20190124Staff 21-47 to Suez.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
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
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NOS. SUZ-W-18.02I
EAG-W-I8-01
SECOND 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.
(SUEZ) provide the following documents and information as soon as possible, by THURSDAY,
FEBRUARY 14,2019.
This Production Request is continuing, and SUEZ 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. SUEZ 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.
SECOND PRODUCTION REQUEST
TO SUEZ WATER JANUARY 24,2019I
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. 21: With regard to Production Request Response No. 1, please provide
all tables, schedules and exhibits mentioned in Jarmila Cary's testimony, schedule 1a, in
electronic format with all formulas intact. Please also provide all associated workpapers.
REQUEST NO. 22: With regard to Production Request Response No. 11 Exhibit L,
please provide a description of the professional services listed under Costs and Expenses for the
amount of $1,875.00. Also provide a copy of the invoice, if received, or detailed calculation and
all relevant information to demonstrate the prudency of the amount listed in that exhibit.
REQUEST NO. 23: Please provide all documents and workpapers related to the "Due
Diligence" SUEZ Water Idaho performed concerning the condition of Eagle Water Company's
system and operations in Section XI, on page 5 of the Application.
REQUEST NO. 24: Please explain how SUEZ Water Idaho was able to determine that
the purchase price represents a"fair value" ofthe assets to be purchased as referenced in Section
XI, on page 5 of the Application. Please provide all supporting documents and workpapers.
REQUEST NO.25: Does Eagle Water Company currently meet Federal and State
requirements for safe drinking water? If SUEZ Water Idaho maintains that Eagle Water
Company does not meet Federal and State requirements, please provide evidence that supports
SUEZ Water Idaho's conclusion.
REQUEST NO.26: In Attachments 3 and4 of the Application, SUEZ Water Idaho,
references under benefits to Eagle Water Company customers, "critical system disinfection for
public safety." Please explain how SUEZ Water Idaho will provide this as an incremental
benefit to Eagle Water Company customers through the acquisition.
SECOND PRODUCTION REQUEST
TO SUEZ WATER 2 JANUARY 24,2019
REQUEST NO. 27: In the postcard mailer sent by SUEZ Water Idaho to Eagle Water
Company customers, SUEZ Water Idaho explains why customer rates would increase over the
next 3 years. For each of the items referenced in the mailer that are noted below, please provide
justification, including any cost/benefit analysis or other types of analysis that the Company
conducted supporting each claim and/or need.
a. Current rate structure ... isn't sustainable and doesn't support regular system
upgrades.
b. SUEZ Water Idaho needs to ... replace meters.
c. SUEZ Water Idaho needs to ... upgrade generators.
d. SUEZ Water Idaho needs to ... add critical system disinfection.
e. SUEZ Water Idaho needs to ... ensure adequate fire protection.
f. SUEZ Water Idaho needs to ... improve system monitoring.
REQUEST NO.28: Has SUEZ Water Idaho completed an inspection of the assets being
acquired? If so please provide all information, analysis, and reports that resulted from the
Company's inspection.
REQUEST NO. 29: Has SUEZ Water Idaho completed an environmental assessment of
the assets being acquired? If so, please explain and provide all information, analysis, reports and
documentation that resulted from SUEZ Water Idaho's assessment.
REQUEST NO. 30: Are there any liens on any of the assets being acquired by SUEZ
Water Idaho through the acquisition? If so, please explain and provide all relevant
documentation and information related to each lien.
REQUEST NO. 31: Is Eagle Water Company involved in any lawsuits that may
interfere or affect the acquisition? If so, please provide all information and documentation
related to each lawsuit and explain how it will affect the acquisition.
SECOND PRODUCTION REQUEST
TO SUEZ WATER aJ JANUARY 24,2019
REQUEST NO. 32: SUEZ Water Idaho anticipates it will need to add three additional
employees to operate the Eagle Water Company system. See Cary Direct at 8. Please provide a
job description and salary range for the new SCADA Operator, Meter Reader and Customer
Service Representative positions. For each position, please indicate and explain whether: (a) the
job description and salary range is the same as the current positions within SUEZ's existing
Idaho service territory; and (b) the position will be dedicated solely to work related to serving
customers within the Eagle Water Company's service area. If the answer to (b) is no, please
provide further explanation regarding the need for the new positions.
REQUEST NO. 33: How many SCADA Operator, Meter Reader and Customer Service
Representative positions does SUEZ have currently? Please indicate how many of these
positions are considered to be full time and whether the positions are currently filled or vacant.
How many of these positions have been filled within the last twelve months?
REQUEST NO.34: For each Customer Service supervisory or managerial position for
SUEZ Water Idaho, please provide: (a) the job description and salary range; (b) whether the
position is considered to be full time; and (c) whether the position is currently filled or vacant.
REQUEST NO. 35: Please provide an organizational chart for SUEZ Water Idaho.
REQUEST NO. 36: Will the installation of AMI meters within both the SUEZ Water
Idaho and Eagle Water Company service areas be conducted by SUEZ employees or will the
Company contract with other parties to perform some or all of the work required? Will Meter
Readers be involved in the installation of meters? If so, what impact will that have on Meter
Reader's normal duties, including their ability to read meters in a timely fashion?
REQUEST NO. 37: For each month in CY 2016,2017 and 2018, please provide: (a)
the total number of estimated bills provided to customers; and (b) the reason for the estimate.
SECOND PRODUCTION REQUEST
TO SUEZ WATER 4 JANUARY 24,2019
REQUEST NO. 38: How many customers received two or more consecutive estimated
bills at any time during the period of 0l/01/16 and l2l3ll18? What steps can the Company take
to minimize the number of estimated bills?
REQUEST NO. 39: Please provide the Company's Customer Service Call Center
performance objectives (measures and goals) for handling incoming calls. What steps does the
Company take if it fails to meet its performance objectives?
REQUEST NO. 40: Please provide the number of incoming calls handled by the
Customer Service Call Center by month for CY 2016,2017 and 2018.
REQUEST NO. 41: Please provide the service level for SUEZ Water Idaho's Customer
Service Call Center by month for CY 2016,2017 and 2018. ooSeryice level" is the percentage of
calls answered within a certain number of seconds, e.g., 80oh of calls answered within 20
seconds.
REQUEST NO. 42: Please provide the hours of operation for the Customer Service Call
Center. Please explain how the Company handles all after-hours calls. How does the person
handling after-hours calls determine what constitutes an emergency requiring immediate dispatch
of a SUEZ employee?
REQUEST NO. 43: Please provide the Company's Customer Service Center
performance objectives for responding to written correspondence, including emails. What steps
does the Company take if it fails to meet its performance objectives?
REQUEST NO. 44: For 2016,2017 and 2018 by typelcategory of complaint, please
provide the number of complaints received by the Company directly from a customers or other
interested parties.
SECOND PRODUCTION REQUEST
TO SUEZ WATER 5 JANUARY 24,2019
REQUEST NO. 45: Does SUEZ Water Idaho plan to allow Eagle Water Company
customers to sign up for Budget Billing or participate in its Leak Adjustment or SUEZ Cares
Program at the time the purchase is approved? If so, what conditions will the Company place on
the ability of customer's to sign up/participate?
REQUEST NO. 46: Please provide the justification for charging anyone who, after the
sale, establishes a new customer account within the former Eagle Water Company service
territory the same rate as current SUEZ customers rather than the incremental rates being
proposed for Eagle Water customers who had service prior to the sale. See Thompson Direct
at9.
REQUEST NO. 47: Does SUEZ consider administrative actions such as removing,
adding or otherwise changing names or mailing addresses on an account due to divorce, death, or
some other reason to be "establishing a new account"?
Dated at Boise, Idaho, this /4 n
ourof January 2019.
Sean Costello
Deputy Attorney General
i:umisc:prodreq/suzwl8.2_eagwlS.lsctnc prod req2 to SUEZ
SECOND PRODUCTION REQUEST
TO SUEZ WATER 6 JANUARY 24,2019
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24th DAY OF JANUARY 2019, SERVED
THE FOREGOTNG SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
TO SUEZWATERIDAHOINC., IN CASE NOS. SUZ-W-I8-02/EAG-W-18-01, By
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GIVENS PURSLEY LLP
60I W. BANNOCK ST.
BOISE, TD 83702
E-MAIL : rncc(.D givenspurslcy. com
MARSHALL THOMPSON
SUEZ WATER IDAHO, INC.
8248 W. VICTORY RD.
BOISE,IDAHO 83709
E-MAIL : rnarshall. thonr pson(?.suez.com
N.L. BANGLE
H2O EAGLE ACQUISTION, LLC
I88 W. STATE ST.
EAGLE, IDAHO 83716
E-MAIL : rT ban gle@h2o-solutionsl lc.net
CHERESE D. MoLAIN
MSBT LAW, CHTD.
7699 W RIVERSIDE DR
BOISE ID 837I4
E-MAIL: cdm(D.msbtlaw.com
JAMES M PIOTROWSKI
PIOTROWSKI DURAND PLLC
1O2O W. MAIN STREET, SUITE 440
PO BOX 2864
BOISE ID 83701
E-MAIL : i ames(/)iclunionlai,v.corn
NORMAN M SEMANKO
PARSON BEHLE & LATIMER
8OO W MAIN STREET, SUITE 13OO
BOISE ID 83709
E-MAIL: nsemanko(#)parsonsbehle.com
ec t't, d)parsclns behl e. sorn
.conl
ROBERT DESHAZO
EAGLE WATER COMPANY, INC.
I88 W. STATE ST.
EAGLE, IDAHO 83616
E-MAIL: eaglew'aterco @.smail.corn
MOLLY O'LEARY
BIZCOUNSELOR AT LAW PLLC
1775W STATE STREET, #150
BOISE TD 83702
E-MAIL: rnolly@)bizcounselolatlaw.com
MAYOR STAN RIDGWAY
CITY OF EAGLE
660 E CIVIC LANE
EAGLE ID 83616
E-MAIL : sri d gewayr,?=q,ci tyot'eagle. org
sber q rn ann (d)c i tyo {b a gl e. clr g
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdv(dhotmail.com
CERTIFICATE OF SERVICE
ABIGAIL R GERMAINE
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
I50 N. CAPITOL BLVD.
PO BOX 500
BOISE ID 83701-0500
E-MAIL : agerrnaine({ijcityofboise.org
SECRETARY
CERTIFICATE OF SERVICE