20180720Suez to Staff 1-7.pdf

Michael C. Creamer, ISB #4030
GIVENS PURSLEY LLP
601 W. Bannock St.
P.O.Box2720
Boise, Idaho 83701-2720
Telephone: [phone]
Facsimile: 208-388-1300
1425531 1_1.DOC 130-1721
RTCTIVED
?01$ JUL 20 PH tr: LS
.l
SUEZ WATER IDAHO INC.'S
RESPONSE TO COMMISSION
STAFF'S FIRST PRODUCTION
REQUEST
u
OD oi.J
Attorneys for SUEZ Water ldaho Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISION
IN TIIE MATTER OF THE JOINT
APPLICATION OF UNITED WATER
IDAHO INC., AIID 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
$lll.Z-d - tX-o t
Case No. U\Yts{ilL14-01
The following are SUEZ Water Idaho Inc.'s (o'Suez") answers/responses to Commission
Stafls JUNE 27,2018 "First Production Request of the Commission Staff to Suez Water Idaho
Inc."
The following Responses each are sponsored by SUEZ's General Manager and Vice
President, Marshall Thompson. Mr. Thompson has recently moved into this role to replace Mr.
Gregory Wyatt who has recently accepted a position with the SUEZ corporate office in New
Jersey.
REOUEST NO. 1: On page 4 of his supplernental testimony, Mr. Wyatt states
that no contractor costs for the unsuccessful bore attempts were included in the
SI.IEZ WaTeR IDAHo INC.,S RESPONSE TO COTUUISSIOT.I STAFF,S FIRST PRODUCTION REQUEST - I
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?
RESPONSE TO REOUEST NO. 1: There were no costs incurred by the Company
directly associated with the unsuccessful bore attempts. As previously stated, all of the
contractor costs incurred on the unsuccessful bore attempts were borne by the contractor.
The project did, however, incur certain indirect costs due to the delays associated with the
unsuccessful bore attempts. These costs include continued engineering and operations support of
the project and continued application of AFUDC. These costs are booked to the project and are
included in the current cost information.
SUEZ would also point out that the surcharge calculation worksheet utilized from the
original cost estimates may need to be adjusted specifically related to the computation of income
taxes. SUEZ invites a discussion with Staff to clarify those calculations. In addition, SIJEZ
inadvertently stopped AFUDC as of November 2017 when the project was placed in service. An
adjustment should be made for this. However, SUEZ proposes not to adjust the surcharge to
account for this, but rather to include this amount in a future rate filing, and again invites
discussion with Staff concerning this proposal.
As stated in Company response to Production Request #6 below, SUEZ invites Staff to
schedule an audit at SUEZ's local Idaho office at8248 West Victory Road, Boise, to view
electronically any documents related to the project charges.
LEQUEST NO. 2: On page 4 of Exhibit 2 of his original testimony
(UWI-W-l4-01), Mr. Wyatt provided an estimate of the costs of replacing mains and
SUEZ WereR IDAHo INC.'s RESnoNSE To CoMMISSToN STAFF's Frnsr PRooucrroN REeUEST - 2
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.
RESPONSE TO REOUEST NO. 2: The additional piping costs amounted to $18,930 as
detailed below, (rounded to $19,000 in the testimony).
B o H
I
4
5
93
9{
95 t" F/c r,{sTAu
96 4'ft/C MAIEiIAL
9' -4' GATE VAI.VE
s-Al ilDor{ 5. r{EAr 5910 s. SRl x waYwEr,ItoT
t AiAflOOt{ 2" NEA&61ZtW. 8ilAfl WAY
rs 2' & 6" aBaI\rDolrMENlS oFr 5, SnrA$ WAY
1.6!0
400
lLm
?.{0o
5&
lJ(x,
1m0
xtr
1650
3$
ll,qn
:,qB
6$rJa
Ldnta
2?J{t
8.6
u.50
6m
500.00
L5Ar0
Lm.o
!00.00
60
50
a&
am
I
I
I
I
During the project, SUEZ discovered that certain portions of the existing piping were not
below frost depth andlor were in such poor condition that new pipe could not be connected to the
existing pipe. As is often the case with buried piping, the actual location and condition are not
known until the pipe is exposed during construction. The shallow depth and poor condition of
piping that was discovered when it was exposed necessitated the replacement of some piping not
originally anticipated to need replacement. This included:
Existing Z-inchmain at the east end of Brian Way that was replaced with new 4-inch
main (IDEQ minimum pipe size requirement). Costs included installation of 400 ft. of new 4-
inch PVC and abandonment of the existing 2-inch near 6123 Brian Way, and the 2-inch & 6-inch
abandonments off S. Brian Way (in the roadway).
