20210225Micron 7-23 to Suez.pdf

Austin Rueschhoff ISB No. 10592
Thorvald A. Nelson
HorreNo & HaRtru
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
fi relson@hollandhart. com
Attorneys for Micron Technology, [nc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF SUEZ WATER IDAHO ) CASE NO. SUZ-W-20_02
INC.'S APPLICATION FOR AUTHORITY )
TO INCREASE ITS RATES AND CHARGES ) SECOND PRODUCTION
FOR WATER SERVICE IN IDAHO ) REQUEST 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 AND INSTRUCTIONS
Please respond to these interrogatories and requests for production of documents by March
t8,2021.
DEFINITIONS
"SUEZ Water ldaho, Inc.," "SUEZ," "the Company," or o'you" means SUEZ Water Idaho,
Inc. and the employees, offrcers, directors, agents, consultants, attorneys and all persons
acting under contractual arrangement with or acting or purporting to act on behalf of SUEZ.
1
MICRON TECHNOLOGY, INC.'S
SECOND PRODUCTION REQUEST
TO SUEZ WATER I FEBRUARY 25,2021
2
3
"Agreement" means any contract, written or oral, or any non-contracfual understanding
"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, electonic
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 refurn, telegram, telex, report, record, order or notice of
governmental action of any kind, study, minutes, logs, graph, index, tape, disc, intemal
operating manual, data sheet or data processing card, or any other written, recorded,
transcribed, punched, taped, filmed, graphic or retrievable maffer 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
identifu 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 of the 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 "identifu" 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
MTCRON TECHNOLOGY, INC.'S
SECOND PRODUCTION REQUEST
TO SUEZ WATER -2- FEBRUARY 25,2021
4.
5
6.
7
8.
group with which such person is identified in response to any requests, provided,
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 employ 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 narne, business,
type of entity, present status 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, group, individual or orgarization of any type
whatsoever.
11. "PLJC" or "Commission" means the Idaho Public Utilities Commission.
t2 "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.
13."Relating To" or "Related To" means pertaining to, presenting, discussing, commenting
on, analyzing, or mentioning in any way.
MICRON TECHNOLOGY, INC.'S
SECOND PRODUCTION REQUEST
TO SUEZ WATER 3 FEBRUARY 25,2021
b.
c.
d.
10.
I
2.
3
4.
5
6.
7
8
9.
GENERAL INSTRUCTIONS
lnterrogatories and requests for production must be answered with particularity and in
detail.
Interrogatories 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
31.01.0t.225.
lnterrogatories 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 identiffing the documents which relate to your answers. You must also clearly
identifu 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 supplemental answers.
In answering these interrogatories and requests for production you should furnish all
information which is in your possession, custody or control 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, employees, former ernployees, and any other agents as appropriate or
available and with reference to the sources described above.
If the respondent is not a witress who has filed written direct testimony, please indicate
which of the company's witnesses will be prepared to answer these questions on the stand.
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.
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.
10.
11
MICRON TECHNOLOGY, INC.'S
SECOND PRODUCTION REQUEST
TO SUEZ WATER -4-FEBRUARY 25,2027
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
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
darueschhoff@hollandhart. com
aclee@hollandhart. com
sl earsanoamari@hollandhart. com
INTERROGATORIES AI\D REOUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 7: Please provide Suez Water Idaho's definition of a Residential
customer. Please include documentation supporting the response.
REQUEST NO. 8: Please provide Suez Water Idaho's definition of a Commercial
customer. Please include documentation supporting the response.
REQUEST NO. 9: Please provide Suez Water Idaho's definition of an Other Public
Authority Customer. Please include documentation supporting the response.
REQUEST NO. 10: Please provide Suez Water Idaho's definition of Private Fire
Customer. Please include documentation supporting the response.
REQUEST NO. 11: Please state whether the customer classes included in the class cost
of service study sponsored by Mr. Prettyman accurately align with the definitions provided above,
in response to Request Nos. 7 - 10.
