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Home My WebLink About20210304IFHC 3-12 to Suez.pdfKEN NAGY (I.S.B. No. 6176) ATTORNEY AT LAW P.O. Box 164 Lewiston,Idaho 83501 Telephone: (208) 301 -0126 Facsimile: (888) 291 -3832 E-mail: knagy@lewiston.com ATTORNEY FOR INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, II\IC. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF SUEZ WATER IDAHO INC.'S APPLICATION FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN IDAHO ) ) ) ) ) ) ) CASE NO. SUZ-W-20-02 INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, [NC.'S SECOND INTERROGATORIES AND REQUEST FOR PRODUCTION TO SUEZ WATER IDAHO,INC. PROPOUNDED TO:Suez Water Idaho, Inc. and its attorneys of record, Michael C. Creamer and PrestonN. Carter Intervenor Intermountain Fair Housing Council, Inc. March 3,2021 Two (Nos. 3-10) Two (Nos. 3-4) PROPOUNDED BY: DATE: Interrogatories Set No. : Request for Production Set No COMES NOW the Intervenor [ntermountain Fair Housing Council, Inc. ("Intervenor"), by and through its attomey of record Ken Nagy, Attorney atLaw, and hereby submits to Suez INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S SECOND INTERROGATORIES AND REQUEST FOR PRODUCTION TO SI.]EZ WATER IDAHO,INC. KEN NAGY Attorney et Lrw Lewiston, Idaho Water Idaho, Inc. and its attorneys of record the Interrogatories and Request for Production described below pursuant to IDAPA $31.01.01.225. The lntervenor submits these lnterrogatories to be answered separately and fully in writing under oath within twenty-one (21) days from the date of service of said Interrogatories upon you. In responding to these lnterrogatories, you are required to fumish such information as is available to you and not merely information which you know of your own personal knowledge, including information in the possession of your agent, or attorney, or any investigator for the answering party. These Interrogatories are continuing in nature and the Intervenor demands 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. This request is continuing in nature and it is expressly requested that any relevant correspondence, information, documents or writing coming into the possession of you, your agents, or your counsel be promptly furnished to the undersigned afforney of record. The terms "document" and "documents" include but are not limited to all handwritten, typed, printed or photostatic material and drafts, duplicates, carbon copies or any other copies thereof, in the possession, custody or control of you or yoru counsel. If any portion of the documents requested to be produced was, but no longer is, in your possession or control or is no longer in existence, state whether it is: 1. Missing or lost; 2 INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S SECOND INTERROGATORIES AND REQUEST FOR PRODUCTION TO SI]EZ WATER IDAHO,INC. KEN NAGY Attorney atLaw Lewistoo, Idaho 2. Destroyed; 3. Transferred voluntarily or involuntarily to other, and if so, to whom; 4. Otherwise disposed of. In each instance, explain the circumstances surrounding the authorization for such disposition and state the approximate date thereof. Your response to these discovery requests shall be mailed or otherwise delivered to the undersigned KenNagy, Attorney atLaw, P.O. Box 164, Lewiston, Idaho 83501. INTERROGATORY NO. 3: When you provided notices to housing consumers in the relevant service area regarding the rate increases that you have proposed in this proceeding, specify all languages in which you provided such notices. INTERROGATORY NO. 4: State whether you receive or have received any funding from the federal government. If the answer is in the affirmative, specify in detail the amounts you receive or have received, and the purpose for which you receive or have received such funding. NTERROGATORYNO. 5: If youranswerto InterrogatoryNo.4 above is inthe affirmative, do you have a Language Access Plan (LAP)? If the answer is in the affirmative, describe with specificity the content of your LAP. REOUEST FOR PRODUCTION NO. 3: Produce a copy of your Language Access Plan (LAP) and all documents pertaining thereto discussed in response to lnterrogatory No. 5 above. INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S SECOND INTERROGATORIES AND REQUEST FOR PRODUCTION TO SUEZ WATER IDAHO,INC. J KEN NAGY Attorney rt Lrw Lewiston, Idaho INTERROGATORY NO. 6: To give notice to housing consumers in the relevant service area regarding the rate increases and other relevant matters at issue in this proceeding, do you use an affirmative marketing plan? If the answer is in the affirmative, describe with specificity the content of your affirmative marketing plan. REOUEST FOR PRODUCTION NO. 4: Produce a copy of your affirmative marketing plan and all documents pertaining thereto discussed in response to Interrogatory No. 6 above. INTERROGATORY NO. 7: Explain in detail the reasons that you completed alterations or