The 60 ft. of new 6-inch PVC was required to make the tie-overs to SUEZ's existing 6-
inch main on S. Eastwood Place.
ORIEINAT ESTIMATE
ut{tt tosrUHlT9 lltrrl CO6T SUBTOT[urlt c(xl rTtM co6r
ACTUAL
uxlTs SUETOIA
DIFFENENCE
PVC rNS;Ail.
SUEZ W,CTER IDAHO INC.'S RESPONSE TO COMMISSION STETT'S FIRST PRODUCTION REQUEST - 3
t
BRIAN SUBDIVISION - WATER SUPPLY PROJECT - COST EsTIMATE VERSUS ACTUAT
The 6-inch abandonment near 5940 S. Brian Way Well Lot was to cut off and
remove a portion of pipe that had connected the BSWUA existing well to the system.
REOUEST 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.
RESPONSE TO REOUEST NO. 3: The additional $24,030 (rounded to $24,000 in
Testimony) consists of the following:
o Existing service abandonment labor - $ 1 1,750
o Existing service abandonment material - $9,400o Extra labor at 6057 & 6075 Brian Way - $1,680 - the existing services were in the
customer's backyard necessitating additional time and materials.
o Extra trenching & sprinkler connection at 6123 Brian Way - $ 1,200 - there were two existing
services at this home that were tied together and needed to be separated.
The service tie-overs and abandonments, both labor and material, originally were
estimated based on the contractor's expectations from above ground observations. Many
of the individual customer services subsequently were determined to be in poor locations
with difficult underground conditions, and needed to be moved to entirely new locations
to meet SUEZ' construction standards
REOUEST 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 rn2017. Please explain why Owyhee construction was not
qualified to perform this project.
SUEZ WnrrR IDAHo INC.'s RESPoNSE To CoMMISSIoN STAFF's FrRST PRoDUcrroN Rrquesr - 4
RESPONSE TO REQUEST NO. 4: SUEZ conducts annual reviews on the performance
of its "approved" main installation contractors based on the work they perform for SUEZ. In
early 2017, SUEZ removed Owyhee Construction Company ("Owyhee") from the approved
contractor list based on SUEZ's most recent evaluation of their overall performance on recent
contracts.
REOUEST 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.
RESPONSE TO REOUEST NO. 5: Please see as-built diagrams provided as
Attachment t hereto and included on enclosed CD for supporting data.
REOUEST 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.
RESPONSE TO REQUEST NO. 6: Please see the Excel file named "#6 Brian Water
Project Detail Cost.xlsx," which provides details and summary of all costs charged to the project
and is provided on the enclosed CD for supporting data.
All original documents related to invoices, etc. are maintained at the Company's
corporate offices in Paramus, NJ and accessible electronically at SUEZ's local office at8248
West Victory Road, Boise. SUEZ invites Staff to schedule a time to audit and view
electronically any documents related to the project charges as detailed in the Excel file.
REOUEST NO. 7: Please provide copies of the quarterly construction reports for
October 2015, January 2016, February 2016, July 2017, and November 2017.
SUEZ WATER IDAHo INC.'s RESIoNSE To CouutsstoN STAFF's FrRST PRoDUCTIoN REeUEST - 5
RESPONSE TO REQUEST NO. 7: Copies of the October 2015, January 2016,
July 2017, and November 2017 quarterly construction reports are provided as Attachment
2 hereto and is provided on the enclosed CD for supporting data. There is no February
2016 report as the quarter ending December 2015 report was submitted to the Utility
Administrator, Randy Lobb, in January 2076, and is the January 2016 report provided
with this Response. ,)*
DArED tt i, Z-/lauyof July 2018.
GIVENS PURSLEY LLP
Michael C
Attorneys for SUEZ Water Idaho Inc.
SUEZ WerER IDAHo INC.'s RESPoNSE ro CouurssroN STAFF'S FrRSr PRoDUcrroN Rrquesr - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on theZD-day of Jrl./ , zot8l caused to be filed
three copies of the foregoing with the Cornmisslor. ur ..qri..d y fUC Rule 31.01.01 .061.02.a
and a copy the foregoing to be served upon:
Commission Staff
Brandon Karpen
Deputy Attomey General
Idaho Public Utilities Commission
47 2 W . Washington Street
Boise, ID 83702
Brian Subdivision Water Users
Richard Juengling, President
5885 S. Eastwood Place
Boise, ID 83716
Email: [e-mail]
Michael C. Creamer
SUEZ WATER Ioe.go INC.,S RESPoNSE To COMMISSIoN STAFF,S FIRST PRoDUCTION REQUEST - 7
SUEZWATERIDAHO INC.'S
RESPONSE TO COMMISSION
STAFF'S FIRST
PRODUCTTON REQUEST #s
CASE NO. Uwr-\ry'- 14-01
ATTACHMEI{T 1
suez ,@\a-a
r3060
APPROVED
Suez -Terry
Dahle - Chad
2-27.18
\ -,:
ffi i
IiJ
SALe
l
!
alFsloyto*k"JpT- ri-
gM .A. PUN WT
- -i: r
l
i
J
MWME
lH,F--
I :l?-----
-
\. il l':
)I
i
I
r[66&p
4E
1J060
.J
IW:1'-t0O'
li
-3':t:F.U-
.i.
\l
,'Note',
i All Dl rs RESTRAINEO
LEcEMr'--\.'.
l @
1
,\
I
'{,/ ,---.
l^l
).:i.
ii '1"
I
I
SUEZWATERIDAHO INC.'S
RESPONSE TO COMMISSION
STAFF'S FIRST
PRODUCTTON REQUEST #7
CASE NO. UWI-\il-14-01
ATTACHMEI\T 2
i :,:.i i'!jl.' i;.-: . ;?I ;.: i,x3 l'.i" t, i ) ! ;i;';..,,
8248 W. VICTORY ROAD
BOISE, ID 83709
TEL [phone]
FAX [phone]
WWW.UNITEDWATER.COM
Mr. Randy Lobb
Administrator
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83702
October 19, 2015
Re: Brian Subdivision Connection Project, Quarterly Report
Dear Randy,
Consistent with Order No. 33195, Case No UWI-W-14-01, following is the quarterly
construction report on progress and expenditures to date through September 30,
2015, Due to my illness and absence from work most of the summer, no 2nd
quarter report was prepared or submitted.
As repofted in the 1't quarter update, the project was placed on hold during the
irrigation season because we were not permitted to perform canal bore work during
that time frame. Since the end of March, there has been virtually no physical
activity on the project other than monthly water level monitoring.
It is our intent to construct a new deeper but shallower sloping directional bore now
that the irrigation season has ended. We anticipate our bore contractor, Earth
Energy, to mobilize for that work the week of November 16, 2015. Following a
successful canal bore, they will mobilize to accomplish the bores of the Boise River
and the Penitentiary Canal, so as to reach Warm Springs Avenue. Assuming
successful bores and fair weather, we will commence roadway and in-subdivision
work later this spring/summer, It is difficult to project exact timelines for the
project pieces.
I am in touch with Dick Yuengling of the Brian Subdivision Water Users Association
and am providing him with a copy of this update.
Total project construction-work-in-progress expenditures through September 30,
2015 equal $215,944, and are detailed in the attached exhibit.
Please advise if further information is desired.
Sin
o Wyatt
nager
tl
ne
ly
"Prt,
United
Water
UNITED WATER IDAHO CONSTRUCTION.WORK.IN-PROGRESS SUMMARY REPORT
Quorter End Dote: 9/3O120L5
Project lD: C15D101_060 "BSWUA lnterconnection, Acquisition & Rebuild"
TOTAT COST COST TYPE
5L7,70s Legal (associated with BSWUA Agreement and IPUC filing)
529,2L7 Contractor costs for land surveys, alignments, easements, construction staking, geotechnical engineering, New
York Canal liaison, piezometer well (including groundwater monitoring program) & associated fees
S936 Contractor costs for hydraulic analysis of BSWUA connection alternatives
S108,029 Contractor & material costs for directional bores
s830 Fees paid by United Water for canal crossings & ITD permits
s26,s3s United Water Payroll: Salary, benefit & vehicle allocations
524,86t United Water overheads
57,83L Allowances for Funds Used During Construction
52Ls,944 GRAND TOTAr COST TO DATE 9l30l20ls
SUEE
Gregory P. Wyatt
8248 West Victory Road
Boise, lD 83709
Tel:[phone]
Fax:[phone]
Email : greg.wyatt@suez-na. com
January 25,2016
Mr. Randy Lobb
Administrator
ldaho Public Utilities Commission
472 W . Washington Street
Boise, lD 83702
Dear Randy:
Consistent with Order No.33195, Case No UWI-W-14-01, following is the quarterly construction report on
progress and expenditures to date through December 31 ,2015.
As reported in the last quarter update, the project was placed on hold during the irrigation season because we
were not permitted to perform canal bore work during that time frame. From mid-April to early-December, there
was virtually no physical activity on the project other than monthly groundwater level monitoring adjacent to the
New York Canal.
ln early-December 2015, our bore contractor, Earth Energy, remobilized to begin working on a new directional
bore under the New York Canal. This bore is one of two required to accomplish the main line connection from
our distribution system at Surprise Way to the Brian Subdivision. lt is our intent to construct a new deeper but
shallower sloping directional bore now that the irrigation season has ended, using a more powerful drilling rig
and larger diameter reaming stem. The total length of this new bore is approximately 885 ft.
During this new pilot bore drilling, the contractor's rig experienced mechanical failures that resulted in halting
construction for necessary repairs and plans for restarting pilot drilling as soon as possible in 2016. The
contractor has restarted pilot drilling and is drilling from below the New York Canal up towards Surprise Way.
It is expected to take the full 1st quarter of 2016 to complete the New York Canal bore. Following a successful
canal bore, the contractor will mobilize to accomplish the bores of the Boise River and the Penitentiary Canal, so
as to reach Warm Springs Avenue. Assuming successful bores and fair weather, we will commence roadway
and in-subdivision work later this spring/summer. lt is difficult to project exact timelines for the project pieces.
I am in touch with Dick Yuengling of the Brian Subdivision Water Users Association and am providing him with a
copy of this update.
Total project construction-work-in-progress expenditures through December 31, 2015 equal $225,682, and are
detailed in the attached exhibit.
Sincerely
Gregory P. Wyatt
General Manager
Cc:J. Reichard, SUEZ; R. Yuengling
United Water ldaho is changing its brand to SUEZ
Office * 8248 West Victory Road, Boise, lD 83709
SUEZ WATER IDAHO CONSTRUCTION-WORK-IN-PRO6RESS SUMMARY REPORT
f ormerly United Water.ldaho
cosrs ro Dote: 72/3u2075
Project /D: C15D101_060 "BSWUA lnterconnection, Acquisition & Rebuild"
TOTAL COST COST TYPE
Stt,tos Legal (associated with BSWUA Agreement and IPUC filing)
S30,123 Contractor costs for land surveys, alignments, easements, construction staking, geotechnical engineering, New
York Canal liaison, piezometer well (including groundwater monitoring program) & associated fees
Sgso Contractor costs for hydraulic analysis of BSWUA connection alternatives
S108,029 Contractor & material costs for directional bores
Sa:o Fees paid by SUEZ for canal crossings & ITD permits
Szo,ozz SUEZ Payroll: Salary, benefit & vehicle allocations
S2s,s3s SUEZ overheads
512,s03 Allowances for Funds Used During Construction
Szzs,6g2 GRAND TOTAr COSTTO DATEtzlSLl2OLS
SUEZ
SUEZ Water ldaho
8248 West Victory Road
P.O. Box 19A420
Boise, lD 83719-0420
July 26,2017
Mr. Randy Lobb
Administrator
Idaho Public Utilities Commission
472 W. Washington Street
Boise, lD 83702
Re: Brian Subdivision Connection Project, Quarterly Report June2017
Dear Randy:
Consistentwith OrderNo.33195, Case No UWI-W-14-01, following isthequarterlyconstruction reporton progress
and expenditures to date through June 30, 2017. Significant milestones on the project have been achieved during
the second quarter ol 2017.
First, our boring contractor, Earth Energy, successfully completed the Boise River and Penitentiary Canal bore
and pipeline installation. The remaining pipetine work to connect the bore pipes, the pipe installation in Warm
Springs Avenue, and the work within the Brian Subdivision is now scheduled to begin on July 31. Our pipeline
contractor, Dahle Construction, anticipates an approximate 2-month construction timeline for all this work.
However, unknown underground issues, particularly within the Brian Subdivision, could extend the timeline. And
lastly, we began our communications with the Brian homeowners, first with a meeting with Dick Juengling, and
then with an introduction letter to all homeowners on July 20; a copy was sent to Beverly Barker.
During the second quarter we also competitively rebid the above described pipeline work because the initial pricing
received three years ago was no longer valid. Not surprisingly, the new pricing is higher than the old pricing by
more than $300,000. We are in the process of assessing all the differences in project scope and pricing and will
have a better understanding of the details next month.
Total project construction-work-in-progress expenditures through June 30, 2076 equal $961,677, and are detailed
in the attached exhibit. The contractor was responsible for its costs associated with all the un-successful boring
effort.
Please advise if further information is desired
Sincerely,
G
CC: D Juengling, J. Miller
SUEZWATER IDAHO CONSTRUCTION.WORK.IN-PROGRESS SUMMARY REPORT
Quorter End Dote: 6/30/2Ot7
Project lD: C15D101-060 "BSWUA lnterconnection, Acquisition & Rebuild"
TOTAL COST COST TYPE
5t7,7os Legal (associated with BSWUA Agreement and IPUC filing)
534,622
SUEZ costs for parts, material & supplies and contractor costs for land surveys, alignments, easements,
construction staking, geotechnical engineering, New York Canal liaison & road integrity, piezometer well
(including groundwater monitoring program), safety & associated fees
se36 Contractor costs for hydraulic analysis of BSWUA connection alternatives
$698,479 Contractor & material costs for directional bores
S83o Fees paid by SUEZ for canal crossings & ITD permits
Ss1,s67 SUEZ Payroll: Construction lnspection, salary, benefit & vehicle allocations
$L09,474 SUEZ overheads
S48,064 Allowances for Funds Used During Construction
s96].,677 GRAND TOTAT COST TO DATE 6130120t7
SUEE
SUEZ Water ldaho
8248 West Victory Road
P.O. Box 190420
Boise, lD 83719-0420
November 30,2A17
Mr. Randy Lobb
Administrator
ldaho Public Utilities Commission
47 2 W. Washington Street
Boise, lD 83702
Re: Brian Subdivision Connection Project, Quarterly Report October 2017
Dear Randy:
Consistent with Order No. 33195, Case No UWI-W-14-01 , following is the quarterly construction report on progress
to date through October 31,2017.
Our pipeline contractor, Dahle Construction, has completed all pipeline work in both Warm Springs and throughout
the Brian Subdivision, and all 46 customers have been connected with new service lines, meter vaults, and meters.
All 46 customers are now receiving water service from SUEZ and are being billed according to our current
approved metered tariff.
Additionally, we mailed two interim letters communicating the project work and schedule to all the Brian
homeowners; copies were sent to Beverly Barker.
Project costs recorded at the quarter ending date of October 31 are not materially different than those provided in
the last quarterly update sent on July 26, so I am not providing any updated cost summary in this raport. A
significant portion of the remaining project costs have been recorded in November and we anticipate having all
invoices and costs posted to the project by year end. Once all project costs are recorded and verified we intend
to recalculate the proposed customer surcharge based on known actual project costs. We expect to prepare and
submit the project costs compared to estimates from 2014 along with the calculations supporting the revised
surcharge as promptly as we can after all costs are recorded and verified; hopefully in January or early February
2018.
We anticipate additional communications with the 46 customers as we prepare and finalize the submission to the
Commission, and as in accordince with Order No.33195.
Please advise if turther information is desired
& General
CC: D Juengling, M. Creamer, J. Miller