20210317English Direct.pdf

BEFORE THE ,i,;;:[i1,'F.*
jr.:t iijiii lJ PH t+; 5?
IDAHO PUBLIC UTILITIES GOMMISSION : si.,ia,l-;il
'=.. , .i..-,i i:J':,"iri .#'.b1l.hi{
IN THE MATTER OF SUEZ WATER IDAHO
INC.'S APPLICATION FOR AUTHORITY TO
INCREASE ITS RATES AND GHARGES
FOR WATER SERVICE IN IDAHO
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GASE NO. SUZ-W-20-02
DIRECT TESTIMONY OF DONN ENGLISH
IN SUPPORT OF THE STIPULATION
AND SETTLEMENT
IDAHO PUBLIC UTILITIES COMMISSION
MARCH 17,2021
O. P1ease state your name and business address?
A. My name is Donn English. My business address is
11331 W. Chinden B1vd., BLDG 8, STE 2O]--A, Boise, Idaho
837]-4.
O. By whom are you employed and in what capacity?
A. I am employed by the Idaho Public Utilities
Commj-ssion as a Program Manager overseeing t,he Accounting
and Audit Department in the Utilities Division. I am also
the program Manager overseeing the Technical Analysis
Department, also within the Util,ities Division-
O. Please describe your educational background and
professional experience .
A. My educational background and professional
experiences are shown in Exhibit No. l-01.
a. What. is the purpose of your testimony in this
proceeding?
A. The purpose of my testimony is to describe the
Application of SUEZ Water Idaho, Inc. ("SUEZ Water" or
"Company" ) to increase its rates and charges for water
service in Idaho, d.escrj-be the proposed comprehensive
Stipulation and Settlement ("Sett.Iement" ) reached by t,he
parties in this case, and explain staff's support for the
proposed Settlement..
O. How is your testimonY organized?
A. My tesLimony is subdivided under the following
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headj-ngs:
Background Page 2
Staff Investigation Page 3
Set.tlement Evaluation Page 5
Settlement Overview Page 6
Background
O. Please describe SUEZ Water's original filing.
A. SUEZ Water made its original filing with the
Idaho Pubf ic Utilities Commj-ssion on Sept.ember 30 , 2020,
requesting authority to j-ncrease its revenues by $10.16
miltion, or 22.3*, effective on or after October 31, 2020.
The requested increase was based on a test year ending ,June
30, 2020, with proforma adjustments through March 3l-, 202]-.
Rate base was j-ncluded through March 31, 202L, using the
13-month average method. The Company proposed using its
current capital sEructure of 54.072 equit.y and 45.93? debt,
and a return on common equity ("RoE") of 1,0.22. The
Company proposed a uniform increase t.o all customer
classes.
a. How was the case processed after the Company's
filing was received?
A. The Commission issued a combined Notice of
Appllcation and Notice of Intervention Deadline ("NoEice")
on OcLober 2!, 2020. The Notice suspended the proposed
effective date for thirty days and five months and
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established an Intervent,ion Deadline of November 11 , 2020.
Intervenor status was subsequently granted to Ada County,
Boise City, SUEZ Water Customer Group ("SWCG"), Community
Action Partnership Association of Idaho ("CAPAI"), Micron
Technology, Inc. ("Micron"), Intermountain Fair Housing
Council, Inc. ("IFHC"), and four individual residents of
the Boise Bench collectively referred to as the Individual
Intervenors. The parties participat.ed j-n four settlement
conferences, and on March 12, 202L, all parties either
agreed to the proposed settlement term sheet or stated
their intent to withdraw as a party from the case. On
March 16, 202L, the Individ.ual Intervenors filed a Motion
to Wit.hdraw from the proceeding, and on March 17, 2021,
IFHC expressed their intent to also file to withdraw. A
Joint Motion to Approve the Settlement was filed with the
Commission on March 17, 202l-. The Set.tlement was signed by
all remaining part j-es.
Staff Investsigation
O. What type of investigation did Staff conduct to
evaluate the Company's rate increase request?
