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Home My WebLink About20190214Suez to Staff Attachments - Redacted.pdfRESPONSE TO STAFF PRODUCTION REQUEST NO. 21 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 21: The tables included in SUEZ testimony are produced to Staff on compact disc with formulas intact. Attached please find the excel file labeled Response to Production Request 21 – Exhibit A.xlsx, which contains the exhibits mentioned in Jarmila Cary’s testimony. Exhibit No. 1 Case No. SUZ-W-18-02J. Cary, SUEZSchedule 1a IPUC Capital Capital Capital Annual Investment Investment InvestmentLineReportRevisedRequiredChangeRevisedRequiredChangeRevisedRequired Change RevisedNo.Description 2017 Adjust 2017 Year 1 Year 1 Year 1 Year 2 Year 2 Year 2 Year 3 Year 3 Year 3 1 Operating Revenue 760,105 760,105 760,105 760,105 760,105 Operating Expenses: 2 Labor 279,150 279,150 90,000 369,150 369,150 369,1503Purchased Water 0 0 0 0 0 4 Power Purchased for Pumping 161,279 161,279 2,000 163,279 163,279 163,2795Chemicals0024,000 24,000 24,000 24,000 6 Materials & Supplies 65,905 65,905 17,750 83,655 83,655 83,6557Contract Services 41,067 41,067 25,000 66,067 66,067 66,067 8 Rentals- Property & Equipment 10,450 10,450 10,450 10,450 10,4509Transportation Expense 25,201 25,201 25,201 25,201 25,201 10 Insurance 20,120 20,120 20,120 20,120 20,12011Advertising00000 12 Rate Case Expense (Amortization)1,879 1,879 1,879 1,879 1,87913Regulatory Comm. Exp. (Other except taxes)13,239 13,239 13,239 13,239 13,239 14 Bad Debt Expense 0 0 - - - 15 Miscellaneous 6,812 6,812 6,812 6,812 6,812 16 Amortization Remediation Costs 0 0 0 0 017Other O&M Expenses 0 0 0 0 0 18 Operating & Maintenance Expense 625,102 0 625,102 0 158,750 783,852 0 0 783,852 0 0 783,852 19 Depreciation & Amortization Expense 65,276 65,276 81,000 174,951 201,240 376,191 118,500 494,69120Gross Receipts Tax 0 0 0 021Franchise Tax 6,047 6,047 6,047 6,047 6,04722Property, Payroll, Excise and Other Taxes 59,401 59,401 59,401 59,401 59,401 23 Total Operating Expenses Before Income Taxes 755,826 0 755,826 81,000 158,750 1,024,251 201,240 0 1,225,491 118,500 0 1,343,991 24 Operating Income Before Income Taxes 4,279 0 4,279 (264,146)(201,240)0 (465,386)(118,500)0 (583,886)25 State Income Taxes 227 227 (25,145)(55,978)(74,134) 26 Federal Income Taxes 0 0 (70,971)(157,997)(209,243)27 Deferred Federal Income Taxes 0 0 0 0 0 28 Operating Income $4,052 $0 $4,052 $0 $0 ($168,030)($201,240)$0 ($251,411)($118,500)$0 ($300,510) 29 Interest Expense $587 $0 $0 $0 $0 $98,957 $244,004 $0 $342,960 $143,681 $0 $486,641 30 Utility Plant in Service 3,131,715 3,131,715 2,700,000 5,831,715 6,708,000 12,539,715 3,950,000 16,489,715 31 Accumulated Amortization (59,306)(59,306)(59,306)(59,306)(59,306) 32 Accumulated Depreciation (1,204,144)(1,204,144)(81,000)(1,285,144)(201,240)(1,486,384)(118,500)(1,604,884)33 Net Plant 1,868,265 1,868,265 2,619,000 4,487,265 6,506,760 10,994,025 3,831,500 14,825,525 34 Contributions in Aid of Construction (3,155,195)(3,155,195)(3,155,195)(3,155,195)(3,155,195)35 Customer Advances for Construction 0 0 0 0 0 36 Accumulated Deferred Income Taxes 0 0 0 0 037Materials and Supplies 0 0 0 0 0 38 Prepaid Expenses 0 0 0 0 039Working Capital (1/8th O&M Expenses)78,138 78,138 97,982 97,982 97,982 40 Unamortized bond discount 0 0 0 0 041Rate Base Adj. - set Rate Base to -0-0 1,208,792 1,208,792 1,208,792 1,208,792 1,208,792 42 Other Rate Base Items 0 0 0 0 0 43 Rate Base ($1,208,792)$1,208,792 $0 $2,619,000 $0 $2,638,844 $6,506,760 $0 $9,145,604 $3,831,500 $0 $12,977,104 44 Rate of Return -0.34%0.00%0.00%-6.37%-3.09%-2.75%-0.47%-2.32% 45 Required Rate of Return 8.50%8.50%8.50%8.50%8.50%8.50%8.50%8.50%8.50%8.50%8.50%8.50% 46 Required Net Operating Income ($102,747)$102,747 $0 $222,615 $0 $224,302 $553,075 $0 $777,376 $325,678 $0 $1,103,054 47 Operating Income Deficiency (106,799)$ 102,747$ (4,052)$ 222,615$ -$ 392,332$ 754,315$ -$ 1,028,787$ 241,038$ 33,914$ 1,403,564$ 48 Gross Revenue Conversion Factor 1.369970 1.369970 1.369970 1.369970 1.369970 1.369970 1.369970 1.369970 1.369970 1.369970 1.369970 1.369970 49 Revenue Deficiency (Overage)($146,312)$140,761 ($5,551)$304,976 $0 $537,483 $1,033,388 $0 $1,409,407 $330,214 $46,461 $1,922,839 50 Long Term Debt Ratio 50.00%50.00%50.00%50.00%50.00%50.00%50.00%50.00%50.00%50.00%50.00%50.00% 51 Common Equity Ratio 50.00%50.00%50.00%50.00%50.00%50.00%50.00%50.00%50.00%50.00%50.00%50.00%52 Total Capital 100.00%100.00%100.00%100.00%100.00%100.00%100.00%100.00%100.00%100.00%100.00%100.00% 53 Long Term Debt Cost - Estimated 7.50%7.50%7.50%7.50%7.50%7.50%7.50%7.50%7.50%7.50%7.50%7.50%54 Common Equity Cost - Estimated 9.50%9.50%9.50%9.50%9.50%9.50%9.50%9.50%9.50%9.50%9.50%9.50% 55 Long Term Debt Weighted Avg. Cost 3.75%3.75%3.75%3.75%3.75%3.75%3.75%3.75%3.75%3.75%3.75%3.75% 56 Common Equity Weighted Avg. Cost 4.75%4.75%4.75%4.75%4.75%4.75%4.75%4.75%4.75%4.75%4.75%4.75%57 Total Capital - Weighter Avg. Cost 8.50%8.50%8.50%8.50%8.50%8.50%8.50%8.50%8.50%8.50%8.50%8.50% Gross Revenue Conversion Factor 59 Net Deficiency 100.0000% 60 Less IPUC Assessment Rate 0.2275%61 Less Uncollectible Accounts Expense 0.5000% 62 Total 0.7275% 63 State Tax Rate 6.9250% 64 Effective State Tax Rate State Income Tax * Deficiency 6.8746% 65 Federal Income Tax Rate 21.0000% 66 Effective Federal Tax Rate Federal Income Tax * Deficiency 19.4036% 67 Net After Tax 72.9943% 68 Composite - IPUC Fees, Uncollectible, Income