20200930Application.pdf

Michael C. Creamer (lSB No. 4030)
Preston N. Carter (lSB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise, lD 83702
Telephone: [phone]
Facsimile: (208) 388-1 300
mcc@qivenspu rslev.com
prestonca [e-mail]
,= 'I ,:" T ltJ{. n, i.i is;- l Y 5- L,
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Aftorneys for SUEZ Water ldaho lnc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICAT]ON
OF SUEZ WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE
IN THE STATE OF IDAHO
Case No. SUZ-W-20-02
APPLICATION
SUEZ Water ldaho lnc., ("SUEZWater," "Applicant," or oCompany") files this
Application with the ldaho Public Utilities Commission ("Commission") requesting an
Order approving revisions to Applicant's schedules of rates and charges for water
service in the State of ldaho to become effective on or after October 31, 2020.
t.
Applicant is a public utility water corporation within the meaning of the ldaho
Public Utility Law, is duly organized and existing under the laws of the State of ldaho
and is engaged in conducting a generalwater business in and about Boise City, Ada
County, ldaho, having its principal office and place of business at 8248 West Victory
Road, Boise, ldaho. A certified copy of Applicant's Articles of Incorporation, together
with all amendments to date, is on file with the Commission, along with Applicant's most
recent annual report. Applicant's current Certificate is Amended Certificate No. 143.
SUEZ WATER'S APPLICATION
It.
SUEZ Water has been providing water service to the public in Boise City and
sunounding areas for more than 100 years. Currently, SUEZ Water provides service to
approximately 98,000 customers within Ada County, Idaho.
1il.
SUEZ Water's operations, and rates and charges for service have been reviewed
in several rate proceedings before the Commission, most recently, five years ago in
Case No. UWI-W-15-01.
lv.
Attached hereto as Aftachment 1 are copies of Applicant's Schedule Number 1,
General Metered Service; Schedule Number 1B, Flat Rate Service; Schedule Number
2, Public Hydrants and Street Sprinkling; Schedule Number 3, Private Fire Sprinkling
and Service; and Schedule Number 4, Private Fire Hydrant Service, containing the rates
under which water service is currently rendered and charged to Applicant's customers.
V.
Attached hereto as Attachment 2 are copies of Applicant's new proposed
Schedule Numbers 1, 18, 2,3 and 4 setting forth charges to be made to Applicant's
customers rates on and after October 31,2020.
vt.
Applicant proposes to increase rates by $10,160,211. This represents an overall
average increase of 22.3o/o over SUEZ's rates as approved by the Commission in 2015.
SUEZ Water submits that the proposed changes in rates and charges set forth
on Aftachment 2 are just and reasonable. The expected rate of retum under the revised
SUEZ WATER'S APPLICATION 2
rates and charges will be 7.460/o, which is a fair rate of return on SUEZ Water's
investment in property used and useful in rendering water service.
vt1.
The revenue realized by Applicant under its presently authorized rates produces
a rate of return of 4.09o/o based on a test year ending June 30,2020. Applicant seeks
additional revenues to recover increased operating expenses and costs associated with
plant additions, and to produce afair rate of return, thereby enabling it to continue to
provide adequate and reliable service to its customers.
vlil.
As discussed in the testimony of Marshall Thompson, Applicant is proposing a
revision to its Rules and Regulations Governing the Rendering of Water Service to
eliminate the Company's gross-up payments from developers to offset the Company's
income tax liability associated with Contributions in Aid of Construction. This revision
has been proposed under Docket No. SUZ-W-2O-O1 that is cunently under review with
the Commission.
tx.
Applicant is filing concurrently herewith Direct Testimony of Marshall Thompson,
Harold Walker lll, Timothy Michaelson, Jarmila Cary, David Njuguna, Catherine Cooper,
Matthew Kahn, James Cagle, Dane Watson, Mohammed Zerhouni and Gary Prettyman,
and Exhibits 1-15. Exhibits 1-15 include financial statements, revenue analysis, analysis
of cost of service, and supporting work papers that justify and support the proposed
increase.
3SUEZ WATER'S APPLICATION
X.
Applicant proposes to implement the requested increase in revenue by a uniform
percentage increase to all rate elements.
xl.
Notice to SUEZ Water's customers is being accomplished by news media
releases simultaneously with the filing of this Application and by an individual notice
mailed to each customer. Copies of the press release and customer notice are
attached to this Application as Attachment 3. ln addition, a copy of the Application and
Applicant's present and proposed rate schedules are available for public inspection at
its office a|8248 West Victory Road, Boise, ldaho at any time during office hours. The
Application will be available on the Commission's homepage at www.puc.idaho.qov.
Customers may also subscribe to the Commission's RSS feed to receive periodic
updates.
XII.
