20210218Suez to IFHC 1-2.pdf

Michael C. Creamer (lSB No.4030)
Preston N. Carter (lSB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: (208) 388-1 300
mcc@qivenspu rslev.com
p restonca rter@q iven sp u rsl ev. co m
IN THE MATTER OF THE APPLICATION
OF SUEZ WATER IDAHO INC. FOR
AUTHORIry TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE
IN THE STATE OF IDAHO
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Attorneys for SUEZ Water ldaho lnc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. SUZ-W-20-02
SUEZ WATER IDAHO INC.'S
RESPONSE TO INTERVENOR
INTERMOUNTAIN FA]R HOUSING
COUNSEL, INC.'S FIRST
INTERROGATORIES AND
REQUEST FOR PRODUCTION
SUEZ Water ldaho lnc., ("SUEZWatef or'Compan/) submits the following
responses to Intervenor lntermountain Fair Housing Counse!, lnc.'s First lnterrogatories
and Request for Production to SUEZ Water Idaho, lnc., dated February 1,2021.
DATED: February 18, 202'l
SUEZ WATER IDAHO INC.
/ -_-
--
By:
Michae! C. Creamer
Preston N. Carter
Attorneys for App licant
SUEZ WATER'S RESPONSE TO INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S FIRST
INTERROGATORIES AND REQUEST FOR PRODUCTION.l
1 5s38301_1.DOCX [3G209]
CERTIFICATE OF SERVICE
I certify that on February 18,2021, a true and correct copy of the foregoing was
served upon all parties of record in this proceeding via electronic mail as indicated
below:
Commission Staff
Jan Noriyuki, Commission Secretary Electronic Mail
ldaho Public Utilities Commission
11331W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, lD 83714
ian.norivuki@puc. idaho.qov
Dayn Hardie Electronic Mail
Matt Hunter
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, lD 83714
[e-mail]
matt. [e-mail]
lntervening Parties
Ada County:
Lorna K. Jorgensen
John C. Cortabitarte
Ada County Prosecuting Attorney's Office
Civi! Division
200 W. Front Street, Room 3191
Boise, lD 83702
I io rq en se n @ad acou ntv. id .qov
ico rta bita rte@adacou nty. id .oov
CAPAI
Brad M. Purdy
2019 N. 17th Street
Boise, lD 83702
[e-mail]
lnteruenors:
Marty Durand
Piotwrowski Durand PLLC
1020 Main Street, Suite 440
P.O. Box 2864
Boise, lD 83701
[e-mail]
Electronic Mail
Boise City
Scott B. Muir
Deputy City Attorney
Boise City Attorney's Office
150 N. Capito! Blvd.
P.O. Box 500
Boise, lD 83701-0500
boi secitvatto rnev@citvofbo ise. o rq
Suez Water Customer Group:
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main Street, Suite 1300
Boise, lD 83702
NSema nko@ parsonsbeh le.com
BoisedockettO rsonshehle com
ldaho Fair House Council, lnc.
Ken Nagy
Attorney at Law
P.O. Box 164
Lewiston, lD 83501
[e-mail]
SUEZ WATER'S RESPONSE TO INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S FIRST
INTERROGATORIES AND REQUEST FOR PRODUCTION .2
1 5538301_1.DOCX [30-2091
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart
555 17th St., Suite 3200
d a ruesch hoff@ ho I la nd hart. com
tnelson@ holland hart.com
aclee@holla ndhart.com
q lqa rqa noa ma ri@ hol la nd ha rt. com
Jim Swier
Greg Harwood
Micron Technology, lnc.
8000 S. FederalWay
[e-mail]
[e-mail]
./ *_--__=- -- tZ-_Z_:__
Preston N. Carter
SUEZWATER'S RESPONSE TO INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S FIRST
INTERROGATORIES AND REQUEST FOR PRODUCTION .3
1 s538301_1.DOCX [3G209]
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S
FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION TO
SUEZ WATER IDAHO tNc.
Preparer/Sponsoring Witness: Marshall Thompson
FAIR HOUSING INTERROGATORY NO. 1:
Describe each and every study, investigation or inquiry that you conducted regarding the
impact that the rate increases that you have proposed in this proceeding will impact !ow-
income housing consumers in the relevant service area.
RESPONSE NO. 1:
SUEZ Water Idaho, lnc. ("SUEZ") dtd not conduct a study, investigation or inquiry
regarding the impact that the proposed rate increases may have on low-income housing
consumers in the relevant service area.
suz-w-20-02
FAIR HOUSING INTERROGATORY 1
Page 1 of 1
SUEZ WATER IDAHO INC.
CASE SUZ-W-20-02
INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S
FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION TO
SUEZ WATER IDAHO, INC.
Preparer/Spon soring Witness: Marshall Thompson
FAIR HOUSING REQUEST FOR PRODUCTION NO. 1:
Produce a copy of each and every item pertaining to any study, investigation or inquirythat you conducted regarding the impact that the iate increasei that you-hare proposed
in this proceeding will impact low-income housing consumers in the relevant service areadescribed or discussed in your response to lnterrogatory No. 1.
