20210323Staff 1-3 to Suez.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03s7
IDAHO BAR NO. 5470
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
WESTERN AIRCRAFT,INC.
CASE NO. SUZ-W-21.01
COMPLAINANT
vs.FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
SUEZ WATER IDAHO,INC.
SUEZ WATER IDAHO INC.,
RESPONDENT.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond, Jr., Deputy Attorney General, requests that Suez Water Idaho, Inc. ("Suez or
"Company") provide the following documents and information as soon as possible, or by
TUESDAY, APRrL 6, 2021.r
This Production Request is continuing, and Suez is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may later
obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Suez is reminded that responses pursuant to
I Stuffir requesting an expedited reryonse. If responding by this date will be problematic, please call Staff s attorney
at (208) 334-03s7.
FIRST PRODUCTION REQUEST
TO SUEZ WATER
MARCH 23,202I
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Commission Rules of Procedure must include the name and phone number of the person preparing
the document, and the name, location and phone number of the record holder and if different the
witness who can sponsor the answer at hearing if need be. Reference IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Regarding the non-potable lines encountered during Western's
excavation for the Hangar 0 project:
a. What is the purpose of these lines and whom do they serve?
b. Who installed these lines?
c. Were these lines installed before or after the Suez main on Boeing?
d. Please provide a drawing showing the location of these lines. Are they above or below
the Suez main?
REQUEST NO.2: Regarding the sewer line encountered during Westem's excavation for
the Hangar 0 project:
a. Whom does this sewer line serve?
b. Who installed this line?
c. Was this line installed before or after the Suez main on Boeing?
d. Please provide a drawing showing the location of this line. Is it above or below
the Suez main?
REQUEST NO. 3: What are the fire flow requirements for each of the following
hydrants?
a. Hydrant 1298
b. Hydrant 0013335
Dated at Boise,Idaho, this 23'd day of March202l
John Jr.
General
i:umisc/prod req/suzw2l. ljh prod reql suez
FIRST PRODUCTION REQUEST
TO SUEZ WATER
2 MARCH 23,202I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF MARCH2O2I,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO SUEZ WATER IDAHO, INC., IN CASE NO.
SUZ-W.ZL-OI, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
DAVID H LEROY
ATTORNEY AT LAW
802 W BANNOCK ST STE 201
BOISE ID 83702
E-MAIL: [e-mail]
PRESTON N CARTER
BLAKE W RINGER
GIVENS PURSLEY LLP
PO BOX2720
BOISE rD 83701-2720
E-MAIL:com
blakerineer@g ivenspursley.com
MARSHALL THOMPSON
SUEZ WATER IDAHO INC
8284 W VICTORY RD
BOISE ID 83709
E-MAIL: [e-mail]
.1,- /lA^^
SECRETItrY
CERTIFICATE OF SERVICE