20200930Cooper Direct.pdf

iti: t; I tVEfr
Michae! C. Creamer (lSB No. 4030)
Preston N. Carter (!SB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise, lO 83702
Telephone: [phone]
Facsimile: (208) 388-1 300
[e-mail]
[e-mail]
:itr s{: 3il Pffi !: $g
Attorneys for SUEZ Water ldaho lnc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF SUEZ WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE
!N THE STATE OF IDAHO
Case No. SUZ-W-20-02
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
DIRECT TESTIMONY OF CATHERINE COOPER
SEPTEMBER 2O2O
1Q.PIease state your name and business address.
My name is Cathy Cooper, P.E. My business address is 8248 West Victory
Road, Boise, ldaho 83709.
By whom are you employed, and in what capacity?
I am the Director of Engineering for SUEZ Water ldaho lnc. ("SUEZ" ot
"Company").
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 Civi!
Engineering at the University of Washington in Seattle. I have been a
licensed Professional Engineer in the State of ldaho since 1999.
I have been employed as a civil engineer for 26 years. My work
experience includes 22years at Boise area consulting firms where I focused
my work on water system engineering. My experience includes preparing
detailed hydraulic calculations; designs for storage tianks, pump stations,
pressure reducing stations, pipelines, and we!! 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 ldaho.
Please describe your duties as Director of Engineering.
2A.
3
4
5
6
7
I
I
o.
A.
o.
A.
10
11
12
13
14
15
16
17
18
19
20
21
Cathy Cooper, Di
SUEZ Water ldaho lnc.
1
22 0.
2
3
4
5
6
7
8
I
1A
11 0.
12
13 A.
o,
A.
I have oversight over the Company's capital expenditure budget and short
and long-term facility and water supply planning. ln addition, I manage
selected engineering projects for the Company.
What is the purpose of your testimony?
I wil! discuss these topics:
o Pro forma adjustments to the test year (ending June 30, 2020) to
recognize investments in plant in service through March 31,2021.
. Explanation of the purchased water expense and adjustments thereto
as it relates to drought protection and weather conditions.
o Brian Subdivision Water Users Association connection.
Since the last proceeding has the Gompany continued to invest in
utility plant in service?
Yes. Gross plant from the last proceeding test year ending November 30,
2015 has increased $101.181 million. The pro forma additions (net of
retirements) for the period July 1,2020 to March 31,2021 total $25.124
million. The total plant in service investment from November 30, 2015 to
March 31,2021 is $126.305 million, an increase of 32.0% over the
Company's Plant in Service at November 30, 2015 of $394.267 million. The
Company continues to provide new and replacement utility plant in all areas
of the business including source of supply, water treatment, pumping,
transmission and distribution mains, distribution storage, customer service
lines, customer meters, information technology, and general plant.
Cathy Cooper, Di
SUEZ Water ldaho lnc.
10
14
15
16
17
18
19
20
21
22
2
2
3
4
5
6
7
8
I
10
1Q.
A.
o
A.
11
12
13
14
15
16 0.
17
18 A.
19
21
Are these plant in service additions used and useful in providing
seruice to the Company's customers?
Yes they are. Additionally, the projects included in pro forma Rate Base
from July 1, 2020 through March 31,2021 will also be in service.
Can you now discuss, in general terms, the capital additions planned
to be placed in service from July 1,2020 through March 31,2021?
Yes. The capital additions include meters and services, pumping
equipment, new and replacement mains, treatment equipment, control
equipment, facility improvements, an engineering master facility plan,
information technology systems, and security upgrades. The pro forma
plant additions for this time period are detailed in two locations with
associated exhibits. Plant in service additions for the period of July 1 ,2020
to March 31,2021 are summarized by account number in Exhibit 11,
Schedule 3 sponsored byWitness Cary, and are also listed by project name
on the attached Exhibit No. 3.
Does Exhibit 3 also show retirements, cost of removal and salvage for
the pro forma period?
