20181115Cooper Direct.pdf

Michael C. Creamer (ISB No. 4030)
Givens Pursley LLP
601 W. Bannock St.
Boise, lD 83702
Telephone: [phone]
Facsimile: (208) 388-1 300
mcc@ eivenspursley. com
Attorneys for SUEZ Water ldaho Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!-r !-- a [: t,, i :-: nI r,.* l-, L , ,,, ;:J
Ir ll,ly I5 fli,l l0: 20
IN THE MATTER OF THE JOINT
APPLICATION OF EAGLE WATER
COMPANY, INC. AND SUEZ WATER
IDAHO INC. FOR APPROVAL OF SALE
AND ACQUISITION OF EAGLE WATER
COMPANY, INC. ASSETS BY SUEZ
WATER IDAHO INC. AND AMENDMENT
OF CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY NO.
143, AND APPROVAL OF RATES AND
CHARGES
Case Nos. SUZ-W-18-02
EAG-W-18-01
DIRECT TESTIMONY OF CATHY COOPER
ON BEHALF OF SUEZ WATER IDAHO INC.
November 2018
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Please state your name and title.
My name is Cathy Cooper, P.E.. I am the Director of Engineering for SUEZ
Water Idaho Inc.
Please summarize your professional experience and educational background.
I am a graduate of the University of Colorado at Boulder with a Bachelor of
Science in Civil Engineering. I completed my Master of Science in Civil
Engineering at the University of Washington in Seattle. I have been a licensed
Professional Engineer in the State of Idaho since 1999.
I have been employed as a civil engineer for 24 years. My work experience
includes 22 years at Boise area consulting firms where I focused my work on
water system engineering. My experience includes preparing detailed hydraulic
calculations; designs for storage tanks, pump stations, pressure reducing stations,
pipelines, and well houses; water system Master Facility Plans; hydraulic models;
and project cost estimates. I was an Owner and the Managing Partner at my last
consulting firm.
I have been employed by SUEZ since July 2016 as the Director of Engineering in
Idaho.
What is the purpose of your testimony?
My testimony provides information on future source of supply needs for SUEZ
customers, SUEZ's plans for where that source will come from, and the projected
capital savings to SUEZ customers as a result of planned near-term capital
expenditures that could be avoided with the proposed acquisition of Eagle Water
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assets. My testimony also discusses the benefits I believe Eagle Water customers
would realize from the proposed Eagle Water asset purchase.
From an engineering and operational standpoint, there are significant efficiencies
to be gained for all customers in sharing sources of supply, redundant sources,
and storage tanks as I will further describe below.
Describe the location of Eagle Water Company in relation to the SUEZ water
system.
The following map shows SUEZ boundaries and pressure zones in the northwest
portion of the SUEZ system, with the Eagle Water Company boundary outlined in
green. You can see that Eagle Water Company and the SUEZ system share
boundaries on three sides. The relatively small area depicted north of Eagle
Water's main service area and east of SUEZ's Floating Feather zone is a small
development that also is served by Eagle Water with its existing system.
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Eagle Water Company
Service Area
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Floatiug feaihrr
\\'est First
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Describe existing SUEZ facilities in the area.
The following map shows SUEZ's primary sources of supply and facilities in the
northwest portion of its system. This area is supplied primarily by SUEZ's
Floating Feather well and Marden Water Treatment Plant (WTP). These main
sources fill the Hidden Hollow Tank, which provides storage for pumping north
to the large developments of Hidden Springs and Avimor. The Hidden Hollow
Tank also provides necessary fire protection and peaking supplies to SUEZ's
West Main Service Area. SUEZ's Redwood Creek well can provide
approximately fifty-five percent redundancy to the Floating Feather well through
a booster pump located at the Floating Feather well house.
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4visel
Floating Feather Well
Hidden !pj4g;
Redwood Creek Well
Marden WTP
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Please describe existing Eagle Water Company Facilities.
Eagle Water has seven well facilities and two booster pump stations. There are
no gravity storage tanks existing in the Eagle Water system. Eagle Water
provides all demands (maximum day, peaking, and fire flows) directly from their
wells. A map depicting the Eagle Water service area and key facilities is attached
as Attachment I to SUEZ's and Eagle Water's Joint Application.
I have performed an engineering and hydrogeologic analysis of the Eagle Water
system for SUEZ, and believe there are currently several regulatory shortfalls
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Hidden Hollow Tank
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Terr llile Ridge
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related to pumping capacity in the Eagle Water system that should be addressed in
the near-term. It appears that Eagle Water does not currently meet Idaho
Department of Environmental Quality (IDEQ) requirements for redundant non-
fire pumping capacity (IDAPA 58.01.08 Section 501.17), redundant fire pumping
capacity (IDAPA 58.01 .08 Section 501 .18), and emergency operation (IDAPA
58.01.08 Section 501.07). This means that with its largest well out of service the
Eagle Water system would fall short on peak hour flows or fire protection flows.
