20210212Micron 1-6 to Suez.pdf

Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
HorreNo & HART r-r,p
555 lTth Street, Suite 3200
Denve,r, CO 80202
Telephone: [phone]
Facsimile: (7 20) 235-0229
Email: [e-mail]
tnelson@hollandhart. com
i i,-,r,_.lr,,,iIfii[:i
Attomeys for Micron Technology, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF SUEZ WATER IDAHO ) CASE NO. SUZ-W-20-02
INC.'S APPLICATION FOR AUTHORITY )
TO INCREASE ITS RATES AND CHARGES ) FIRST PRODUCTION REQUEST
FOR WATER SERVICE IN IDAHO ) OF MICRON TECHNOLOGY, INC.
) TO SUEZ WATER IDAHO, INC
)
Micron Technology, Inc. ("Micron" or "Intervenor"), by and through its counsel, Holland
& Hart LLP, submits the attached interrogatories and requests for the production of documents to
SUEZ Water Idaho, Inc. ("SUEZ"). The following response date, definitions, and instructions
apply to the enclosed interrogatories and requests for production of documents.
In addition to the written copies provided as responses to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
RESPONSE DATE. DEFINITIONS AI\D INSTRUCTIONS
Please respond to these interrogatories and requests forproduction of documents by March
5,2021.
DEFINITIONS
*SUEZ Water Idaho,Inc.," "SUEZ," "the Company," or o?ou" means SUEZ Water Idaho,
Inc. and the employees, officers, directors, agents, consultants, attorneys and all persons
acting under contractual arrangement with or acting or purporting to act on behalf of SUEZ.
2. "Agreement" means any contract, written or oral, or any non-contractual understanding.
MICRON TECHNOLOGY, INC.'S
FIRST PRDUCTION REQUEST
TO SUEZ WATER .I. FEBRUARY I2,2O2I
1
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4.
"And/Or" will be construed disjunctively or conjunctively as necessary so that the scope
of these interrogatories is as broad as possible and includes any information which might
be constructed to be outside their scope.
"Communication" should be interpreted as broadly as possible to include, but not be
limited to, all forms of communication, whether written, printed, oral, pictorial, electronic
or otherwise and by any means or type whatsoever.
"Date" shall mean the exact day, month, and year if ascertainable, or if not the best
approximation thereof in relation to other events.
"Document" and "documentation" should be interpreted as broadly as possible, including
the original or any copy, regardless of origin or location, of any book, pamphlet, periodical
publication, letter, scrapbook, diary, calendar, canceled check, photograph, form,
memorandum, schedule, tax return, telegram, telex, report, record, order or notice of
governmental action of any kind, study, minutes, logs, graph, index, tape, disc, internal
operating manual, data sheet or data processing card, or any other written, recorded,
transcribed, punched, taped, filmed, graphic or retrievable matter or data of any kind,
however produced or reproduced, to which you have or have had access. This definition
includes all documents which have been created and/or which reside in any type of
electronic format.
Any document that is not exactly identical to another document for any reason (such as
marginal notations or deletions) should be considered a separate document.
As to any document related to the matters addressed herein that is not currently in your
possession but that you know or believe such a document exists, you are requested to
identiff and indicate to the best of your ability its present or last known location or
custodian.
To "describe, "detail," or "state" shall mean to relate as completely as possible each and
every act, omission, incident, event, condition, circumstance, decision, and/or thing
relating directly or indirectly to the subject ofthe explanation including all pertinent dates.
To "explain" means to make known in detail, to make clear the cause or reason of any
account for each act, omission, incident, event, condition, circumstance, decision, and/or
thing relating directly or indirectly to the subject of the explanation including all pertinent
dates.
9. Any request to "identi&" or "provide" should be interpreted to mean
a. With respect to a natural person, that person's full name, title, job description, and
business and home address. Where the identification pertains to a past period, as
to each person identified who is still in your employ, or the employment of the
group with which such person is identified in response to any requests, provided,
MICRON TECHNOLOGY, INC.'S
FIRST PRDUCTION REQUEST
TO SUEZ WATER -2- FEBRUARY I2,2O2I
5
6.