REQUEST NO. 12: With respect to the Private Fire Service class included in the class
cost of service study, please provide the following:
t2.
MICRON TECHNOLOGY, INC.'S
SECOND PRODUCTION REQUEST
TO SUEZ WATER -5-FEBRUARY 25,2021
a.Please provide a detailed description of the type and size of customers included in
this customer class. For example, do residential customers take Private Fire
Service? Or, do larger customers like commercial businesses and manufacturers
take Private Fire Service?
Please state the test year number of Residential customers included in the Private
Fire Service class in the cost of service study. Please break out this number by each
size of Private Fire Line offered by the Company.
P1ease state the test year number of Commercial customers included in the Private
Fire Service class in the cost of service study. Please break out this number by each
size of Private Fire Line offered by the Company.
Please state the test year number of Other Fublic Authority customers included in
the Private Fire Service class in the cost of service study. Please break out this
number by each size of Private Fire Line offered by the Company.
REQUEST NO. 13: Please refer to Exhibit 5, Schedule 3, and the Company's adjustments
Rl, R2, and R3.
For each size of Private Fire Line identified in Exhibit 5, Schedule 3, please state
the adjusted test year number of bills developed by the Company.
For each size of Private Fire Line, please break out the test year number of bills
identified in part a., between Residential, Commercial, and Other Public Authority.
REQUEST NO. 14: With respect to Private Fire Service rates, please provide the
following:
Please provide a detailed explanation as to why the current fixed monthly charges
for Private Fire Service customers are significantly less than the fixed monthly
meter charges under the General Metered Service tariff, for meters of the same size.
Please provide the cost basis for the rate differential discussed in part a., with
references to class cost of service studies if applicable.
REQUEST NO. 15: Please explain whether the Company has customers who use large
amounts of water for irrigation. If so, please provide a detailed description of these customers and
identiff their usage characteristics, annual and monthly volumes in gallons, meter size, and size
and length of distribution mains used to connect them to the system, and extra capacity demands.
Please identi$ which customer class in the cost of service study includes these irrigation customers
and loads. Please identify the tariffrate schedule applicable to the irrigation load.
REQUEST NO. 16: If Suez has a significant amount of irrigation load, please state
whether or not it has considered establishing a separate customer class and rate schedule for these
customers. Please include a detailed explanation supporting the response.
b.
c.
d.
a.
b.
a.
b.
MICRON TECHNOLOGY, INC.'S
SECOND PRODUCTION REQUEST
TO SUEZ WATER -6-FEBRUARY 25,2021
REQUEST NO. 17: Please state whether or not the Company has any agricultural
irrigation customers. If the response is affirmative, please provide the following:
The number of these customers served by Suez Water Idaho.
Monthly water use for each of these customers for the most recent five year period.
(Please clearly identiff the units of consumption).
The number of and size of the meters used to provide service to each of these
customers.
Identiff the rate schedule serving each of these customers.
REQUEST NO. 18: Regarding distribution mains:
Please identiff all sizes (in diameter) of distribution mains installed on the
Company's distribution system.
For each main size identified in part a., above, please provide the total length of
main installed on the Company's distribution system.
Please describe the Company's meter installation protocols in terms of speciffing
the size of a main that is needed to connect a specific meter size to its distribution
system.
REQUEST NO. 19: Please identifu the number of meters, the size of the meters, and the
sizes of distribution mains that serve Residential customers.
REQUEST NO. 20: Please identiff the number of meters, the size of the meters, and the
sizes of distribution mains that serve Commercial customers.
REQUEST NO.21: Please identiff the number of meters, the size of the meters, and the
sizes of distribution mains that serve Other Public Authority customers.
REQUEST NO.22: Please provide documentation desuibing Suez Water Idaho's meter
installation policies, including descriptions of the sizes of mains that can be used to safely and
reliably provide service to various meter sizes.
REQUEST NO. 23: Of the Company's total claimed revenue requirement of
$55,818,645, please provide the following:
Please state the amount (in dollars and as a percentage) of the total proposed
revenue requirement that is fixed.