Applicant stands ready for an immediate hearing on this Application and requests
that a hearing be held as soon as possible.
xilt.
Communications in reference to this Application should be addressed to:
Michael C. Creamer (lSB No. a030)
Preston N. Carter (lSB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise, lD 83702
Telephone: [phone]
Facsimile: (208) 388-1 300
m cc@qivenspu rslev. com
prestonca rter@qivenspurslev. com
4SUEZ WATER'S APPLICATION
and
1
Michael C. Creamer
Preston N. Carter
Attorneys for Applicant
2
David Njuguna
Manager- Regulatory Business
Suez Water Management and Services
Company
461 From Road, Suite 400
Paramus, NJ 07052
david. [e-mail]
SUEZ Water respectfully requests that the Commission:
That this Application be heard and acted upon at the earliest possible date,
That the Commission find that the Applicant's existing rates are unjust,
unreasonable and insufficient to provide Applicant with a fair rate of return
and that the revised rates and charges proposed in Attachment 2 of this
Application are just and reasonable and that Applicant be permitted to charge
said rates to its customers, effective October 31 ,2020,
That the Commission grant such other and further relief as the Commission
may determine proper in the circumstances.
DATED this 30th day of September 2020.
SUEZ WATER IDAHO INC
9 ----::----
3
By:
5SUEZ WATER'S APPLICATION
ATTACHMENT 1
Application
Attachment 1
Page I of6
Sheet No. 3
Replacing all Previous Sheets
SUAI WATER IDAHO INC.
SCHEDULE NO. 1
GENERAL TETERED SERVICE
Ayailabilitv: To all metered customers not served under a separate schedule.
Customer Charges:
Meter Size
5/8',-3/4
1u
1-114' and 1-112"
2" or multiple me*ers of equivalent capacity
3" or multiple meters of equivalent capacity
4" or multiple meters of equivalent capacity
6" or multiple meters of equivalent capaci$
8" or multiple meters of equivalent capacity
10" or multiple meters of equivalent capacity
Bi-Monthly
Per Meter
Charqe
$21.11
$26.99
$46.17
$71.64
$139.73
$260.68
$435.22
$569.37
$811.39
Volume Charue: Winter Rates
For allwater used less than 3CCF (1@ cubic Feet) (CCFXI CCF=748 gallons): $1.4674
For allwater used greaterthan 3CCF $1.4674
Volume Charoe: Summer Rates
For all water used less than 3GCF (100 cubic Fee$ (CGFXI CCF=748 gallons): $1.4674
For allwater used greaterthan 3CCF $1.8577
Conditions of Contract:
The customer shall pay the total of the customer charge plus the volume charge. The
volume charge is based on all metered water for the billing period. Consumption is
expressed in hundred cubic foot units or thousand gallon units as determined by the meter
installed by the Company. The customer charge will be prorated whenever the customer
has not been a customer for the entire billing period.
Summer Period:
The summer rate will apply to water consumd between May 1 and September 30. Meter
readings straddling these dates willbe prorated.
lssued Per IPUC Order No.
Effective - June 1,2018
lssued by SUEZ WATER IDAHO lNC.
G-bory P. Wyatt, Vice President
8248 West Mctory Road, Boise, lD
Application
Attachment 1
Page 2 of 6
SCHEDULE NO. {B
FLAT RATE SERVICE
Availabilitv:
To non-metered residential customers pursuant to Residential or Multi-Family
Housing Non-Contiguous Water Systems Agreement Paragraph 11(a) addressing
flat rate systems.
Customer Charqeq:
Based on Suez Water ldaho residential consumption for the year ending June
1998 of 208.75 ccf, the avemge reidentialbill, assumingas4" meter and 65% /
35olo sumffierArinter split, is $486.42. Billed bi-monthly, equals $81.07.
Bi-illonthlv Chame: $81.07
Cond itions of Contract:
The monthly charge will be prorated whenever the customer has not been a
customer br the entire billing period. The Company or the customer may convert
to metered service pursuant to Subparagraphs (b) or (c) of Paragraph 11 as
follows:
(b) lf Company should determine that a flat rate customer is using water in
excess of the average residential customer, the Company will provide a
meter setting and meter. Customerwillthen pay Company's metered tariff
rates as approved by the IPUC, ufrich rates may be amended from time to
time.
(c) lf a customer prefers to pay Company's approved metered tiariff rates, the
customer shall pay the installation and material costs associated with the
installation of a meter setting.
Sheet No. 5
Replacing all Previous Sheets
SUEZ WATER IDAHO INC.
lssued Per IPUC Order No.
Effective - June 1, 2018
lssued by SUEZ WATER IDAHO lNC.
Gregory P. Wyatt, Moe President
Application
Attachment 1
Page 3 of 6
Sheet No.6
Replacing all Previous Sheets
SUEZ TDAHO ll{C.