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8.
in addition, that person's title and job description as of the time of such past period.
where the person is no longer in your ernploy or the employment of the group with
which such person is identified in response to any request, provide that person's
affiliate, position, home and business address, if known, or if not known, such
person's last known affiliation, position, home and business address, or portions
thereof as may be known.
With respect to an entity other than a natural person, that entity's name, business,
type of entity, present stafus and present or last known address.
With respect to a document, that document's title, date, author (and, if different, the
signer), addresses, recipients, or other persons who assisted in the preparation,
subject matter or general nature, and any amendments thereto, present location and
custodian, whether or not such document is in the respondent's possession, custody
or control and whether or not the document is claimed to be privileged. The final
version and each draft of each document should be identified and produced
separately. Each original and each non-identical copy (bearing marks or notations
not found on the original) of each final version and draft of each document should
be identified and produced separately.
With respect to a physical facility, the location of the facility, the intended purpose
of the facility, the actual use of such facility, the operating dates of the facility, the
installation date of the facility, the date utilization of the facility terminated if
applicable, and whether the facility is subject to the jurisdiction of the Idaho Public
Utilities Commission, the Federal Energy Regulatory Commission, or any other
regulatory body.
"Person or Entity" should be interpreted to denote, unless otherwise specified, any natural
person, firm, corporation, association, Broup, individual or orgarization of any type
whatsoever.
11. "PIJC" or ooCommission" means the Idaho Public Utilities Commission.
12."Record" or "Records" includes any regulation, formal or informal, official or unofficial
memorandum, document or written preservation of any events, actions taken or rejects,
decisions and details thereof relating to the subject matter of the question and your response
including electronic data and e-mail. A copy of the original "record" is preferred; stating
the substance thereof will suffice where a copy cannot be made and is not available.
l3 "Relating To" or "Related To" means pertaining to, presenting, discussing, commenting
on, aralyzing, or mentioning in any way.
GENERAL INSTRUCTIONS
Interrogatories and requests for production must be answered with particularity and in
detail.
MICRON TECHNOLOGY, INC.'S
FIRST PRDUCTION REQUEST
TO SUEZ WATER J FEBRUARY I2,2O2I
b
c
d.
10.
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5
6.
2.
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4
7
8
9
lnterrogatories and requests for production must be answered separately and fully in
writing under oath within twenty-one (21) days after service in accordance with IDAPA
31.01.01.225.
Interrogatories and requests for production must be signed by the person upon whose
personal knowledge responses are based or who helped in any way in answering these
interrogatories and requests for production.
You must provide the names of any other persons upon whose personal knowledge
responses are based or who helped in any way in answering these interrogatories and
requests for production.
In making your answers, you must produce all relevant documents and data by attachment
or by identifuing the documents which relate to your answers. You must also clearly
identiff each interrogatory to which the document relates.
These interrogatories and requests for production are continuing in nature and in the event
any information provided in an answer is changed or supplemented by future developments
or other factors, you must file appropriate supplernental answers.
ln answering these interrogatories and requests for production you should furnish all
information which is in your possession, custody or conftol including, but not limited to,
information from any files, records, or documents in the possession of your attorneys,
consultants, staff, accountants, experts, employees, former employees, and other agents.
These interrogatories and requests for production should be answered based on your
personal knowledge, the personal knowledge of your attorneys, consultants, staff,
accountants, experts, ernployees, former employees, and any other agents as appropriate or
available and with reference to the sources described above.
If the respondent is not a witness who has filed written direct testimony, please indicate
which of the company's witnesses will be prepared to answer these questions on the stand.
10.In addition to a hard copy, please provide an electronic copy of your responses in Microsoft
Word. Where responses are prepared using spreadsheet software, please provide an
electronic copy in Microsoft Excel format.
ll If after exercising due diligence you are unable to answer any interrogatory or to produce
any document requested, you must explain your inability in detail.