A. Staff's approach in any general rate case is to
extensively review the Company's Applicatj-on and associated
testj-mony and workpapers, identify adjustments to its
revenue requirement, and prepare to file testimony for a
fu11y-1it.igat.ed proceeding. There were 1-4 staff members
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analyzing this case consisti-ng of auditors, engineers,
utility analysts, and consumer investigators, along with
supervisors. Staff auditors reviewed t.he Company's test
year results of operations, capital budgeLs, capital
spending trends, operations and maintenance ("O&M")
expenses and Lrends, and verified all of the Company's
calculations and assumptions with regard to the overall
revenue requirement. Because of the public health
emergency due to the COVID-1-9 virus, Staff members were not
able to conduct onsite audits or reviews of the Company's
books and records and they did not have extensive
interviews with Company personnel. However, the auditors
reviewed thousands of transactions, selected samples, and
performed transaction testing in accordance with standard
audit practices. Staff reviewed the Company's l-abor
expense, incentive p1ans, and employee benefits to ensure
the appropriate leve1 of expenditures are included in
rates.
Staff reviewed both completed and proposed
Company investments to determine the prudence of capital
additions. Expendj-t.ures j-ncluding pension expense,
salaries, and O&M expenses were also examined.
Additionally, Staff investigated the Company's cost of
capital, capital structure, cosL of service, and revenue
normalization. In totaI, Staff submitted over 155
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production requests and held several virtual meetings with
Company personnel as a part of its comprehensj-ve
J-nvestigation.
Entering int,o the settlement negotiations, Staff
had a list of potential revenue requirement adjustments to
present to the parties. Return on Equity ("ROE") is always
a major issue in general rate cases. Calculatj-ons of ROE
ranged f rom 8 .75e" t.o the Company proposed 10.2? but the
parties did not. reach a specj-fic agreement on t,he
appropriate ROE or capital sLructure. Based on the success
of its investigation, Staff and the parties were able to
negotiate a rate increase t.otaling 8.752 over two years as
opposed to the one-time 22.3* requested by the Company.
Settlement Evaluation
O. How did Staff determj-ne that the overall
Settl-ement was reasonable?
A. In every settlement evaluation, Staff and other
parties must examine the risks of losing positions at
hearing and determine if the agreement is a bet,ter overall
ouLcome. Staff must evaluate each individual adjustment.
and det.ermine t.he likelihood of t.he Commj-ssj-on accepting or
reject,ing Staff's rationale for the adjustment.
Ult.imately, Staff's intent in every settlement conference
is to negotiate the best possible outcome for customers.
O. Does Staff support the Settlement as reasonable?
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A. Yes. After a comprehensive review of the
Company's Application, thorough audit of the Company's
books and records, and ext,ensive negotiations with the
parties to the case, Staff supports the proposed
Set.tlement. The Set.t.lement. of f ers a reasonable balance
between the Company's opport.unity to earn a reasonable
return on its investment and affordable rates for
customers. The Settlement addresses several of Staff's
primary goals in this proceeding, including a revenue
requirement increase that is more palatable to customers,
adjusting amortization periods to better reflect time
periods between rate cases, and the commitment by SUEZ
Water to perform a load study to assist in allocat.ing costs
to different cusLomer classes. Staff believes the
Settlement, supported by all remaining parties to the case,
is in t.he public j-nterest; fair, just, and reasonable; and
should be approved by the Commission.
Settlement Overview
O. Would you please describe the terms of the
Settlement?
A. The proposed Settlement adopts a phase in of t,he
negot,iated revenue increase. fnstead of the Company's
proposed 22.32 increase, customers will see an increase of
3.55? on May 1, 2021-, representing a revenue increase of
$1.62 million for the Company. On May 1, 2022, rates will
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increase by another $2.38 mi11ion, or 5.22. The overall
increase for the Company, phased in over two years, is
$3.996 mil]ion, or 8.752.
The Settlement does not det.ail all of the
different. components of t.he revenue requirement
calculat,j-on. However, the Settlement specJ-ficalIy provides
a framework for the treatment of amortization expenses,
depreciation expense, pension expense, and the return of
the remaining benefits from the Tax Cuts and Jobs Act.
("TCJA") to customers. Additionally, the Settlement
outlines how the parties believe intervenor funding, if
granted by the Commission, should be recovered by the
Company.
O. Please explain how t.he Settlement t.reats
amortization expenses .
A. In its ApplJ-cation, the Company requested to
amortize t.he balance of its deferred pension costs,
deferred power costs, rate case expenses, and deferred
convenience fees over a three-year perJ-od. To mitigate the
impact of the rate increase to customers, the parties
agreed to a four-year amortization period. The Settlement
also specifies that any remaining balances associated with
deferred pension costs and power costs, either positive or
negative, will be incorporated into the amortization
expense in the Company's next general raLe case. This
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treatment ensures that customers will PaY, and the Company
wil-l recover, [o more and no less than the actual pension
contributions and power costs incurred by t,he Company.
Consistent with Order Nos. 29838 and 32443, the Company
will be authorized to accrue a carrying charge on the
balances at the Commission-authorized customer deposit
rate.
Regulatory assets associated wlth deferred tank
painting costs will be amortized over twenty years as
previously approved by the Commission and as requested in
the Company's Application. Additionally, the amortizatj-on
of the Allowance for Funds Used During ConsLruction
("AFUDC") equity will continue with the 35-year
amortization period approved in Order No. 33436 in the
Company's Last general raLe case.
O. Please describe the tax benefits associated with
the TC,JA.
A. On January 11, 20L8, the Commission opened Case
No. GNR-U-18-01 to investigate the impact of the TCJA on
utility cosLs and ratemaking. The Commission reduced t.he
raLes SVEZ Water charges customers j-n Idaho to reflect the
reduced income tax expense at the new 2l-? corporate tax
rate. However, the TC,JA required companies to revalue
their deferred tax amounts at the new corporate tax rates
(2]-*) which resulted in excess deferred federal- income tax
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reserve balances. Balances associated with regulated
utiliLy operations resulted in a balance sheet
reclassification from deferred tax to a deferred regulatory
asset or liability. This revaluation effected both planL
(priotected or permanent tax benefit) and non-pIant
(unprotected or temporary tax benefit) balances.
For plant-related excess Accumulated Deferred
Federal Income Taxes ("ADFIT"), the Company must amortj-ze
the balance under the Internal Revenue Service ("IRS")
Average Rate Assumption Method ("ARAM"). To comply with
the IRS normalizat.ion rules, the Company must return the
plant-related ADFIT to customers over the remaining life of
the associated assets. The ARAM serves as a proxy for the
composite remaining life of the assets. The associated
amortizaLion of the pIant.-related ADFIT provides customers
approximately $227,000 per year.
The temporary (one-time) tax benefit.s associated
with non-pIant ADFIT balances can be returned to customers
in any manner approved by t.he Commission. The parties in
this case agree to return the entirety of the approximately
$16 million unprotected ADFIT to customers over one year,
beginning on May 1, 2021. After the one-year period, all
benefits associated with non-p1ant ADFIT will have been
returned to customers and rates will increase on
May 1 , 2022.
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The l-ast component of t.he TCJA is the regulatory
liability associated with t.he reduced t.ax rates from
,Tanuary 1, 201-8 through May 31, 201-8, prior to the rate
relief offered by the Commission on 'June L, 2018 to account
for the reduction in the corporate tax rate. The parties
in this case agree that $772,504 represents the correct
calculation of the regulatory liability and customers will
receive this benefit over one year, similar to t.he
treatment of the non-P1ant ADFIT.
On May 1, 2022, customer rates will increase by
$2.38 mi11ion, or 5.202 to reflect. the depletion of these
tax benefits.
O. Why does St.aff support returning the benefits of
the non-p1ant. ADFIT and regulatory liabilit.y associated
with the reduced tax rate from ,fanuary 1, 201-8 through
May 31, 2018 to customers in one year.
A. The Commisslon has discretion on the timing and
method to return these benefits to customers. The parties
agree that returning these benefit,s to customers in one
year is a practical approach to mitigate any rate increase
granted during a time that. many customers may still be
recovering from diminished employment opportunitj-es and
other financial difficulties. This approach essentially
creates a two-year phase in of the stipulated revenue
requirement. increase.
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O. How does the Settlement address other revenue
requirement issues?
A. The Sett.lement specifically addresses the
recovery of the Company's contributions to its pension plan
and updates the Company's depreciat.ion rates.
A. Please discuss the recovery of the Company's
pension contributions .
A. Consistent. wit.h seLLlements approved by the
Commission in Order Nos. 32443 and 33435 (Case Nos.
UWf-W-1,1-A2 and UWI-W-15-01, respectively), a base level of
pension expense recovery is established. The Company will
be authorized to record a deferred asset or l-iability for
the difference between t,he actual cash contri-butions in
each year and the base 1eveI included in rates. In this
Set.tlement, the parties agree that $1,31-2,595 is the
appropriate base 1evel for pension recovery.
O. Please dj-scuss the Company's depreciation expense
and how it is reflected in the Settlement.