Yes. The retirements include service lines, meters, pumping equipment,
new and replacement mains, treatment equipment, control equipment,
information technology equipment, and facility improvements. The cost of
removal is included for additions that involve removing an existing asset. ln
some cases there is no existing asset to remove with the plant addition.
Cathy Cooper, Di
SUEZ Water Idaho lnc
20
3
22
1
2
30.
4
5A.
6
70.
8
9A.
10 0.
11
12 A.
13
14
15
16
17
18
19
20
21
22
23
Salvage value is included for assets that are anticipated to have an actual
salvage value.
Will these plant additions be in service by the end of the pro forma
period?
Yes. These plant additions are undenray and/or planned for completion by
the end of the pro forma period, March 31 ,2021.
Will the plant additions shown on Exhibit No. 3 be used and useful in
providing service to the Gompany's customers?
Yes they will.
Please discuss the basis for SUEZ Water ldaho's purchased water
expense in the pro forma amount of $217,314 as shown on Exhibit 4.
The annual cost of surface water is dependent on multiple factors including
snowpack, drought conditions, and summer high temperatures. Annual
purchased water costs have ranged from $146,682 to $198,234firom 2015
to 2020. SUEZ's surface water portfolio is diverse, balanced across natural
flow water rights, storage contracts, exchanges, irrigation district shares
both owned and leased, Iong term rental pool lease agreements, and short
term rental pool lease agreements. Short term (one season) rental poo!
lease agreements are used to make up any shortfalls in surface water
supply for the year when necessary, which has been required for two years
in the period lrom 2015 to 2020.
SUEZ anticipates the available water market in the Valley will tighten
as growth continues over the coming decades. ln addition, drought and
Cathy Cooper, Di
SUEZ Water ldaho lnc.
4
1
2
3
4
5
6
7
8
90.
10
11 A.
12
13
14 A.
15
16
17 A.
18
19
20
21
22
23 A.
flood conditions may be exacerbated as an effect of climate change. With
this in mind, SUEZ is working towards more permanent surface water
arrangements to solidify surface water availability over the long-term for our
customers. Natural flow rights, where available, are favored over storage
rights that may be more susceptible to drought conditions. Purchases are
preferred over leases. This move towards more permanent surface water
use arrangements is reflected in the cunent slightly increased purchased
water costs over previous years.
Are the lease/contract costs generally known and measureable related
to purchased water expense?
Yes the costs are generally known and measurable. These agreements
have been executed or are in planning/progress, and are shown on Exhibit
No.4.
Can you clarify why purchased water expense proposed in the pro
forma period exceeds the test year expense by approximately
$19,080?
The test year purchased water expense is $198,234. The purchased water
expense in the pro forma period is $217,314. There were some minor
adjustments to the proportions of leased rental poolwater that shifted costs
slightly. The majority of the difference, though, is due to a shift from 400
leased to 400 owned shares in Boise City CanalCompany, increasing costs
by $19,600.
Can you explain in detail the breakdown of this additional expense?
Cathy Cooper, Di
SUEZ Water ldaho lnc.
5
1
2
3
4
5
6
7
8
I
10
11
12
13
14
15
16
17
18
19
20
21
22
23
A. Yes. SUEZ is finalizing an agreement with Boise City Cana! Company to
purchase 400 shares. These shares have been previously leased by SUEZ
for 10 year terms. The purchase will ensure the long-term ability by SUEZ
to deliverthese high priority naturalflow rights to customers. This purchase
is part of SUEZ's efforts to shift to more permanent sources of surface
water.
O. Do you believe $217,314, as depicted on Exhibit No. 4 is a reasonable
allowance for purchased water expense for rate making purposes?
A. Yes.
O. Can you summarize the Company's decision to expand the certificated
area and install infrastructure to be able to serve the Brian
Subdivision?
A. Yes. ln accordance with the findings in IPUC Cases UWI-W-14-01 and
SUZ-W-18-01 the Company made the connection to Brian Subdivision, and
split the costs between Brian Subdivision residents and SUEZ ratepayers
in the manner ordered by the Commission. The Final Order in the case
finds that AFUDC is appropriately accrued on the SUEZ portion of
construction costs until included in rates at the conclusion of the next
general rate case. Order No. 34153 at 5. These Brian Subdivision costs
totaling $2,130,200 have been included in this rate case and wil! be put into
service in March 2021 (plant account 331400).
