20180905Reply Comments.pdf

Michael C. Creamer,ISB #4030
GIVENS PURSLEY LLP
601 W. Bannock St.
P.O.Box2720
Boise, Idaho 83701-2720
Telephone: [phone]
Facsimile: 208-388-1300
Attorneys for SUEZ Water ldaho Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISION
RECEIVED
?0lB S[p -S pl,t 3: tr6
ii, ',-' '-r r'',r r^- .. ,.._.._ ,i : L, I- U flLlL,' rr_;, ; -,; :CF,.iL{ISS|ON
IN THE MATTER OF THE JOINT
APPLICATION OF UNITED WATER
IDAHO INC., AND ABRIAN
SUBDIVISON WATER USERS
ASSOCIATION FOR APPROVAL OF AI\
AMENDMENT TO CERTIFICATE OF
PUBLIC CONVENIENCE AND
NECESSITY NO. 143; APPROVAL OF AN
AGREENT FOR CONNECTION AND
TRANSFER OF WATER SYSTEMS;
APPROVAL OF RATES AND CHARGES
Case No. Ur#I+l+0h StE- td-18 -o \
SUEZ'S RESPONSE TO
COMMENTS OF COMMISSION
STAFF AND BRIAN SUBDIVISION
WATER USERS ASSOCIATION
SUEZ Water Idaho Inc., (the "Company'') through its attorneys of record, submit
the following Response to Comments of the Commission Staff dated August 23,2018
and to the Testimony of Brian Subdivision Water Users Association ("BSWUA") filed
with the Commission on August 21, 2018 in the above-referenced case.
1. Response to Staff Comments
a. Alternative Cost Allocation Proposal and Revised Surcharge
The Staff s comments propose, among other things, an adjustment to the allocation of
final project costs; in particular, the allocation of the $260,500 of costs for pipeline construction
that exceeded the Company's original estimate. The Company supports Staff s proposal to
move $260,500 of the additional project costs into rate base and to reduce the amount to be bome
SUEZ'S RESPONSE TO COMMENTS - 1
1432 I 879_l.doc[30-172]
by Brian Subdivision customers to a total of $278,773, which will lower the bi-monthly
surcharge to $141 .35,$70.67 monthly, and the one-time lump-sum pa5rment to $5,808.22.
The Company agrees that this approach will help to mitigate the financial impact of the
unforeseen additional costs on the small number of Brian Subdivision customers by
modifying the cost allocation and adjusting the surcharge amount. The Company
understands that project costs not supported through revenue collected from the surcharge
will be subject to post-closing allowance for funds used during construction and be
collected through base rates without being subject to 13-month averaging in a subsequent
rate case.
b. Budget Billing, Conditions of Contract and Customer Notification
The Company agrees with Staff s proposed Schedule 1C adjustment and inclusion of a
Budget Billing monthly amount. The Company further agrees to clarify the conditions of
contract and would not seek to alter the amount or terms associated with the surcharge amount in
subsequent general rate proceedings.
The majority of Brian Subdivision customers will have the option to elect Budget Billing
by November 2018, depending on their initiated date of service with the Company. However,
the Company is unable to offer the Budget Billing option to any customer with less than twelve
months of billing history on record in its customer information and billing system. The
Company's billing system does not allow for estimations of prior usage, nor does it have the
ability to calculate Budget Billing options based upon a customer billing history of less than
twelve months. Customers may enroll in Budget Billing immediately following their twelfth
month of available billing data.
SUEZ'S RESPONSE TO COMMENTS - 2
I4321879 l.doc[30-172]
The Company will notify Brian Subdivision customers of the various payment & billing
options available to them following the final Commission order. The Company will inform Brian
Subdivision customers that they will default to a bi-monthly surcharge if they choose not to
notify the Company of their preferred billing option within thirty days after the final Commission
order. Customers may modify their billing option following this date if they wish to later elect
the one-time lump-sum surcharge payment amount, or to enroll in the Budget Billing option.
2. Response to BSWUA Comments
The Company has also reviewed BSWUA's comments styled as "testimony" filed with
the Commission on August 21,2018 and fuither comment of Mr. Juengling submitted via email
to Ms. Terri Carlock on August 23,2078. The Company appreciates the financial burden that
any surcharge may place on customers with limited financial resources. However, as stated in
Mr. Juengling's Direct Testimony submitted with the Company's and BSWUA's Joint
Application to the Commission, after an extensive investigation by BSWUA, it determined a
connection to the Company's system, via the new pipeline, to be "the only feasible [water
supplyl option for the Brian Subdivision." R. Juengling, Direct Testimony,p.4,l.18-19. The
Company understands that all parties and the Commission were in agreement on the need for the
project, the relative benefits it would provide to Brian Subdivision residents, the Company and
its other customers, and the appropriateness of the proposed cost allocation when the Joint
Application was considered. The Company believes that Staff s recommendation with respect to
the $260,500 of additional pipeline cost is a reasonable and equitable approach to mitigating its
impact while substantially honoring the material terms of the parties' agreement, their Joint
Application and the Commission's Order.
SUEZ'S RESPONSE TO COMMENTS - 3
14321879 Ldoc[30-172]
The Company also points out that the new pipeline under the Boise River provides the
primary water supply to Brian Water Subdivision. Homes separate from the Brian Subdivision,
off Warm Springs Avenue between Highland Valley Road and Signal Rock Drive, continue to be
provided their water supply from the Company's existing Harris Ranch Reservoir in the Harris
Ranch development. As an engineering best practice, a pipeline interconnection between the
Harris Ranch system and the Boise River Crossing pipeline has been established to function as a
redundant source of supply into the Harris Ranch area. However, neither this interconnection
nor the Boise River Crossing pipeline serve as the primary supply for any areas west of Signal
Rock Drive.+
RESPECTFULLY SUBMITTED this 5 auy of September,20l8.
GIVENS PURSLEY LLP
B
Michael C. Creamer
Attorneys for SUEZ Water ldaho Inc.
SUEZ'S RESPONSE TO COMMENTS - 4
14321879 l.doc[30-172]
vI HEREBY CERTIFY that on theS day of September, 2018 I caused an original and
seven (7) copies ofthe foregoing to be served upon:
CERTIFICATE OF SERVICE
Diane Hanian, Secretary
Idaho Public Utilities Commission
472 W . Washington Street
Boise, ID 83702
by hand delivering the same to the above-named at the last known address(s) as set forth above.
I also served a true and correct copy to the address listed below via regular mail:
Richard Juengling
President, Brian Sub Water Users
5885 S. Eastwood Place
Boise, ID 83716
Email: iuenelinsrichard@Ef,nail.com
Michael C. Creamer
SUEZ'S RESPONSE TO COMMENTS .5
14321879 l.doc[30-172]