12. If you object to any interrogatory or request for production, you may serve written
objections on Micron as provided in IDAPA 31.01.01.225, identiffing the subject matter
objected to and stating with particularity the reasons for the objections. In addition, the
objections and the answers must be contained in separate pleadings with each clearly
identified as an objection or answer. The service of an objection will not excuse you from
MICRON TECHNOLOGY, INC.'S
FIRST PRDUCTION REQUEST
TO SUEZ WATER -4- FEBRUARY I2,2O2I
answering the remaining interrogatories or responding to the remaining requests for
production for which no objection is stated.
13.If any responses to these interrogatories or requests for production have already been
provided in prior discovery in this matter, please direct Micron to the specific discovery
request and response where such response can be found.
14. Copies of the responses and any and all documents produced should be provided to
Thorvald A. Nelson
Austin Rueschhoff
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email : tnelson@hollandhart. com
darueschho ff@ho llandhart. com
aclee@hollandhart. com
gl gareanoamari @holl andhart. com
INTERROGATORIES AND REOUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: Please refer to the direct testimony of Mr. Prettyman atpage 3, lines
l0-14
a-In electronic spreadsheet format with all formulas intact, please provide
workpapers supporting the development of the base, maximum day and maximum
hour demand ratios used in SUEZ's class cost of service study.
Please identifr the maximum day and maximum hour demand ratios that SUEZ
considers to be oostandard industry factors" for each customer class included in its
class cost of service study.
Please provide the source of the "standard industry factors" identified in response
to part b., above.
Please indicate whether or not SUEZ has ever conducted a load study to verift that
these ratios are consistent with the actual base, maximum day and maximum hour
demands associated with each of SUEZ's customer classes.
If SUEZ has conducted a load study, please provide the results of such study on
electronic spreadsheet with formula intact.
f. If SUEZ has never conducted a load study, please explain why not.
b
c.
d.
e.
MICRON TECHNOLOGY, INC.'S
FIRST PRDUCTION REQUEST
TO SUEZ WATER -5-FEBRUARY I2,2O2I
REQUEST NO.2: With respect to SUEZ's purchased power cost:
a.Please identifu the electric utilities that provide service to SUEZ.
For each utility identified above in part a., please identifu the tariff rate schedule
under which SUEZ takes electric service.
b.
c.Please provide a copy of each electric tariffidentified above in part b.
REQUEST NO. 3: Please refer to the direct testimony of Ms. Catherine Cooper at page
2,line 14-16, and page 3, lines 3-4.
Of the $25.124 million pro forma plant additions (net of retirernent) for the period
from July 1,2020 through March 31,2021, please state the amount that has been
placed in service to date.
b. Please update this response as new information becomes available.
REQUEST NO. 4: Please refer to the direct testimony of Mr. Timothy Michaelson. With
respect to the 3O-year regression analysis used to determine the declining usage adjustment for the
residential class, please provide the following:
Please explain why a 30-year time period is appropriate for such a regression
analysis.
Please identiff the drivers of the declining usage trend that Mr. Michaelson has
identified.
Based on the drivers of declining usage identified above in part b., does Mr.
Michaelson expect that the rate of declining usage should decrease over time,
increase over time, or stay the same? Please provide a detailed explanation
supporting the response. Please also provide any documents or analyses relied upon
by Mr. Michaelson for this response.
REQUEST NO. 5: Please refer to the direct testimony of Mr. Timothy Michaelson. With
respect to the Zl-year regression analysis used to determine the declining usage adjustrnent for the
commercial class, please provide the following:
Please explain why a 25-year time period is appropriate for such a regression
analysis.
Please identiff the drivers of the declining usage trend that Mr. Michaelson has
identified.
a.
a.
b.
c.
a.
b.