Taxes 27.0057% 69 Composite Residual 72.9943% 70 Net to Gross Multiplier 136.9970% Projected Eagle Water Operating Costs and Revenue Deficiency Exhibit No. 1 Case No. SUZ-W-18-02 J. Cary, SUEZ Schedule 1b Projected Impact to Average Eagle Water Customer (using existing Eagle Water tariff structure) for the Revenue Deficiency calculated in Exhibit 1 Schedule 1a and Average Customer Bill shown in Schedule 2 Average Residential Bill Average Commmercial Bill 12.350$ 38.955$ Existing Avg. Bill 31.242$ 98.545$ Increase Increase over 2017 actual revenues using avg. calculated bill 252.97%43.592$ 137.500$ New Rates 12.350$ 38.955$ Existing Avg. Bill Increase over existing Eagle Water tariff using avg. calculated bill 255.55%31.560$ 99.550$ Increase Exhibit No. 1 Case No. SUZ-W-18-02 J. Cary, SUEZSchedule 2 SUEZ Proposed Rate Phase In for Eagle Water 50%75%100% 100 cubic feet or CCF Summer Tariff Rate 0.4510$ 1.8577$ Winter Tariff Rate 0.4510$ 1.4674$ change over 2017 EWC actual revenue 233% Per 3CCF Per 1 CCF Rate for first 3 CCF (winter & summer)600CF or less 7.84$ 3.92$ 1.307$ 1.4674$ change over existing EWC rates per calculated avg. bill 235% Over 600 CF per 100 CF 0.4510$ Total Annual Impact (Residential & Commercial)507,937$ Total Annual Impact (Residential & Commercial)630,183$ Total Annual Impact (Residential & Commercial)630,183$ Grand Total 1,768,304$ Residential Customer 3/4" Meter 3CCF in Summer at Winter Rate Annual Increase 270,588$ Annual Increase 394,644$ Annual Increase 394,644$ Monthly Increase 6.44$ Monthly Increase 9.40$ Monthly Increase 9.40$ Winter/Summer Consumption 30%70%(Based on 2017 consumption by month avg.) 3/4" Meter - Monthly 7.84$ 10.56$ CCF allowed 6 Over 6CCF 0Customers3,500 Monthly Consumption (CCF Hundred Cubic Feet) Fixed Winter Summer Total Calculated Annual Fixed Winter Summer Total Rate Calculated Annual Fixed Winter Summer Total Rate Calculated Fixed Winter Summer Total Rate Calculated 6 7.84$ -$ -$ 7.84$ 5.28$ 1.32$ 3.49$ 10.09$ 29%7.92$ 1.98$ 5.24$ 15.13$ 50%10.56$ 2.64$ 6.98$ 20.18$ 33%10 7.84$ 0.54$ 1.26$ 9.64$ 5.28$ 2.20$ 6.09$ 13.57$ 41%7.92$ 3.30$ 9.14$ 20.36$ 50%10.56$ 4.40$ 12.18$ 27.14$ 33%16 7.84$ 1.35$ 3.16$ 12.35$ 518,700$ 5.28$ 3.52$ 9.99$ 18.79$ 52%789,288$ 7.92$ 5.28$ 14.99$ 28.19$ 50%1,183,932$ 10.56$ 7.04$ 19.99$ 37.59$ 33%1,578,575$ 204.33% 20 7.84$ 1.89$ 4.42$ 14.15$ 5.28$ 4.40$ 12.59$ 22.27$ 57%7.92$ 6.60$ 18.89$ 33.41$ 50%10.56$ 8.80$ 25.19$ 44.55$ 33%30 7.84$ 3.25$ 7.58$ 18.66$ 5.28$ 6.60$ 19.10$ 30.98$ 66%7.92$ 9.90$ 28.64$ 46.47$ 50%10.56$ 13.21$ 38.19$ 61.95$ 33% 40 7.84$ 4.60$ 10.73$ 23.17$ 5.28$ 8.80$ 25.60$ 39.68$ 71%7.92$ 13.21$ 38.40$ 59.52$ 50%10.56$ 17.61$ 51.20$ 79.36$ 33% 50 7.84$ 5.95$ 13.89$ 27.68$ 5.28$ 11.01$ 32.10$ 