improvements to your system prior to seeking approval of the rate increase that you have requested in this proceeding. INTERROGATORY NO. 8: Describe in detail how you have or will address and/or remediate water quality issues as part of the alterations or improvements to your system for which you are seeking approval of a rate increase in this proceeding. INTERROGATORY NO. 9: Will you increase your profitability in the event that the Idaho Public Utilities Commission approves the rate increase that you are seeking in this proceeding? INTERROGATORY NO. 10: If your response to Interrogatory No. 7 above is in the affirmative, specify in detail the amount that you will increase your profitability in the event that the Idaho Public Utilities Commission approves the rate increase that you are seeking in this proceeding. INTERROGATORY NO. 1 1: [n your response to Interrogatory No. 2 inyow Suez Water ldaho Inc.'s Response to Intervenor Intermountain Fair Housing Counsel [sicJ, Inc.'s 4 INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S SECOND INTERROGATORIES AND REQUEST FOR PRODUCTION TO SI.]EZ WATER IDAHO,INC. KEN NAGY Attorney at Law Lewiston, Idaho First Interrogatories and Requestfor Production dated. February 18,202I, you attached a copy of an email dated "Oct. 1,2020 at2:05 PM" which states that you will increase your revenues by *$10.2 million per year." In the event that the Idaho Public Utilities Commission approves the rate increase that you are seeking in this proceeding, specify how you will apply that increase in revenues. INTERROGATORY NO. 12: In the event that you state in your response to InterrogatoryNo. 9 above that the increase in revenues will be applied in part or in whole to the costs you have incurred in completing alterations or improvements to your system, will your rates decrease when such costs have been paid for? DATED 1ri, 3rd day of March 2021 Ken Nagy Digiblt rigned by X.n Nagy Dl{: (n-Kah N.iry, o=Atory .t lrq ou, cmilioagyoLwistonrom, GUS D.h: 2O2l .03.03 2002:02 .08'00' KEN NAGY Attorney for Intervenor Intermountain Fair Housing Council,Inc. CERTIFICATE OF SERVICE I hereby certify that on 6" 3rd day of March ,2021,I caused to be served a full, true, and accurate copy of the foregoing by the method/s indicated below, and addressed to the following: JanNoriyuki Commission Secretary Idaho Public Utilities Commission 11331 W. ChindenBlvd. Building 8, Suite 201-4 P.O. Box 83720 Boise, lD 83720 [ ]Bv lxl ny U.S. Mail Email to: ian.noriyuki(dpuc.idaho. sov matt.hunter@nuc. idaho. gov terri. carlock@puc. idaho. gov 5 INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S SECOND INTERROGATORIES AND REQUEST FOR PRODUCTTON TO SUEZ WATER IDAHO,INC. KEN NAGY Attorney rt Lrw kwiston, Idaho Michael C. Creamer Preston N. Carter Givens Pursley LLP Attorneys at Law 601 W. Bannock St. Boise, D 83702 tllxl By U.S. Mail By Email to: mcc@givenspurslev.com and prestoncarter@ givenspursley. com DavidNjuguna Suez Water Management & Services 461 From Rd., Suite 400 Paramus, N.J. 07052 [ ] Bv U.S. Mail Ix] By Email to: David.njuquna@,suez.com Dayn Hardie Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd. Building 8, Suite 201-4 P.O. Box 83720 Boise, D 83720 [ ] BvU.S. Mail I x] By Email to: davn.hardie@,puc.idaho.eov Lorna Jorgensen John Cortabitarte Ada County Prosecuting Attomey's Office Civil Division 200 W. Front St., Room 3191 Boise, lD 83702 [ ] Bv U.S. Mail Ix] By Email to: ljoreensen@adacountv.id.eov i cortabitarte@ adacounty. id. eov Mary Grant Depury City Attorney City of Boise 150 N. Capitol Blvd. P.O. Box 500 Boise,ID 83701-0500 [ ] Bv U.S. Mail I x] By Email to: mrgrant@cityofboise.org Norman M. Semanko Parsons, Behle & Latimer 800 W. Main St., Suite 1300 Boise, D 83702 t 1x I By U.S. Mail ] By Email to: NSemanko(@parsonsbehle.com Boisedocket@parsonsbehle. com 6 INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S SECOND INTERROGATORIES AND REQUEST FOR PRODUCTION TO SUEZ WATER IDAHO,INC. KEN NAGY Attorney at Lsw Lewiston, Idaho Marty Durand Piotrowski Durand, PLLC 1020 Main St., Suite 440 P.O. Box 2864 Boise,ID 83701 [ ] Bv U.S. Mail [x ] By Email to: marty@idunionlaw.com Bard M. Purdy 2019 N. 17ft St. Boise, ID 83702 [ ] Bv U.S. Mail I x] ByEmail to: bmpurdy@hotmail.com Austin Rueschhoff Thorvald A. Nelson 555 17th St., Suite 3200 Denver, CO 80202 [ ] Bv U.S. Mail [X ] By Email to : darueschhoff@,hollandhart. com tnelson@hollandhart. com aclee@ hollandhart. com gl earsanoamari@hollandhart. com Jim Swier Greg Harwood Micron Technology, Inc. 8000 S. Federal Way Boise, lD 83707 [ ] Bv U.S. Mail lxl BvEmail to:com gbharwood@micron.com Ken Nagy Digfr.lly tigh.d by h Nagy DN: 6i(.n N.gy. o-Atom.y .t [.w ou,.hd=lEgyQlsido<oD cdJS Dare: 202t.03.03 20Sl {3 {8'00' Ken Nagy 7 INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S SECOND INTERROGATORIES AND REQI]EST FOR PRODUCTION TO SUEZ WATER IDAHO,INC. KEN NAGY Attorney at Law kwiston, Idaho