20181221Staff 1-20 to Suez Water.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
IN THE MATTER OF THE JOINT
APPLICATION OF SUEZ WATER IDAHO AND
EAGLE WATER COMPANY FOR THE
ACQUISITION OF EAGLE WATER COMPANY
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NOS. SUZ-W-18-02/
EAG-W-18-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
SUEZ WATER IDAHO INC.
The Staff of the Idaho Public Utilities Commission requests that Suez Water Idaho Inc.
(Company) provide the following documents and information as soon as possible, by FRIDAY,
JANUARY 11,2019.
This Production Request is continuing, and the Company is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
FIRST PRODUCTION REQUEST
TO SUEZ WATER i DECEMBER 21, 2018
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide all tables and exhibits included in all testimonies in
electronic format with all formulas intact. Please also provide all associated workpapers.
REQUEST NO. 2: Please identify and describe the escalation and/or change in state and
federal regulations mentioned on page 3 of Thompson testimony for the years 2010 to present.
Identify each agency or department requiring the regulation, and specify whether each
escalation/change in regulation is local, state, or federal in nature.
REQUEST NO. 3: In reference to page 8 of Thompson testimony, please demonstrate
how the Eagle Water system has "suffered from less than optimal capital investment" including
deficiency reports from regulatory agencies, outage locations and durations, and complaints of
inadequate service from Eagle Water customers. Please also provide the number of Eagle Water
customers that have requested service from SUEZ Water Idaho due to the condition of the Eagle
Water system.
REQUEST NO. 4: Please quantify the monetary value of each item included in the list
of "Identifiable synergies and efficiencies" listed on pages 8-l I of Thompson testimony. Please
identifu whether the benefit is to current Eagle Water customers or current SUEZ Water Idaho
customers.
REQUEST NO. 5: Please provide all financial analyses prepared by or for SUEZ Water
Idaho for estimating the value of Eagle Water's system. If not clearly labeled in the workpapers,
please provide assumptions on the cost of capital and annual (or quarterly, if applicable)
expected revenue and costs, including book depreciation, tax depreciation, income taxes,
deferred taxes, property taxes, and other items typically included in a discounted cash flow
analysis.
FIRST PRODUCTION REQUEST
TO SUEZ WATER 2 DECEMBER 21, 2018
REQUEST NO. 6: SUEZ Water Idaho proposes a three year rate phase-in for Eagle
Water customers after the acquisition (Cary testimony page 72,lines 6-15). Please break down
the portion of the increase that will be recovered through basic service charges and the portion
recovered through consumption rates. Please explain the method and rationale used and provide
all supporting workpapers.
REQUEST NO. 7: Thompson's testimony on page 8 states, "Suez's standards for plant
maintenance, upgrades and replacements indicate that some substantial capital investments
should be scheduled over the next several years." Please provide supporting evidence including
reports, analysis, etc. that demonstrates that the current Eagle Water system is not providing safe,
reliable service.
REQUEST NO. 8: Please provide the documentation that supports the increase of
$158,750 in operating expenses as shown in Exhibit No. l, Schedule la in Cary's testimony
REQUEST NO. 9: Please provide all the analysis, including all workpapers of Eagle
Water Company system showing that it does not meet IDEQ requirements for redundant non-fire
pumping capacity (IDAPA 58.01.08 Section 501.17), redundant fire pumping capacity (IDAPA
58.01.08 Section 501.17) and emergency operation (IDAPA 58.01.08 Section 501.07) stated in
Cooper's testimony page 5, lines 1-6. Please include schedules of the expected costs to resolve
the Eagle Water system requirements.
REQUEST NO. 10: Please provide the regulatory requirements and standards for the
"disinfection needs" of Eagle Water Company as stated in Cary testimony page 5 line 12. Please
include in your response the deficiency letters Eagle Water Company has received as a result of
water testing, or any other evidence supporting these needs.
REQUEST NO. 11: Please provide the source documents for the closing costs incurred
to date. Did SUEZ Water Idaho competitively bid the ALTA survey? If so, please provide the
bids. If not, please explain why it was not competitively bid.
FIRST PRODUCTION REQUEST
TO SUEZ WATER aJ DECEMBER 21, 2018
REQUEST NO. 12: Please provide SUEZ Water Idaho's capital budget projections for
the years 2019-2025.
REQUEST NO. 13: Please provide SUEZ Water Idaho's budgets filed for approval
with the board of directors for the years 20 I 0 through 20 I 8. Include in your response the actual
capital investments by year for 2010 through 2018.
REQUEST NO. 14: Please provide the cost breakdown for the $11.7 million capital
cost avoidance. Include in the response: a) analysis that shows need for new sources of supply;
b) other options that were studied; and c) the cost-benefit analysis for the other options.
REQUEST NO. 15: Please provide the cost-benef,rt analysis supporting the installation
of new automated meters for Eagle Water Company customers.
REQUEST NO. 16: Please provide SUEZ Water Idaho's current meter replacement
plan for SUEZ customers.
REQUEST NO. 17: Please provide the meter replacement plan for Eagle Water
customers if SUEZ acquires Eagle Water.
REQUEST NO. 18: Please provide all workpapers supporting the analysis of Eagle
Water Company's current portfolio of municipal water rights identified in Cooper's direct
testimony page 5, lines 10-1 1. Please include schedules of the expected costs to resolve Eagle
Water's standalone system of the water right issues.
REQUEST NO. 19: Please provide the source documents and detailed costs estimates
for the $13.4 million anticipated investment for the Eagle Water system.
FIRST PRODUCTION REQUEST
TO SUEZ WATER 4 DECEMBER 2I, 2018
REQUEST NO. 20: Please reconcile the charts shown in Cooper's testimony on pages
7,8 and 11.
a. Are there projects listed on pages 7 and 8 that are duplicated on page 11? Please
explain.
b. Is the total cost actually the $30.141 million as shown on page 8 plus the $13.358
million shown on page 1 I for a total of $43.499 million? Please explain.
c. Please identify which capital investments the Company would make with the
acquisition of the Eagle Water system and which capital investments the
Company would make without the acquisition of the Eagle Water system.
Dated at Boise, Idaho, this Z/tr
day of December 2018.
l6
Sean Costello
Deputy Attomey General
i :umisc:prodreq/suzw I 8.2_eagw I 8. I sctnc prod req I to Suez
FIRST PRODUCTION REQUEST
TO SUEZ WATER 5 DECEMBER 21, 2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2I't DAY OF DECEMBER 2018,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO SUEZ WATER IDAHO INC., IN CASE NOS. SUZ-W-18-02/EAG-W-I8-01, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 W. BANNOCK ST.
BOISE, ID 83702
E-MAIL : mcc(i?, givenspursley.com
ROBERT DESHAZO
EAGLE WATER COMPANY, INC
188 W. STATE ST.
EAGLE, IDAHO 83616
MARSHALL THOMPSON
SUEZ WATER IDAHO, INC.
8248 W. VICTORY RD.
BOISE, IDAHO 83709
E-MAIL : rnar:shall. thompsonG)suez.com
N.L. BANGLE
188 W. STATE ST.
EAGLE, IDAHO 83716
E-MAIL : rrbansle,.@h2o-solutionsll c.net
SECRET
CERTIFICATE OF SERVICE