48.38$ 75%7.92$ 16.51$ 48.15$ 72.57$ 50%10.56$ 22.01$ 64.20$ 96.77$ 33%60 7.84$ 7.31$ 17.05$ 32.19$ 5.28$ 13.21$ 38.60$ 57.09$ 77%7.92$ 19.81$ 57.90$ 85.63$ 50%10.56$ 26.41$ 77.20$ 114.17$ 33% 70 7.84$ 8.66$ 20.20$ 36.70$ 5.28$ 15.41$ 45.10$ 65.79$ 79%7.92$ 23.11$ 67.66$ 98.68$ 50%10.56$ 30.82$ 90.21$ 131.58$ 33%80 7.84$ 10.01$ 23.36$ 41.21$ 5.28$ 17.61$ 51.61$ 74.49$ 81%7.92$ 26.41$ 77.41$ 111.74$ 50%10.56$ 35.22$ 103.21$ 148.98$ 33%90 7.84$ 11.37$ 26.52$ 45.72$ 5.28$ 19.81$ 58.11$ 83.20$ 82%7.92$ 29.71$ 87.16$ 124.79$ 50%10.56$ 39.62$ 116.22$ 166.39$ 33% 100 7.84$ 12.72$ 29.68$ 50.23$ 5.28$ 22.01$ 64.61$ 91.90$ 83%7.92$ 33.02$ 96.91$ 137.85$ 50%10.56$ 44.02$ 129.22$ 183.80$ 33%500 7.84$ 66.84$ 155.96$ 230.63$ 5.28$ 110.06$ 324.69$ 440.02$ 91%7.92$ 165.08$ 487.03$ 660.03$ 50%10.56$ 220.11$ 649.38$ 880.04$ 33%1000 7.84$ 134.49$ 313.81$ 456.13$ 5.28$ 220.11$ 649.79$ 875.17$ 92%7.92$ 330.17$ 974.68$ 1,312.76$ 50%10.56$ 440.22$ 1,299.57$ 1,750.35$ 33% 3CCF in Summer at Winter Rate Annual Increase 237,349$ Annual Increase 235,540$ Annual Increase 235,540$ Monthly Increase 39.56$ Monthly Increase 39.26$ Monthly Increase 39.26$ 15%85%(Based on 2017 consumption by month avg.) 14.15$ 23.09$ 20 Over 20CCF 0 Fixed Summer Total Calculated Annual Fixed Winter Summer Total Rate Calculated Annual Fixed Winter Summer Total Rate Calculated Fixed Winter Summer Total Rate Calculated 20 14.15$ -$ -$ 14.15$ 11.54$ 2.20$ 15.29$ 29.04$ 105%17.31$ 3.30$ 22.94$ 43.55$ 50%23.09$ 4.40$ 30.59$ 58.07$ 33%30 14.15$ 0.68$ 3.83$ 18.66$ 11.54$ 3.30$ 23.19$ 38.03$ 104%17.31$ 4.95$ 34.78$ 57.05$ 50%23.09$ 6.60$ 46.38$ 76.06$ 33% 40 14.15$ 1.35$ 7.67$ 23.17$ 11.54$ 4.40$ 31.08$ 47.03$ 103%17.31$ 6.60$ 46.62$ 70.54$ 50%23.09$ 8.80$ 62.17$ 94.06$ 33%50 14.15$ 2.03$ 11.50$ 27.68$ 11.54$ 5.50$ 38.98$ 56.02$ 102%17.31$ 8.25$ 58.47$ 84.04$ 50%23.09$ 11.01$ 77.96$ 112.05$ 33% 75 14.15$ 3.72$ 21.08$ 38.96$ 233,730$ 11.54$ 8.25$ 58.72$ 78.51$ 102%471,079$ 17.31$ 12.38$ 88.07$ 117.77$ 50%706,619$ 23.09$ 16.51$ 117.43$ 157.03$ 33%942,158$ 303.10% 60 14.15$ 2.71$ 15.33$ 32.19$ 11.54$ 6.60$ 46.87$ 65.02$ 102%17.31$ 9.90$ 70.31$ 97.53$ 50%23.09$ 13.21$ 93.75$ 130.04$ 33%70 14.15$ 3.38$ 19.17$ 36.70$ 11.54$ 7.70$ 54.77$ 74.02$ 102%17.31$ 11.56$ 82.15$ 111.02$ 50%23.09$ 15.41$ 109.54$ 148.03$ 33% 80 14.15$ 4.06$ 23.00$ 41.21$ 11.54$ 8.80$ 62.66$ 83.01$ 101%17.31$ 13.21$ 94.00$ 124.52$ 50%23.09$ 17.61$ 125.33$ 166.02$ 33%90 14.15$ 4.74$ 26.83$ 45.72$ 11.54$ 9.90$ 70.56$ 92.01$ 101%17.31$ 14.86$ 105.84$ 138.01$ 50%23.09$ 19.81$ 141.12$ 184.01$ 33%100 14.15$ 5.41$ 30.67$ 50.23$ 11.54$ 11.01$ 78.45$ 101.00$ 101%17.31$ 16.51$ 117.68$ 151.50$ 50%23.09$ 22.01$ 156.91$ 202.01$ 33% 500 14.15$ 32.47$ 184.01$ 230.63$ 11.54$ 55.03$ 394.26$ 460.83$ 100%17.31$ 82.54$ 591.40$ 691.25$ 50%23.09$ 110.06$ 788.53$ 921.67$ 33%1000 14.15$ 66.30$ 375.68$ 456.13$ 11.54$ 110.06$ 789.02$ 910.62$ 100%17.31$ 165.08$ 1,183.54$ 1,365.93$ 50%23.09$ 220.11$ 1,578.05$ 1,821.24$ 33%2000 14.15$ 133.95$ 759.03$ 907.13$ 11.54$ 220.11$ 1,578.55$ 1,810.20$ 100%17.31$ 330.17$ 2,367.82$ 2,715.30$ 50%23.09$ 440.22$ 3,157.09$ 3,620.40$ 33% YEAR ONE YEAR TWO YEAR THREE Eagle Water Company Rates Exhibit No. 1 Case No. SUZ-W-18-02 J. Cary, SUEZ Schedule 3 Percentage of SUEZ Tariff 50%75%100% SCHEDULE 1D GENERAL METERED SERVICE: EAGLE WATER SERVICE AREA Volume Charges Per 100 cubic feet or 1CCF (748 gallons)600CF or less 7.8400$ For all water used less than 3CCF (per CCF)0.7337$ 1.1006$ 1.4674$ Over 600CF (per 100CF=1CCF)0.4510$ Winter Rate (Oct 1 - Apr 30) greater than 3CCF 0.7337$ 1.1006$ 1.4674$ Summer Rate (May 1 - Sep 30) greater than 3CCF 0.9289$ 1.3933$ 1.8577$ Meter Charge CF allowed Monthly Monthly Monthly Monthly SCHEDULE 3A PRIVATE FIRE SPRINKLER AND SERVICE: EAGLE WATER SERVICE AREA Private Fire Monthly Monthly Monthly Monthly SCHEDULE 1E FLAT RATE SERVICE: EAGLE WATER SERVICE AREA Non-Metered Monthly Monthly Monthly Monthly IDEQ Drinking water fee (per potable connection) $0.33 per month, $4.00 annually $0.50 bi-monthly, $3.00 annually 0.25$ 0.25$ 0.25$ Eagle Franchise fee - within City limits 1%1%1%1% Disconnection - business hours 15.00$ 20.00$ 20.00$ 20.00$ Disconnection - non business hours 30.00$ 30.00$ 30.00$ 30.00$ Wholesale rate - Eagle Point Subdivision (consolidated billing) Wholesale Countryside Estates Order 29113 New Connection hookup fee 845.00$ N/A N/A N/A Original hookup fee 245.00$ N/A N/A N/A Engineering Study 100.00$ N/A N/A N/ANew Well 500.00$ N/A N/A N/A 48.075%N/A N/A N/A EAGLE WATER COMPANY TARIFF Surcharge for usage greater than 600 CF per month 2/23/2009 - 2/22/2016 SUEZ TARIFF PHASE-IN YEAR 1 PHASE-IN YEAR 2 PHASE-IN YEAR 3 Order 37074 was effective June 1, 2018 Order 30734 was effective February 23, 2009 Exhibit No. 1 Case No. SUZ-W-18-02 J. Cary, SUEZ Schedule 4 Eagle Water % Water Sold by month - per billing reports (shown in cubic feet) Residential CF 2016 CF 2017 Dec 1,952,184 2.51%2,043,140 2.75% Nov 2,017,908 2.59%2,280,128 3.07% Oct 3,581,554 4.60%9,399,751 12.64% Sep 8,027,681 10.32%9,010,590 12.12% Aug 15,653,394 20.12%13,660,614 18.37% Jul 12,942,331 16.64%12,781,355 17.19% Jun 12,553,436 16.14%10,174,248 13.69%Summer Consumption - May - Sept. May 8,252,439 10.61%6,655,373 8.95%70% Apr 6,419,522 8.25%3,113,036 4.19% Mar 2,681,945 3.45%1,925,601 2.59% Feb 2,043,829 2.63%1,487,826 2.00%Winter Consumption Oct. - Apr. Jan 1,658,138 2.13%1,812,603 2.44%30% Total 77,784,361 100.00%74,344,265 100.00% Commercial (Combined by Meter Code 07=3/4", 10,=1" 15=1.5", 20=2", 30=3", 40=4")CF CF CF CF CF CF Meter Code >07 2017 10 2017 15 2017 20 2017 30 2017 40 2017 AverageDec26,952 1.04%122,824 3.53%493,504 3.47%329,162 4.34%54,261 4.04%4,115 0.18%2.77% Nov 7,926 0.30%84,414 2.43%411,357 2.90%368,718 4.87%93,328 6.95%7,673 0.34%2.97% Oct 119,529 4.59%221,878 6.38%475,935 3.35%(4,521,083) -59.66%62,473 4.66%25,604 1.15%-6.59% Sep 494,103 18.99%530,060 15.25%2,174,151 15.30%1,569,478 20.71%111,516 8.31%70,888 3.17%13.62% Aug 561,889 21.59%579,612 16.68%2,493,864 17.55%2,368,917 31.26%206,269 15.37%607,086 27.17%21.60% Jul 552,654 21.24%549,479 15.81%2,442,542 17.19%2,131,534 28.13%202,863 15.12%625,042 27.98%20.91% Jun 375,383 14.42%591,649 17.02%2,127,151 14.97%2,068,536 27.30%174,859 13.03%462,846 20.72%17.91%Summer Consumption - May - Sept. May 202,926 7.80%327,222 9.42%1,262,896 8.89%1,234,316 16.29%124,988 9.31%365,480 16.36%11.34%85% Apr 118,240 4.54%186,407 5.36%799,588 5.63%799,421 10.55%141,716 10.56%46,411 2.08%6.45% Mar 53,828 2.07%94,830 2.73%506,822 3.57%337,089 4.45%68,854 5.13%7,558 0.34%3.05% Feb 41,943 1.61%93,125 2.68%524,177 3.69%584,066 7.71%52,371 3.90%5,351 0.24%3.30%Winter Consumption Oct. - Apr. Jan 47,106 1.81%93,841 2.70%495,861 3.49%308,084 4.07%48,407 3.61%6,081 0.27%2.66%15%2,602,479 100.00%3,475,341 100.00%14,207,848 100.00%7,578,238 100.00%1,341,905 100.00%2,234,135 100.00%1 Exhibit No. 1 Case No. SUZ-W-18-02 J. Cary, SUEZ Schedule 5 Comparison of Eagle Water & SUEZ 2017 Year End Bills and Consumption - per Average Customer SUEZ 2014 2015 2016 2017 2018 (April)2017 Customers (year end)3,546 3,573 3,835 3,908 4,046 Residential 3,089 3,110 3,357 3,418 3,535 81,864 Commercial 454 460 475 490 511 8,988 % commercial 13%13%12%13%13% % growth 1%7%2%4% Revenue Residential 532,972$ 569,067$ 573,291$ 518,494$ 32,926,000$ Commercial 233,100$ 216,515$ 247,932$ 234,316$ 14,292,000$ Avg. Annual Customer Bill Residential 173$ 183$ 171$ 152$ 402$ Commercial 513$ 471$ 522$ 478$ 1,590$ Total Consumption (Gallons)866,845,807 887,260,426 863,624,703 791,265,898 13,754,804,000 Residential 584,139,549 546,434,308 581,827,020 556,095,102 8,901,690,000 Commercial 282,706,258 340,826,118 281,797,683 235,170,796 4,853,114,000 Total Consumption (CFs)115,888,477 118,617,704 118,617,704 105,784,211 1,838,877,540 Residential 78,093,523 73,052,715 77,784,361 74,344,265 1,190,065,508 Commercial 37,794,954 45,564,989 37,673,487 31,439,946 648,812,032 Avg. Annual Consumption (CFs) per Customer Residential 25,281 23,490 23,171 21,751 14,537 Commercial 83,249 99,054 79,313 64,163 72,186 Avg Annual CCF per customer Residential 253 235 232 218 145 Commercial 832 991 793 642 722 Avg Annual Gallons per customer Residential 