MICRON TECHNOLOGY, INC.'S
FIRST PRDUCTION REQUEST
TO SUEZ WATER -6-FEBRUARY I2,2O2I
c.Based on the drivers of declining usage identified above in part b., does Mr.
Michaelson expect that the rate of declining usage should decrease over time,
increase over time, or stay the same? Please piovide a detailed explanation
supporting the response. Please also provide any documents or analyses relied upon
by Mr. Michaelson for this response.
REQUEST NO. 6: Concerning the Company's proposed ratemaking capital structure,
please provide the following:
Please identiS the Treasury function used by SUEZ to access external capital, debt
and equity, to fund necessary infrastrucfure investments.
Please provide a credit rating agency of SUEZ, or an affiliate company, that issues
debt on behalf of its utility.
Please identifu SUEZ's utility dividend payment policy to its parent company.
Identifu the amount of net income and actual dividend payments over the last five
years.
Please provide a credit report on SUEZ, and all affiliate companies, issued by
Standard & Poor's, Moody's or Fitch over the last two years.
Respectfully submitted February 12, 2021.
HOLLAND & HART, u.r
By:
Austin Rueschhoff, ISB No. I
Thorvald A. Nelson
555 lTth Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Facsimile: (7 20) 23 5 -0229
Email: [e-mail]
tnelson@hollandhart. com
Attomeys for Micron Technology, Inc.
a.
b
c.
d.
MICRON TECHNOLOGY, INC.'S
FIRST PRDUCTION REQUEST
TO SUEZ WATER -7-FEBRUARY I2,2O2I
CERTIFICATE OF SERVICE
I hereby certiff that on February 12, 2021, a true and correct copy of the within and
foregoing FIRST PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO SUEZ
WATER IDAHO, INC. was served in the manner shown to:
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
P.O. Box 83720
Boise lD 83720
Jan.noriyuki@puc. idaho. gov
SUEZ Water ldaho Inc.
Michael C. Creamer
Preston N. Carter
Givens Pursley LLP
601 W. Bannock Street
Boise,lD 83702
mcc@ sivenspursley. com
prestoncarter@ givenspursley.com
Ada County
Lorna Jorgensen
John Cortbitarte
Ada County Prosecuting Attorney's Office
Civil Division
200 W. Front Street, Room 3191
Boise,ID 83702
civilpafi [e-mail]
City of Boise City
Abigail R. Germaine
Deputy City Attorney
Boise City Attomey's Office
150 N. Capitol Boulevard
P.O. Box 500
Boise,ID 83701-0500
agermaine@cityofboise. org
MICRON TECHNOLOGY, INC.'S
FIRST PRDUCTION REQUEST
TO SUEZ WATER
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
P.O. Box 83720
Boise lD 83720
Dayn.hardie@puc. idaho. gov
Suez Water Management & Services
David Njuguna
Suez Water Management & Services
461 From Road, Suite 400
Paramus, NJ 07052
David.niuzuna@suez. com
Community Action Partnership Association of
Idaho
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, lD 83702
[e-mail]
Gannon, Montero, Graziano, Philp
Marty Durand
Piotowski Durand PLLC
1020 Main Street, Suite 440
P.O. Box 2864
Boise,ID 83701
[e-mail]
-8-FEBRUARY I2,2O2I
Intermountain Fair Housing Council, Inc. SUEZ Water Customer Group
Ken Nagy
Attorney at Law
P.O. Box 1264
Lewiston,ID 83501
[e-mail]
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise,lD 83702
nsemanko@parsonsb ehl e. com
boisedocket@parsonsbehle. com
Micron Technologt, Inc.
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, lD 83707
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
darueschho ff@hollandhart. com
tnelson@hollandhart. com
acl ee@hollandharl. com
el garsanoamari @holl andhart. com
s/ Gina
16185103 vl
MICRON TECHNOLOGY, INC.'S
FIRST PRDUCTION REQUEST
TO SUEZ WATER -9-FEBRUARY I2,2O2I