20230717Staff 9 to VEO.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION ]M L;
PO BOX 83720
BOISE,IDAHO 83720-0074 y =
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF VEOLIA WATER )IDAHO,INC.'S APPLICATION FOR )CASE NO.VEO-W-23-02
APPROVAL OF INTERCONNECTION )AGREEMENT WITH CITY OF MERIDIAN )
)SECOND PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO VEOLIA WATER IDAHO,
)INC.
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Veolia Water Idaho,Inc.("Veolia"or
"Company")provide the followingdocuments and information as soon as possible,but no later
than MONDAY,JULY 31,2023,1.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,additional documents that it,or any person
acting on its behalf,may later obtain that will augment the documents or information produced.
i Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.1 JULY 17,2023
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.9:Please provide a copy of the Idaho Department of Environmental
Quality ("DEQ")approval document(s)for compliance with IDAPA 58.1.08,Section 542.02.d
(interconnection between potable water supplies).
DATED at Boise,Idaho,this 17th day of July 2023.
'Deputy AttorneyGeneral
i:umise:prodreq/veow23.2cbms prod req 2
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.2 JULY 17,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17th DAY OF JUNE 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO VEOLIA WATER IDAHO,INC.,IN CASE NO.
VEO-W-23-02,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
PRESTON N CARTER
MORGAN GOODIN
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-MAIL:[e-mail]
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE