20200922Reply Comments.pdf

Michael C. Creamer (ISB No. 4030)
PrestonN. Carter [ISB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
mcc@ givenspursle)r. com
pnc@ sivenspursley.com
Attorneys for SUEZ Wqter ldaho Inc.
BEFORE THE IDAHO PTJBLIC UTILITIES COM1VIISSION
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IN THE MATTER OF THE PETITION OF
SUEZ WATER IDAHO, INC. FOR
AUTHORZATION TO ELIMINATE
COLLECTION OF GROSS-UP PAYMENTS
ASSOCIATED WITH CONTRIBUTIONS IN
AID OF CONSTRUCTION
Case No. SUZ-W-20-01
SUEZ WATER IDAHO INC.'S
REPLY COMMENTS
SUEZ Water Idaho Inc. ("SUEZ") submits these comments in response to the comments
filed in this case by Idaho Public Utility Commission Staff ("StaffComments"), the City of
Boise ("City Comments"), and members of the public.
SUEZ appreciates Staff s thorough review of the facts and data that underlie the Petition
in this case. As Staffnotes, and as confirmed by the numerous public comments, the income tax
obligation associated with CIAC has become a barrier to growth on the Company's system. The
reventefrom the new growth that will flow from no longer grossing up these taxes oois more than
suflicient to cover the incremental operating cost of serving those customers and also the revenue
requirement of the CIAC tax gross-up amount." Id. at 4. This avoids adverse impacts to existing
customers, and will indeed confer a benefit by broadening the number of customers over which
future costs will be spread. Id. at3-4. SUEZ looks forward to working with Staffto implement
the changes proposed in the Petition.
SUEZ WarBn Ioeuo INC.'s REpLy CoMMENTS - I
The City does not oppose the Petition or propose modifications to SUEZ's proposal. The
City does pose questions about how SUEZ will raise and account for the "income tax collection
solely from new customers within the new development," City Comments at2-3, and states that
it is not clear what outreach SUEZ conducted to its general customers, id. at 4.
The Staff Comments explain how SUEZ will raise and account for the CIAC income-tax
obligation: the additional revenue generated from new customers will cover the tax through
SUEZ's approved rates, and the income tax effect will be recorded in the ADIT account and will
be amortized over 25 years. Staff Comments at 3-4. Regarding outeach to ratepayers, SUEZ
processed this application in full compliance with the Commission's procedural rules and order
on modified procedure.
Several members of the public filed comments in support of the application. These
comments provide additional factual support for adopting the Company's proposal in this
proceeding.
In light of the Petition, the supporting information, and the comments received in the
case, SUEZ respectfully requests that the Commission issue an order granting the relief sought in
the Petition.
Respectfully submitted this 22nd day of September, 2020.
SUEZ Water Idaho Inc.
By:
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Michael C. Creamer
Preston N. Carter
Givens Pursley LLP
Attorneys for Petitioner
SUEZ Werrn loeso INC.'s REPLY CoMMBNTS - 2
I HEREBY CERTIFY that on this 22nd day of September, Z)2},theforegoing was filed,served, and copied as shown below.
DOCT]MENT FILED:
Ioeno Pusrrc UuLlrrns CouurssroN
Jan Noriyuki
Commission Secretary
PO Box 83720
Boise, ID 83720
j an.noriyuki@puc. idaho. gov
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U. S. Mail
Hand Delivered
Overnight Mail
Fax
E-mail
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Preston N. Carter
SUEZ WarBn IDAHo INC.'s REpry CourvrBu-rs - 3