O. Does this conclude your testimony?
A. Yes.
Cathy Cooper, Di
SUEZ Water ldaho lnc.
6
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
[e-mail]
Aftorneys for SUEZ Water ldaho lnc.
IN THE MATTER OF THE APPLICATION
OF SUEZ WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE
IN THE STATE OF IDAHO
BEFORE THE IDAHO PUBLIC UT!LITIES COMMISSION
Case No. SUZ-W-20-02
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
EXHIBITS 3 & 4 TO ACCOMPANY THE
DIRECT TESTIMONY OF CATHERINE COOPER
Project II)Project Title
In Service
Date
Forecast
Additions
Forecast
Retirements
Forecast
Cost of
Removal
Forecast
Salvage
Source of Supply
c't7A101 IMAP Met-21 $ 149,500 $$$
c18A100 IMAP MaF21 $ 141,400 $$$
c't8A't00 Purchase Boise City Canal Shares Feb-21 $ 21,500 $$$
c20A101 Water Rights Various $ 51.500 $$$
Subtotals $ 363.900 $$$
Treatment
c208500 ReDlace Treatment Equipment Various $ 1'11,900 $ 4 l,600 $ 800 $
c208503 Replace Valves, Meters, & Actuators at WTP's Oct-20 $ 31.000 $ 1 1.s00 $ 't.000 $
c20B504 Replace CWTP peristaltic pumps Auo-20 $ 51.500 $ 1 1.500 $ 500 $
c208505 Chlorination Equipment Dec-20 $ 137,400 $ 46,500 $ 3,000 $
c20B506 MWTP General Rehab Feb-21 $ 114,500 $$$
c208509 Reolace on-site chlorine qenerators Mat-21 $ 469.400 $ 233,200 $ 5,000 $
c218512 Rehab MWTP Collectors MaF21 s 1.525.400 $$$
Subtotals s 2.441.100 s 344.300 3 10.300 $
Pumpinq PIant
c't9c100 Sunset Wesl VFD Jan-2'l $ '122,400 $ 42,000 $ 500 $
c20c100 Pump Equip-Sources of Supply Various $ 915.900 $ 228,700 $ 1 1,000 $
c20c200 Replace Booster Pump Equipment Various $ 103.900 $ 36.500 $ 800 $
c20c503 Replace Control Equipment Dec-20 $ 94,200 $ 42.200 $ 1,000 $
c20c522 System PRV re-builds Dec20 $ 57,200 $ 25,700 $ 500 $
c20c524 Sunset West Well - Motor and Electrical Upsizinq Jan-21 $ 458,000 $ 40,000 $ 3,000 $
c20c525 Facilitv Goolino Auo-20 $ 63.000 $ 20,600 $ 500 $
c20c526 Reconstruct Pumping Facilities Various s 63.400 $$$
c20c527 Landscaping Replacement - System Facilities Nov-20 $ 85,900 $$$
c20c528 Floatinq Feather Rehab Feb-.21 $ 171,700 $ 17,900 $ 500 $
c20c529 Relocate Arctic/Fairview Booster Sep-20 $ 653,500 $ 84,700 $ 25,000 $
Subtotals $ 2.789.100 $ 538.300 $ 42,800 $
T & D Mains
c1sD101 90% Pipeline Costs - Brian W Special Case $ 2,130,200 $$$
c19D708 St Lukes Roadway Phase 2 Jul-20 $ 212,700 $$$
c20D300 Developer Extensions Various $ 4.3'10.000 $$$
c20D501 SpuMing Water Main Phase 2 Oct-20 $ 2.846.200 $ 177,800 $ 28,000 $
c20D631 East First Bench Main Replacements Auo-20 $ 494.900 $ 2,000 $ s00 $
c20D632 Warm Springs Mesa lmprovements Dec-20 $ 1,658,700 $ 54.100 $ 16.300 $