A. Prior to the filing of its Application, the
Company hired Alliance Consulting Group to conduct a
depreciation study of the Company's depreciable assets as
of December 31, 201-9. This was t.he Company's first
comprehensive depreciation study and it est.ablished the
proposed depreciation rates included in t,he testimony and
exhibits sponsored by witness Dane A. Watson on behalf of
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the Company. The depreciation rates agreed to in the
Settlement are included in Exhibit C of the Settlement and
reflect updates proposed by Staff. These updated
depreciation rates reduce the Company's proposed
depreciation expense and revenue requirement.
O. How does the SettlemenE propose the Company
recover j-ntervenor funding if granted by the Commission?
A. The revenue requi-rement agreed to in the
Settlement does not. include an amount to recover intervenor
funding. As allowed by st.atute and by Commission's
procedural rules, parties may request and t.he Commiss j-on
may award intervenor funding to be paid by the Company. If
the Commission awards intervenor funding in this case, the
parties agree that. the Company should be allowed to recover
t.he intervenor funding as an incremental addition to the
first-year revenue requirement. The second-year revenue
requirement witl decrease by the amount of j-ntervenor
funding awarded by the Commission, so the Company will not
continue to recover intervenor funding after
April 30, 2022.
O. Are t.here any other provisions in the Settlement
that you would like to address?
A. Yes. The Set.tlement requires the Company to
complete a load study to provide max-day and max-hour
factors for each customer class and the water system as a
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whole. The Company will convene a discussion process with
interested parties to receive input. on the different study
components. The study will be filed in the Company's next
general rate case and will al1ow parties to det,ermine the
appropriat.e 1evel of cosLs to be assigned or allocated to
the different customer classes.
The Company will also broaden its public outreach
efforts and host annual workshops for al-I interested
parties. Commission Staff, the Idaho Department of
Environmental Quality, and the Idaho Department of Wat,er
Resources will participate in t.he discussion on a range of
topics relat.ed to water conservation and resource planning.
Additionally, Lhe Company has agreed to meet with
representatives of CAPAI to examine the current status of
SUEZ Water's Iow-income assistance program, the ]evel of
participation and effectj-veness of the program, and to
identify and consider opportunities to improve the program
for Iow-income customers.
O. Do you have any other comments on the Settlement?
A. Yes. Staff has exami-ned Exhibits A - C and
verified threy are consistent with the Settlement and
reasonably recover the proposed revenue requirement. As
implied in this testimony, t.he Settlement represents a
fair, just, and reasonable compromise of the positions put
forth by a1t parties and is in the public interest.
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Therefore, Staff recommends the Commission approve the
Set.tl-ement without. material changes or modif ications.
a. Please explain concerns you are aware of related
to water quaIit.y.
A. Customers in the Boise Bench area continue to
have complaj-nts about. waLer quality. Staff has
investigated complaints and attended town haI1 style
meetings held by SUEZ Water with customers. Although SVEZ
Water has made some improvements, customer concerns sti11
exist. Staff will continue to investigate these concerns.
Staff will also monitor and track the Company's ongoing
plans to replace pipe, flush lines, and make improvements
to the Taggart well as approved by the Idaho Department of
Environmental Quality. Staff witl also evaluate delayed or
accelerated timelines for improvements and provide
additional customer communications.
a. Does this conclude your testimony?
A. Yes, it does.
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Professional QuaIif ications
of
Donn English
Program Manager - Accounting and Audit
Program Manager - Technical Analysis
Idaho Public Utitities Commission
EDUCATION
Mr. English graduated from Boise State University in 1998 with a
Bachelor of Business Administration degree j-n Accounting. His
studies concentrated on corporate finance and taxation. He was
a member of the Alpha Beta Psi honor society for Accounting
students. He completed the Annual Regulat'ory Studies Program,
the Advanced Regulatory Studies Program, and the Accounting and
Ratemaking Course offered through the Institute of Public
utilities at Michigan state university. Additionally, h€
regularly attends meeLings and conferences sponsored by the
Nationat Association of Regulatory Commissioners (NARUC) and the
society of utility and Regulatory Financial Analysts.
In 2001, Mr. English became a designated member of the American
Societ.y of pension Professionals and Actuaries (ASPPA) and was
awarded the professional designation of Qualified Pension
Administrator (QPA) and Quallfied 401 (k) Administrator (QKA) '
Mr. English was al-so a member of the Associat.ion of Certified
Fraud Examiners.
BUSINESS EXPERIENCE
prior to joining the Idaho Public Utilities Commission (IPUC),
Mr. English was a Trust Accountant wj-th a pension
administration, actuarial, and consulting firm in Boise, Idaho'
In 7,999, He was promoted to Pension Administrator, and in 2001
he was promoted to Pension Consultant. In that capacity, MT.
English performed actuarial calculations and the required non-
discrimination calcul-ations for hundreds of qualified retirement
p1ans. He completed and filed Form 55OOs and represented clients
during audits by the Department of Labor and the Internal
Revenue Service. He also participated on the task force that
wrote questions for t.he ASPPA administrator and actuarial exams.
Exhibit No. 101
Case No. SUZ-W-20-02
D. English, Staff03ll7l2l Page 1 of 2
Professional Qualificationsof
Donn English
continued
Mr. English joined t,he IPUC in 2003 as a St.aff Auditor. In 20L6,
he was promoted to Audit Team Lead, and in 2018 he became the
program Manager for the Accounting and Audit Department within
the Utitities Divisj-on. In 2020, MI. English also accepted the
responsibility of supervising the Technical Analysis and Energy
Efficiency team. At the Commission, Mr. English has audited a
number of utilities including electric, water, and natural gas
companies, and provided comments and testimony in numerous cases
that. deal with general rates, tax issues, pension issues,
depreciat.ion and other accounting issues, and other regulatory
policy decisions. MR. English participates in t.he Energy
Efficiency Advisory Groups and External Stakeholder Advisory
Committees for Idaho Power, Avista Utilities, Rocky Mountain
Power, and Intermountain Gas Company. He is the Commission's
representative on the NARUC Subcommj-ttee of Accounting and
Finance, and he also t,eaches at the NARUC Rate school.
Exhibit No. 101
Case No. SUZ-W-20-02
D. English, Staff
03ll7l2l Page2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ITth DAY OF MARCH 2021,
SERVED THE FOREGOING DIRECT TESTIMOIYY OF DOIIN ENGLISH IN
SUPPORT OF THE STIPULATION AIID SETTLEMENT, N CASE
NO. SUZ-W-20-02, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GIVENS PURSLEY LLP
PO BOX2720
BOISE ID 83701-2720
E-MAIL : mcc(A,siY enspursley.com
prestoncarter@ givenspursley.com
LORNA K. JORGENSEN
JOHN C. CORTABITARTE
ADA COUNTY PROSECUTING
ATTORNEY'S OFFICE
CNIL DIVISION
2OO W. FRONT STREET, ROOM 3I9I
BOISE,ID 83702
E-MAIL: [e-mail]. gov
j cortabitarte@adacounty. id. eov
MARY R. GRANT
SCOTT B. MUIR
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
150 N. CAPITOL BLVD.
P.O. BOX 500
BOISE,ID 83701-0500
E-MAIL: [e-mail]
BRAD M. PURDY
2019 N. 17rH ST.
BOISE, TD 83702
E-MAIL: [e-mail]
DAVID NJUGUNA
MGR _ REGULATORY BUSINESS
SUEZ WATER MGMNT & SERVICES CO
461 FROM ROAD SUITE 4OO
PARAMUS NJ 07052
E-MAIL: [e-mail]
NORMAN M. SEMANKO
PARSONS BEHLE & LATIMER
8OO W. MAIN ST., STE.13OO
BOISE,ID 83702
E-MAIL: [e-mail]
Boisedocket@oarsonsbehle. corn
MARTY DURAND
PIOTROWSKI DURAND PLLC
1O2O MAIN ST., STE. 440
P.O. BOX 2864
BOISE,ID 83701
E-MAIL: [e-mail]
KEN NAGY
ATTORNEY AT LAW
P.O. BOX 164
LEWISTON,ID 8350I
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF
THORVALD A. NELSON
555 lTrH ST., STE. 3200
DENVER, CO 80202
E-MAIL : [e-mail]
tnel son@hollandhart. com
[e-mail]
gl garganomari @.hollandhart. com
ZOE ANN OLSON
EXCUTIVE DIRECTOR
INTERMONTAIN FAIR HOUSING
COUNCIL INC
4696W OVERLAND RD, STE 140
BOISE ID 83705
E-MAIL: [e-mail]
JIM SWIER
GREG HARWOOD
MICRON TECHNOLOGY, INC.
8OOO S. FEDERAL WAY
BOISE, ID 83707
E-MAIL: [e-mail]
[e-mail]
ARY
CERTIFICATE OF SERVICE