SCHEDULE NO.2
PUBLIC }IYDRANTS AND STREET SPRII{KLING
Availabilitv:
To the Ada County Highway District.
Rates:
Street Sorinklino Service
Flat Charge $282.00 /Month
Miscellaneous:
Bills will be rendered monthly, bi-monthly, or at other intervals upon mutual
agreement of the Company and the customer.
Hydrants and service pipes from the fitting on the Company main to the hydrants
are to be installed and maintained by and at the expense of the Ada County
H(7hway District.
lssued Per IPUC Order No. 34153
Effective - June 1, 2018
lssued by SUEZ WATER IDAHO INC
Gregory P. Wyatt, Moe Presideni
8248 West Mctory Road, Boise, ldaho
Application
Attachment 1
Page 4 of 6
Sheet No.7
Replacing all Previous Sheets
SUEZ WATER IDAHO INC.
SCHEDULE NO.3
PRIVATE FIRE SPRINKLER AND SERVICE
Availabilitv:
To all customers who have sprinkler systems and/or inside hose connections
supplied by a dedicated service line for fire fighting purposes.
Rate:
For service through a separate line for fire fighting purposes.
For 3 service or smaller, per month
For 4' seMce per month
For 6' service per month
For 8" service per month
For 10" service per month
For 12" service per month
$18.61
$28.21
$70.06
$115.13
$179.54
$268.93
Miscellaneous:
Provided that if the installation of a private fire service shall require an extension of the
existing mains of the company, the cost of such extension shall be borne by the
customer.
All private fire services shall be equipped with sealed gate valves or thermal automatic
openings.
Meters may be placed on fire services by the utility at any time; however, metered
rates will not apply unless improper use of water is disclosed, and if such be the case,
usage will be billed to the consumer under Rate Schedule No. 1.
lssued Per IPUC Order No.
Effective - June 1,2018
lssued by SUEZ WATER IDAHO lNC.
Gregory P. Wyatt, Vice President
8248 West Victory Road, Boise, ldaho
Application
Attachment 1
Page 5 of 6
Sheet No. I
Replacing all Previous Sheets
SUEZ WATER IDAHO INC,
SCHEDULE NO.4
PRIVATE FIRE HYDRANT SERVICE
Availability:
To all customers having private fire hydrant installations.
Rate:
For fire hydrants installed and maintained by the customer at customer's expense:
Each fire hydrant, per month $11.29/Month
Miscellaneous:
Service pipe from the fitting on the company water main to the fire hydrant is to be
installed and maintained by the customer.
lssued Per IPUC Order No.
Effective - June 1,2418
lssued by SUEZ WATER IDAHO INC
Gregory P. Wyatt, Mce Presideni
8248 West Victory Road, Boise, ldaho
Application
Attachment 1
Page 6 of 6
ATTACHMENT 2
Application
Attachment 2
Page I of6
Sheet No. 3
Replacing all Previous Sheets
SUEZ WATER IDAHO INC.
SCHEDULE NO. 1
GENERAL TETERED SERVICE
Availabilitv: To all metered customerc not served under a separate schedule
Customer Charges:
Meter Size
518 -314
l',
1-114" and 1-112"
2" or multiple meters of equivalent capacity
3" or multiple metens of equivalent capacity
4" or multiple meters of equivalent capaci$
6" or multiple meterc of equivalent capacity
8" or multiple meters of equivalent capacity
10" or multiple meters of equivalent capacity
Volume Charqe:
For allwater used less than 3CCF (100 cubic Feet) (CCFX1 CCF=748
gallons):
Bi-Monthly
Per Meter Gharse
$24=4+ 25 81
$2€sg33.00
$4€+{+ 56 45
$7+-e+ 87.60
$l€eJsJZg s5
$a60,6s 319_zl
$435,e3532.15
$56s37 696.34
$8++3s 992.33
Wnter Rates
$+.4$tu+ 1 7942
$+4644 1.7942
Summer Rates
$4.4874 1.794?
$14,644" 2 2714
I for allwater used greaterthan 3CCF
Volume Charge:
For all water used less than 3CCF (100 cubic Feet) (CCF)(1 CCF=748
gallons):
I for all water used greater than 3CCF
Conditions of Contract:
The customer shall pay the total of the customer charge plus the volume charge. The
volume charge is based on all rnetered water for the billing period. Consumption is
expressed in hundred cubic foot units or thousand gallon units as determined by the meter
installed by the Company. The customer charge will be prorated whenever the customer
has not been a customer for the entire billing period.
Summer Period:
The summer rate will apply to water consumed between May I and September 30. Meter
readings straddling these dates will be prorated.
lssued Per IPUC Order No.Effective@,2020
lssued by SUEZ WATER IDAHO lNC.