Under a power outage scenario, Eagle Water also would not be able to meet
average day plus fire flow demands.
Also, my analysis of Eagle Water's water rights indicates that Eagle Water's
current portfolio of municipal water rights does not include sufficient authorized
flow rate to meet the system's peak hour demands.
Based on the above-described analysis and conclusions, the Eagle Water system is
in need of near-term upgrades and investment regardless of whether the proposed
asset purchase is approved by the Commission and consummated by the parties.
If the asset purchase is approved, SUEZ proposes facility and permitting
improvements described below that would address these identified deficiencies.
Describe the benefits to existing SUEZ customers of acquiring Eagle Water
Company assets.
As part of SUEZ's ongoing planning and budgeting process, it has near-term
plans to increase the source of supply available to the northwest portion of its
system. An acquisition of the Eagle Water assets would provide additional source
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of supply at an estimated capital cost avoidance of approximately $ 1 1 .7M for
SUEZ customers.
Absent the Eagle Water acquisition, SUEZ has planned several major projects to
increase the amount of supply available to the northwest area of the SUEZ
system. The first project would be completion of the Redwood Creek Pipeline
and an upgrade to the Redwood Creek well pump capacity. SUEZ's existing
Redwood Creek Well can produce approximately 3,000 glm. It currently
produces around 600 gpm to serve the local area in the Floating Feather pressure
zone. Completing the Redwood Creek Pipeline will allow the available excess
water from Redwood Creek well to be transmitted to Hidden Hollow Tank where
it is needed. The second planned project involves improvements to SUEZ's
existing Island Woods #1 and #2 well facilities (located south of the Eagle Water
service area, across the Boise River) and completion of a pipeline across the Boise
River to connect the Island Woods wells to the Redwood Creek Pipeline. The
Island Woods Wells can currently each produce about 800 gpm, but with
upgrades could produce approximately 1,500 gpm each. Upgrading these wells
and piping them into the Redwood Creek Pipeline will allow for another 1,500
gpm total to be transmitted to Hidden Hollow Tank. The Island Woods upgrade
project will also require construction of a new 2 million gallon tank and
associated pump station to provide storage for pumping and keep the Island
Woods pressure zone at acceptable service pressures. We anticip ate that the 2
million gallon storage tank would be located northeast of the intersection of Old
Horseshoe Bend Road and Floating Feather Road. The pump station would be
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located near the intersection of Old Horseshoe Bend Road and Hill Road. The
third project is expansion of SUEZ's Marden Water Treatment Plant (WTP) by 6
million gallons per day. These three improvements will provide approximately
12.5 MGD of additional and redundant supply to the SUEZ system that our
planning projections indicate will be needed by 2022. Absent the Eagle Water
acquisition, they were budgeted to occur between 2018 and 2022 at a total cost of
approximately $41.8M and are summarizedinthe following table.
The acquisition of Eagle Water assets presents an alternative approach where
SUEZ customers canrealize the same benefits of additional source of supply for
less cost. Planned projects in conjunction with the Eagle Water acquisition
include the following. The first priority still would be completion of the
Redwood Creek Pipeline and an upgrade to the Redwood Creek well pump
capacity. The Redwood Creek Pipeline is an important project with or without
acquisition of Eagle Water because it enables use of the full capacity of the
existing SUEZ Redwood Creek well and will serve as a tie-in point for water from
other sources to be transmitted to Hidden Hollow Tank. The second project
would be the interconnection of Eagle Water Wells 6 and 8 with SUEZ's existing
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SUEZ SUPPTY INVESTMENTS ABSENT EAGLE WATER ACQUISITION
Redwood Creek line
S 5712.L6 Replace Redwood Creek Well Pump with 3000gpm Pump
0.00 Optimist Booster Pump Station / New 2 MG Tank 5 z,agq 5 2,894
2.L6 lsland Woods Connection 5 z,ttt 5 2,177
6.00
Marden Expansion (5 MGD, no DAF), includes Main Enlargements
to move the water away from Marden: Marden and Mobley Main
Enlargement (2300'of 35" pi pe), and Lewis / 5th Street Main
Enlargement (11,770'of 24" Pipe)s 2,46s 5 8,518 S 8,02s
s 2.032 S r2.o2z s 15.058 S 28.747 S 41.844Cumulative Cost (in mo's)
Cumulative MGD 4.3 4.3 12.5
Cost per MGD 5 s,sos S 3,48s S s,ssq S 3,3s3
Facility lmprovement 2018 2019 2020 z02L 2022MGD
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2.7(s 2.032 s 9.990
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Hidden Hollow tank. This would allow the tank to provide immediate redundant
fire supplies to Eagle Water customers and use of Wells 6 and 8 to fill Hidden
Hollow Tank. The third project would be construction of a 2 million gallon
storage tank to serve Eagle Water customers with peaking and fire storage, and
rehabilitation of Eagle Water well 1, which will allow Maximum Day Demand for
Eagle Water Customers to be provided within the pressure zone. These
improvements would be scheduled for 2018 to 2021if the acquisition is approved.