Please state the amount (in dollars and as a percentage) of the total proposed
revenue requirement that is variable.
MICRON TECHNOLOGY, INC.'S
SECOND PRODUCTION REQUEST
TO SUEZ WATER -7-FEBRUARY 25,2021
a.
b.
c.
d.
b
c.
a.
a.
b.
c.Please state the amount (in dollars and as a percentage) of the total proposed
revenue requirement that would be recovered through the Company's fixed
monthly charges.
d.Please state the amount (in dollars and as a percentage) of the total proposed
revenue requirement that would be recovered through the Company's proposed
volumetric charges.
Respectfully submitted February 25, 2021.
HOLLAND & HART, rrr
By
Rueschhoff, ISB No. 105
ThorvaldA. Nelson
555 lTthSteet, Suite 3200
Denver, CO 80202
Telephone: [phone]
Facsimile: (720) 235 -0229
Email: [e-mail]
tnelson@hollandhart. com
Attorneys for Micron Technology, Inc.
MICRON TECHNOLOGY, INC.'S
SECOND PRODUCTION REQI.JEST
TO SUEZ WATER -8-FEBRUARY 25,2021
CERTIFICATE OF SERVICE
I hereby certit/ that on February 25, 202t, a true and correct copy of the within and
foregoing SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO SLJEZ
WATER IDAHO, INC. was served in the mailler shown to:
Idaho Public Utilities Commission
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
1 133 1 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@ qivenspursley. com
prestoncarter@ givenspurslev. com
Ada County
Lorna Jorgensen
John Cortbitarte
Ada County Prosecuting Attorney's Offrce
Civil Division
200 W. Front Steet, Room 3191
Boise, lD 83702
[e-mail]. eov
MICRON TECHNOLOGY, [NC.'S
SECOND PRODUCTION REQUEST
TO SUEZ WATER
Matt Hunter
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
I 133 I W. Chinden Boulevard
Building 8, Suite 201-A
P.O. Box 83720
Boise lD 83720
Matt.hunter@puc. idaho. eov
[e-mail]. eov
Suez Water Management & Services
DavidNjuguna
Suez Water Management & Services
461 From Road, Suite 400
Paramus, NJ 07052
David.niueuna@ suez. com
Community Action P artners hip
Association of ldaho
Brad M. Purdy
Attorney atLaw
2019 N. 17th Street
Boise, D 83702
[e-mail]
-9-FEBRUARY 25,2021
City of Boise City
Mary R. Grant
Deputy City Attorney
Boise City Attorney's Office
150 N. Capitol Boulevard
P.O. Box 500
Boise, ID 83701-0500
Boi seC ityAttorney(d cityo fboi se. or g
Intermountain Fair Housing Council, Inc.
KenNagy
Attorney at Law
P.O. Box 1264
Lewiston,ID 83501
knaey(a,lewiston.com
SUEZ Water Customer Group
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise,lD 83702
nsemanko (dp arsonsbehle. com
boisedocket(Eparsonsbehle. com
Micron Technologt, Inc.
Jim Swier
Greg Harwood
Micron Technology, Inc.
8000 South Federal Way
Boise,lD 83707
[e-mail]
[e-mail]
MICRON TECHNOLOGY, INC.'S
SECOND PRODUCTION REQUEST
TO SUEZ WATER
Gannon, Montero, Graziano, Philp
Marty Durand
Piotrowski Durand PLLC
1020 Main Steet, Suite 440
P.O. Box 2864
Boise,ID 83701
[e-mail]
Zoe AwrOlson
Executive Director
Intermountain Fair Housing Council, [nc.
4696W. Overland Rd., Suite 140
Boise,ID 83705
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
darueschho ff(dhollandhart. com
tnel son(E hollandhart. com
aclee(Ehollandhart. com
el qareanoamari(Ahollandha(. com
s/ Gina Garsano-Amari
-10-FEBRUARY 25,2021