c20D633 Second Round - East First Bench Main Repl Feb-21 $ 670,900 $ 21,700 $ 6.500 $
c20D700 Aoencv Related Replacement Mains Various $ 1,887,900 $ 213,100 $ 31,900 $
c21D601 Lower Andy's PRV Ma"-2'l $ s7,200 $ 2,500 $ 200 $
CYYDOO,I Fire Hydrants Various $ 561,200 $$$
CYYDOO2 New Short Mains & Valves Various $ 224.000 $$$
CYYDsO2 Replacement Short Mains & Valves Various $ 204.100 $ 1.200 $ 200 $
Subtotals $ 15,2s8,000 $ 172.100 3 83.600 $
Services
cl 5F005 New lsolated Services Jul-20 $ 1 10,800 $$$
CYYFOO3 New Fire Services Various $ 250.300 $$$
CYYFsO5 Domestic Services Various $ 1,967,800 $ 316.800 $ 26.200 $ 6,700
Subtotals $ 2,328,900 s 316.800 $ 26.200 3 6.700
SIIEZ Water Idaho
Pro Forma Period Plant Additions and Retirements
July 1, 2020 to March 31,2021
Case No. SUZ-W-20-02
Exhibit No. 3
C.CooPer
Page 1 of2
Project ID Project Title
In Service
Date
Forecast
Additions
Forecest
Retirements
Forecast
Cost of
Removal
Forecast
Salvage
Meterc
CYYGsOl Customer Meters Various s 691.200 $ 300.000 $ 10.300 $ 9.100
Subtotals $ 691,200 $ 300,000 I 10,300 $ 9,100
lnformation Technoloov (lT|
c20J109 Power Monitoring Oct-20 $ 45.800 $$$
c20J1 t0 Cityr,\rorks to CCB lnterface Auo-20 $ 40.100 $$$
c20J502 Replace l&C Equipment Dec-20 $ 'r 37,400 $ 61.500 s 1.000 $
c20J507 lT Equipment Oct-20 $ 25,200 $ 1 1,200 $ s00 $
c20J508 SCADA Svstem lmolementation Jan-21 $ 599,700 $ 2s6,700 $ 6,000 $
c20J509 Reolace eoos Jen-21 $ 96.200 $$$
c20J51 1 Bali Hai and Maple Hills PLC Replacement Fe621 $ 178.500 $ 77.200 $ 1,500 $
c20J550 Allisator Radios Dec20 $ 74.400 $ 33.200 $ 1.000 $
Subtota13 $ 1,197,300 $ 439,800 s 10.000 $
General Plant
c20K004 Hvdraulic Model UDdates Nov-20 $ 80,100 $$$
c20K101 Well Master Plan Jul-20 $ 114.500 $$$
c20K102 Safety/Security Upgrades Nov-20 $ 114,500 $$$
c20K1 03 Surface Water Riqhts Analysis Jen-2'l $ 85,900 $$$
c20K501 New and Replacement Tools Various $ 108,800 $$$
c20K502 Victory Office Remodel / Warehouse Expansion Dec-20 $ 1.304.300 $$$
c20K503 Master Facilitv Plan Uodate Jan-21 $ 458.000 $$$
c20K504 Marden Plant Exoansion Studv SeD-20 $ 114.500 $$$
c2'.tK't02 Columbia Area Analysis Study Mar-21 $E5.900 $$$
Subtotals $ 2,466,500 3 $$
$ 27.536.000 s 2.411.600 $ 183,200 $ 15,800
($5.018.600)
$22.517.400
$47,800
SUEZ Water Idaho
Pro Forma Period Plant Additions and Retirements
July l, 2020 to March 31,2021
Gross Plant Adds, Retirements, COR & Salvage
ctAc
Gross Plant Less CIAC
Developer Refunds
Case No. SUZ-W-20-02
Exhibit No. 3
C.Cooper
Page 2 ol 2
dg o oqr1,q.i3E;.8,8fi"3o
cizo
o
o{
F
N5
!t
..lt
xUI
o(!