SUEZ's total costs for improvements both to bring the Eagle Water system up to
appropriate regulatory standards and achieve SUEZ's additional supply objective
of 12.5 MGD would be approximately $30.1M, including the $10M purchase
price for the Eagle Water assets. This represents an avoided capital cost to SUEZ
customers of approximately $11.7M ($41.8M less $30.1M). In addition, with
acquisition of Eagle Water, several existing sources will be preserved for future
supply expansion including SUEZ' Island Woods wells I and2, the Marden WTP
expansion, and Eagle Water wells 2 and 3 (future re-drilling). These avoided and
deferred improvernents will benefit both Eagle Water and SUEZ customers.
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SUEZ SUPPLY INVESTMENTS WITH EAGLE WATER ACQUISITION
Redwood Creek ne2.
2.76
Replace Redwood Creek Well Pump with 3000gpm Pump/higher
TDH S zog
0.00 EWCAcquisition Price S ro,om
s 560.00
Water Right Transfers / APODS to allow full capacity pumping
from EWC Wells
3.24 New Pump EWC Well 8, PRV, connect to RWC Pipeline S r,o+s
3.60 New Pump Well 6, PRV, connect to RWC Pipeline S 1,110
1.44
New 2 MG Tank / Rehab Well 1 (1000 gpm additional available
from Well 5)S z,mo s 3,13s5 z,uz 5 zz,on $ zs,sse S 30,141Cumulative Dollars
0.0 2.2 7.6 12,6Cumulative Supply Gained
Cost per MGD S to,22t S z,qzs S z,zgz
MGD Facility lmprovement 2018 20L9 2020 202t
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S 2.022 S 9.990
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SUMMARY OF AVOIDED CAPITAL COSTS
Absent the acquisition of Eagle Water assets, SUEZ plans to invest approximately
$41.8M to develop and transmit approximately 12.5 million gallons per day of
additional and redundant source of supply. With the acquisition of Eagle Water
assets, SUEZ would need to invest only $30.1M (rnctuaing tne $tOlU p
acquisition price) to develop the same amount of supply. These same supply
improvements would also bring Eagle Water into compliance with regulatory
requirements. This is a capital cost avoidance of $1 1.7M. SUEZ has estimated
that it could pay up to $21.7M for the Eagle Water assets and still break even
from a capital investment standpoint related to supply.
Because the projected capital cost avoidance for SUEZ customers with the
acquisition and integration of the Eagle Water assets exceeds the $10M purchase
price, SUEZ is requesting that the Commission allow the full acquisition price to
be recovered in rates.
Describe the benefit to existing Eagle Water Company customers of SUEZ
acquiring Eagle Water assets.
SUEZ believes there will be substantial tangible benefits to Eagle Water
customers from this acquisition. Portions of the supply projects previously
described will directly benefit Eagle Water customers. In addition, other projects
such as the addition of SCADA Controls, targeted pipeline upgrades, and change
outs to AMI meters would be completed. These improvements that will directly
benefit Eagle Water customers are detailed in the following table with estimated
costs.
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The planned capital improvements that will directly benefit Eagle Water
customers have been used in the Eagle Water rate calculations presented in Ms.
Cary's testimony.
In addition, there are other benefits for Eagle Water customers outside of capital
improvements that are discussed in the testimony of Mr. Thompson.
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PLANNED CAPITAT IMPROVEMENTS THAT WILL BENEFIT EAGTE WATER CUSTOMERS
Project Title
Costs (in 000's)
Benefit Summary20t92020202L
Add chlorination at Wells
2, 4, 6,7,8 Ss5
Chlorine residual in distribution system, protection against contamination risk. $10k
plus OH persite.
SCADA at each Facility
lWells2, 4,6,7,8,2
boosters), control room
and associated hardware
and software S s:z
SCADA controls at each facil ity wi I I al low for 24-hou r monitori ng of syste m ope rations.
lncludes 5250 for a control room, database, historian, radio path survey, etc if Eagle
Water constructed the improvement (no OH on this portion). S35k per site, S5k
continsencv. olus OH.