RESPONSE NO. 1:
Please see the response to lnterrogatory No. 1.
suz-w-20-02
FAIR HOUSING PRODUCTION 1
Page 1 of 1
SUEZ WATER IDAHO INC.
GASE SUZ-W-20-02
INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S
FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION TO
SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Marsha llThompson
FAIR HOUSING INTERROGATORY NO. 2:
Describe each and every action in which you engaged to give notice to housing
consumers in the relevant service area regarding the rate increases that you have
proposed in this Proceeding.
RESPONSE NO.2:
suEz took the following actions to give notice of the proposed rate increase to customers
within the relevant service area:
. On July 30, ZO2O, SUEZ filed with the Commission a notice of intent to file a
general rate case. A copy of the notice of intent is available on the PUC website.
. On September 30,202O, SUEZ provided press releases to local news media. The
press releases are attached to the Application as Attachment 3.
. On October 1,2020, SUEZ published to social media with a link to a rate case
landing page, www.mvsuezwater.com/idahoinvestments2O20. SUEZ reposted this
message and link on the following dates:
o October 22,2020
o October 29,2020
o November 5,2020
o November 12,2020
. On October 1, 2020, SUEZ sent an email to all customers for whom SUEZ has
email addresses - roughly 50,000 accounts. A copy of that email is attached to
this response as an Attachment.
. SUEZ provided individual mailed notices to each customer starting on October 19,
2020. The mailed notices are attached to the Application as Attachment 3. On
October 21,2020, the Commission issued Order No. 34819, which is a Notice of
suz-w-20-02
FAIR HOUSING INTERROGATORY 2
Page 1 of 2
Application, Suspension of Proposed Effective Date, and Notice of lntervention
Deadline. A copy of Order No. 34819 is available on the Commission's website.
suz-w-20-02
FAIR HOUSING INTERROGATORY 2
Page 2 of 2
Gmail - SUEZ Completes Sweeping $115 Million Investment Plan Page 1 of2
Jane Kreller <[e-mail]>ImaGFT
SUEZ Gompletes Sweeping $115 Million lnvestment Plan
1 message
mysuezwater.com <[e-mail]>
Reply-To: [e-mail]
To: [e-mail]
Thu, Oct 1,2020 at 2:05 PM
SUEZ COMPLETES SWEEPING $115 IMILLION
INVESTTVIENT PLAN IN WATER SYSTETVI PROJECTS IN
IDAHO
Community benefiting from enhanced service, safety and boost to local economy.
SUEZ announced the completion of a S-year comprehensive effort to add approximately $1 15 million in
customer improvements to the Treasure Valley's largest water system that serves 230,000 people.
lmprovements include new pipes to minimize leaks and service disruptions, new pumping stations to ensure
everyone has adequate water pressure and new treatment technologies to help ensure high-quality, clean
water. SUEZ filed a detailed report for approval with the ldaho Public Utilities Commission.
lf the ldaho Public Utilities Commission approves the request in full, customer bills would be adjusted by
22.3%. The average residentialbillwould increase by $0.22 a day or $6.61 per month, the average
commercial bill by $0.77 a day or $23.51 a month, and the average public authority bill by $0.62 a day or
$18.97 a month. Company revenues would increase by $10.2 million per year.
Fai r H ousi ns' i,!i;U.,:#i
Attachment
Page 1 of2
https://mail.google.com/mail/u/O?ik=8ccafl791r*ri.*--pt&search:all&permthid:thread-f... 21812021
Gmail - SUEZ Completes Sweeping $l l5 Million Investment Plan Page 2 of2
Despite the large investment in the system and any adjustments to water bills, rates for SUEZ customers in
ldaho will remain below or competitive wlth every other water utility in the valley - public or private.
The $1 15 million in projects also highlight the company's commitment to improve lives and communities in
ldaho by helping to stimulate and sustain the local economy. The extensive upgrades in water infrastructure
will have long-lasting impacts. They not only have brought enhanced water quality and service, but they have
helped sustain jobs and and have kept the local economy churning, even in the midst of the health crisis.
It will take several months for the Commission to accept, reject or modify the first review of a large-scale
investment effort in five years.
This application is a proposal, subject to public review and a Commission decision. Written comments
regarding the SUEZ' application may be filed with the Commission. A copy of the application is available for
review at the offices of the Commission, SUEZ, and on the Commission's homepage at www.puc.idaho.gov
Sign up for the commission's RSS feed to receive email updates on the case.
Learn more at: www.mysuezwater.com/idahoinvestments2020.
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SUEZ WATER IDAHO INC.
CASE SUZ.W.2O.O2
INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S
FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION TO
SUEZ WATER IDAHO, INC.
P repa rer/Sponso ri n g Witness : Marshal! Thompson
FAIR HOUSING REQUEST FOR PRODUCTION NO. 2:
Produce a copy of each and every item pertaining to any action in which you engaged to
give notice to housing consumers in the relevant service area regarding the rate increases
that you have proposed in this proceeding described or discussed in your response to
lnterrogatory No. 1 above.
RESPONSE NO.2:
Please see the response to lnterrogatory No. 2
suz-w-20-02
FAIR HOUSING PRODUCTION 2
Page 1 of 1