20180627Staff 1-7 to Suez.pdf

Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83]20-0074
(208) 334-03s7
IDAHO BAR NO. 7956
IN THE MATTER OF THE JOINT
APPLICATION OF UNITED WATER IDAHO
INC., AND BRIAN SUBDIVISION WATER
USERS ASSOCIATION FOR APPROVAL OF AN
AMENDMENT TO CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY NO. 143;
APPROVAL OF AN AGREEMENT FOR
CONNECTION AND TRANSFER OF WATER
SYSTEMS; APPROVAL OF RATES AND
CHARGES
RfCEIVED
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CASE NO. SUZ.W.18-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
SUEZ WATER IDAHO INC.
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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
WEDNESDAY, JULY 18, 2018.
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
FIRST PRODUCTION REQUEST
TO SUEZ WATER I JtrNE 27,2018
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3t.01.01.228.
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: On page 4 of his supplemental testimony, Mr. Wyatt states that no
contractor costs for the unsuccessful bore attempts were included in the Company's filing. Were
any other costs associated with the unsuccessful bore attempts included in this filing? If so,
please provide the following:
a. A detailed explanation of these costs.
b. Where were these costs recorded?
REQUEST NO. 2: On page 4 of Exhibit 2 of his original testimony (UWI-W-14-01),
Mr. Wyatt provided an estimate of the costs of replacing mains and services within the Brian
Subdivision. On page 5 of his supplemental testimony, Mr. Wyatt explains that an additional
$19,000 of additional piping was required because the existing piping was in poor condition and
required replacement. Please explain what additional piping was not included in the Company's
original estimate in UWI-W-14-01.
REQUEST NO.3: On page 4 of Exhibit 2 of his original testimony (UWI-W-14-01),
Mr. Wyatt provided an estimate of the costs of replacing mains and services within the Brian
Subdivision. On page 5 of his supplemental testimony, Mr. Wyatt explains that abandoning and
replacing the existing BSWUA services resulted in about $24,000 higher cost. Please explain
what abandonment and replacement costs were not included in the Company's original estimate
in UWI-W-14-01.
REQUEST NO. 4: On pages 5 and 6 of his supplemental testimony, Mr. Wyatt explains
that the low cost bidder, Owyhee Construction, was no longer qualified to bid or work on SUEZ
projects in2017. Please explain why Owyhee construction was not qualified to perform this
project.
FIRST PRODUCTION REQUEST
TO SUEZ WATER 2 JUNE 27,2018
REQUEST NO. 5: Please provide a map showing the location and sizes of all major
construction and equipment including pipes, hydrants, tunnels, bore holes, and bore hole casings.
REQUEST NO. 6: Please provide the supporting documentation for all the costs
included for recovery from all ratepayers. In addition, please provide the supporting
documentation for the costs for the Brian Subdivision Water Users Association.
REQUEST NO. 7: Please provide copies of the quarterly construction reports for
October 2015, January 2016, February 2016, July 2017, and November 2017.
Technical Staff: Mike Morrison/l-5
Kathy Stockton/6
Chris HechtlT
i:umisc:prodreq/suzwl 8. lbkmmklscwh prod reql
FIRST PRODUCTION REQUEST
TO SUEZ WATER aJ JLINE 27,2018
Dated at Boise, Idaho, this /.?Di^rof June 2018.
CBRTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF JUNE 2018, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO SUEZWATER, IN CASE NO. SUZ-W-18-01, BY MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MICHEAL C CREAMER
GIVENS PURSLEY LLP
PO BOX2720
BOISE rD 8370t-2720
E-MAIL : mccf.g;, givenspursley.com
RICHARD JUENGLING
PRESIDENT
BRIAN SUB WATER USERS
5885 EASTWOOD PLACE
BOISE ID 83716
Y
CERTIFICATE OF SERVICE