Meter and Service
Replacements (2,000 @
S15oo each)57,L29 5 1,129 S 1,129
Half of EwC meters - fix problematic meter locations, move into right-of-way, lessen
depth for safety and access. lnstall AMI meters. The benefits of AMI meters
include continuous reporting, with customers able to see water usage through the
Suez website, leak detection, and backflow detection.
Meter Replacement with
AMt (2m0 @ s388)s 4s4 5 438
Half of EWCmeters-lnstallAMl metersinexistingmeterboxes. Thebenefitsof AMI
meters lnclude continuous reporting, with customers able to see water usage through
the Suez website, leak detection, and backflow detection. lncludes S16k fortwo
repeaters if Eagle Water constructed the i mprovements, no OH on this portion.
Water Right Transfers to
add APODS to Eagle Water
and SUEz Rishts Ss6
These transfers would allow the two delivery systems to be integrated in the future,
enhancingthereliabilityandflexibilityof both. lnaddition,sharedEaglerightsand
SUEZ rights would fill the currentshortfall in Eagle Water rights to meet peak
demands. These transfers would eliminate the need for Eagle Waterto appropriate
new water rishts to fill its current shortfall.
Map EaBle Water System
into GIS and create
Hydraulic Model 527
Provides the benefit of crews being able to rapidly locate buried infrastructure.
lnclusion in the model will allow forsystem optimization and targeted pipeline
replacement planning. This will also include the Eagle Waterfacilities into
Aquadvanced Energy, an energy-saving system operations platform.
PRV at Well 8 S s28
PRV and porti on of pi pi ng wi I I i ntercon nect the Eagle Wate r system with the Suez
system. Will provide access to fire storage volume in Hidden Hollow Tank for Eagle
Watercustomers. Benefit of supply and storage from Suez system.
PRV at Well 6 S rqr
PRV and portion of pi pi ng wl I I I nte rconnect the Eagl e Wate r syste m with the Suez
system. Will provideaccesstofirestoragevolumeinHiddenHollowTankforEagle
Watercustomers. Benefit of supply and storage from Suez system.
Redwood Creek Pipeline S 2,133
The Redwood Creek pipeline will be the interconnection between the Eagle Water
system and the Suez system. This pipeline being in place will provide Eagle Water
customers with the benefit of being able to access source and storage from the Suez
system. The benefit is calculated on making up the redundancy shortfall in fireflow
for Eagle Water ( 1375 gpm). This would also coverthe shortage in peak hour
redundancy (1175 gpm) and the emergency standbyshonage (429 gpm). lt won't be
available to EWC customers untilthe PRV at well 8 is in place, which ls why it has
beenincludedin2020. Costcalculatedasaportionofthetotalpipelinecost,l3T5
gpm / 7EO gpm (ultimate pipeline capacity with 1000 gpm being used locally in
Floating Feather and Eagle Water area to support current customers and growth
through 2021).
2 MG Tank S 2,006 S 2,006
Will bring Eagle Water into compliance with IDEQ peak hour and fire flow supply and
redundancv reouirements
Pipeline Replacements
(1% peryear)S 3os S ros S 3os
0.6 miles of pi peline replacement per year. First years wil I target undersized I ines or
lines at higher risk of breakage.
Safety and Security
lmprovements S28 S28 S28 Arcflash analysis and improvements, eyewash stations, fall protection at facility sites
Production Rol l-Up Work S 113 S rqr S rar
Pump replacements, HVAC, production meter replacements, pumpi ng faci lity
u pgrades, I andscapi ng, sampl i ng stations, gene rator re place ments, add wate r level
monitorinq in wells, etc
Totals 52,7N s6,708 $1sso s113s8
The improvements in this table have overheads added except for portions of improvements that would be completed if Eagle Water were
makingtheimprovements. Forexample,withrespecttoneededSCADAcontrol fortheEagleWatersystem,SUEZalreadyhasacontrol
room,servers,database,andhistoriancomputerstosupporttheadditionofSCADAattheEagleWaterfacilities. EagleWaterdoesnothavea
control room or associated amenities and would have to purchase them to implementfunctional SCADA control if Eagle Waterwere
constructingtheimprovementitself. TheEagleWaterportionofthecostsdoesnothaveanyoverheadsincluded.
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Do you believe the acquisition of Eagle Water by SUEZ is in the public
interest?
Yes. SUEZ has the available capital resources to make needed improvements to
the Eagle Water system. The Company will complete improvements that will
bring the Eagle Water system into compliance with IDEQ and IDWR
requirements. Eagle Water customers will benefit from sharing sources of supply
and storage with SUEZ customers in addition to the enhanced monitoring and
response that come from a water system having amenities such as a SCADA
system and AMI meters. At the same time, SUEZ customers will avoid
substantial capital costs and still obtain the sources of supply that are needed.
Does this conclude your testimony?
Yes.
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