Marshall Thompson, Vice President
8248 West Mctory Road, Boise,rldahno
Aftachment 2
Page 2 of 6
SCHEDULE NO. TB
FLAT RATE SERVICE
Availability:
To non-metered residential customerc pursuant to Residential or Multi'Family
Housing Non-Contiguous Water Systems Agreement Paragraph 11(a) addressing
flat rate systems.
Customer Charges:
Based on Suez Water ldaho rcsidential consumption for the year ending June
1998 of 208.75 ccf, the avererye residential bill, assuming aYt" meter and 65% /
35% summerArinter split, is $48MAI94J-4. Bitled bi-monthly, equals $81-97
99.03,
Bi-Monthlv Charge: $84$7 99.03
Conditions of Contract:
The monthly charge will be prorated whenever the customer has not been a
customer for the entire billing period. The Gompany or the customer may convert
to metered service purcuant to Subparagraphs (b) or (c) of Paragraph 11 as
follows:
(b) lf Company should determine that a flat rate customer is using water in
excess of the average residential customer, the Company will provide a
meter setting and meter. Customerwillthen pay Company's metered tariff
rates as approved by the IPUC, which rates may be amended from time to
time.
(c) lf a customer prefers to pay Company's approved metered tariff rates, the
customer shall pay the installation and material costs associated with the
installation of a meter setting.
Sheet No.5
Replacing all Previous Sheets
SUEZ WATER tNc_
lssued Per IPUC Order No.
Effective -*nt*aqfi€ Octobel 3 1, 2020
lssued by SUEZ WATER IDAHO lNC.
Marshall Thompson, Mce President
8248 WestVictory Road, Boise, ldaho
Application
Attachment 2
Page 3 of 6
Sheet No.6
Replacing all Previous Sheets
SUEZ WATER IDAHO INC.
SCHEDULE NO. 2
PUBLIC HYDRANTS AND STREET SPRINKLING
Availability:
To the Ada Gounty Highway District.
Rates:
Street Sorinklino Service
Flat Gharge $28230 344 iQ /lvlonth
Miscellaneous:
Bills will be rendered monthly, bi-monthly, or at other intervals upon mutual
agreement of the Company and the customer.
Hydrants and service pipes ftom the fifting on the Company main to the hydrants
are to be installed and maintrained by and at the expense of the Ada County
Highway District.
lssued Per IPUC Order No.Effective@,2020
lssued by SUEZ WATER IDAHO lNC.
Marshall Thompson, Vice President
8248 West Victory Road, to,T#,f,A,lp
Attachment 2
Page 4 of 6
Sheet No. 7
Replacing all Previous Sheets
SUEZ WATER INC.
SCHEDULE NO. 3
PRIVATE FIRE SPRINKLER AND SERVICE
Availabilitv:
Rate:
To all customers who have sprinkler systems and/or inside hose connections
supplied by a dedicated service line for ftre fighting puposes.
For service through a separate line for fire fighting purposes.
For 3'service or smaller, per month
For 4" service per month
For 6' servioe per month
For 8" service per month
For 10'service per month
For 12" seMe per month
$+gg 22 75
$28=Z+_344
$7s€6*98.66
$4-1#:l 140.77
$1+$54 219.53
$26833 328.82
Miscellaneous:
Provided that if the installation of a private fire service shall require an extension of the
existing mains of the company, the cost of such extension shall be bome by the
customer.
All private fire services shall be equipped with sealed gate valves or thermal automatic
openings.
Meters may be placed on fire services by the utility at any time; however, metered
rates will not apply unless improper use of water is disclosed, and if such be the casc!,
usage will be billed to the @nsumer under Rate Schedule No. 1.
lssued Per IPUC Order No.Effective@,2020
lssued by SUEZ WATER IDAHO lNC.
Marstrill Thompson, Vice President
8248 West Victory Road, Boise, ldaho
Application
Aftachment 2
Page 5 of 6
Sheet No.8
Replacing all Previous Sheets
SUEZ WATER tNc.
SCHEDULE NO.4
PRIVATE FIRE HYDRANT SERVICE
Availabilitv:
To all customers having private fire hydrant installations.
Rate:
For fire hydrants installed and maintained by the customer at custome/s expense:
Each fire hydrant, per month $1-4.29 13.80/Ivlonth
Miscellaneous:
Service pipe from the fitting on the oompany water main to the fire hydrant is to be
installed and maintained by the customer.
lssued Per IPUC Order No.
Effective -Jaffiasy40 October 31 ,2O2O
lssued by SUEZ WATER IDAHO INC
Marsfrilt Thompson, Vice Presideni
8248 West Victory Road, Boise, ldaho
Application
Attachment 2
Page 6 of6