=tto6r!ct
o
I0
t!B
o(!
=N
UJ3o
Fzu
=Eoo
oEE:rdccca(o
dsE;
E#60
=c!o6$oeEoiEft
=EF6.E9OE6Ec'=oo.EE
94Eb
ocalAZ'.n
aL6
Eo?$Ex<E.6(L!t6}Bc@
-e90
gE
(EL
Pg_E;K,rES!?EiE IEclJ6
s, EI6 =SEr{
E€}E9(oE E!Ooa
EHfr9 At
GGo(o
NI!,o@
xE
(!Nx6oc<0
oortxooatsrf
o
ci+fo
6)
oood)
Eo
(LI
CoE
G
=o
o,=
oo
d_
oo6o
I!o6
xE
oNx
oqo
ooNx
E(trsooo@
dtt
Eo
.5
oooo
Ee
ILltroEo
=o
0,,g
o.s(L
6I
o-
5ctuE(E
=6o;9Etr>6EcOo!
6A.-:
58
E€EPoo-oeaiH
o
t
otco
o!,c
.EgoI
dE
E.Ero
OECE
-o9B
3Efio6c-o
PEio8E
EE_
>o<5
(o$oN
o
N
oEcuJ
o
Ecoo
co
E
GCLot
o$
s
CD
=ot,
o
soI
iri6d.T'oxiI
aaoooo
6!of
od
(!o
=odoooo
E
aoto.ri
occ)E=E
Eoo
ooo
=!(5
1'E(EJo(!
CL
>oEoc- u;'=b
o9.rDO'cs9g
!6oo*co
EboEEo:Eoo>,E
cGo
Eooto=oco
oo
E
o
6
oo'6o
Eo
o
g
'6
=oo
oo&otr
o.oa
oq
0)EoofooEo!
*E
=*N <-r5oaoo€
tzl
J
LF'^Al-usU
fzz
oqo(oq
@
ccc{!e
oqoo6cir)@
oodo(ooe
b
o(o
die
ooo@o$Ne
oo+Nq(o
e
oocioq(oe
ooeoooF.e
ocooooe
ooo6o
e
afr
=tr
oorio@ l
t
IJJ(LFu=(J-
x.o_
ooo\te
oc€o)4
ocNt
@
oq
@o)e
oori(r)e
@o+Ne,
@
ri
@
oq(o6
oooNe sll
otz
=
o
@!t
6I
oot ooN
oqoo
ooo oo oo ooUd El I
+o 2 z z z
o(o(oooN(o
@@tt
o
oo)oo
o.E
ct!
dd =ll
J
z
(,
=olrjE
Io
=tsJ!
z
=tfIF
u
Ecsa
Io
5c
(.1
(,,)
(.)e
c(.i
!
z
(.)
E(.)
lJ,rq
6e,
6ooEo!to
EooNoN
ooodl
oo
J
z
o
Eo
l,tJo6ao
o(4oNuo
'6
d
(o0)
o
oo6Eo
Eo@o
-!sooN
(-)oo6
oo
Gc(so
(5(,oodl
o
o
FC)dFLozoF
Idc
lrJJJ
s
uJLoc0
ulo
doFo
uJo
UJ
-JFo
uFzoo
oooo
t
cj
trlt6
t
uJotUtroz
tzoodt!oz{
ooo
coE
6ood
to
trit6
d
tJJo
LrJdY
fio
Yo
J
ooo
oocoEoco
=
d.
cid
d6
duJouidY
uJo
Yo
J
Jooo-J
F2lrJg.
fr,(ozo
ao
6co.
aFzIdoaaz(t
tr
2z
ottu6JoE
uto
a.oorD
=o
@oFoFz
lrJ
=
o.
lr.l
zIIJoz
tlrJIFo
ooofc
Eot
o
.=
o
6i
fo
(!t
a
o
=o
oo6oo
({o
.troo?
o
oE6o