady Purdy, Attomey for CAPAI [e-mail]
Ken Nagy, Attorney for IFHC knaey@.lewiston.com
Jim Swier, Afforney for Micron [e-mail]
Greg Harwood, Attomey for Micron [e-mail]
Austin RAustin Rueschhoff , Attomey for Micron [e-mail]
ThorvaldNelson, Attomey for Micron [e-mail]
By /s/ Martv Durand
4. lnterrogatories and Requests for Production
MARTY DURAND