189,103 175,702 173,318 162,696 108,738 Commercial 622,701 740,926 593,258 479,940 539,955 1 CF cubic foot = 7.48 Gallons EAGLE RESPONSE TO STAFF PRODUCTION REQUEST NO. 22 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 22: The $1,875.00 portion of the Givens Pursley legal invoice number 195392 provided in Production Request Response No. 11 Exhibit L, is for professional fees for legal consultation services provided to Givens Pursley LLP by Mr. Dean J. Miller concerning the preparation and filing of SUEZ’s Joint Application and Direct Testimony in this proceeding and concerning the ongoing Idaho Public Utilities Commission proceedings. A copy of Mr. Miller’s invoice in the amount of $1,875.00 is produced as Response to Production Request 22 – Exhibit A. RESPONSE TO STAFF PRODUCTION REQUEST NO. 23 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Cathy Cooper, Director of Engineering, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 23: Information collected, generated and/or reviewed by SUEZ as part of its asset purchase due diligence is included in the exhibit attached to this response and included on the compact disk produced contemporaneously herewith, portions of which have been designated by SUEZ as Confidential and subject to the Protective Agreement among the parties. RESPONSE TO STAFF PRODUCTION REQUEST NO. 24 - PAGE 1 OF 3 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila M. Cary, Director of Finance, SUEZ Water Idaho Inc. REQUEST NO. 24: Please explain how SUEZ Water Idaho was able to determine that the purchase price represents a “fair value” of the assets to be purchased as referenced in Section XI, on page 5 of the Application. Please provide all supporting documents and workpapers. RESPONSE: Fair value is the estimated price at which an asset can be sold in an orderly transaction to a third party under current market conditions, what a willing buyer would pay a willing seller for a given asset, assuming both have a reasonable knowledge of the asset's worth. The value of Eagle Water assets to SUEZ was evaluated before and during the due diligence process and has been discussed in the Direct Testimony of Marshall Thompson and in SUEZ’s First Production Request Response No. 5. In its response, SUEZ stated that it believed the $10M purchase price was justified by the substantial avoided and deferred capital investment SUEZ expects to achieve if the purchase is approved. SUEZ also evaluated the purchase price with reference to the City of Eagle’s 2007 purchase attempt based on an opinion expressed by the City’s Certified Public Accounting Firm, Cooper and Norman, indicating a “reasonable and fair” value of Eagle Water Company of $6,300,000 plus financing cost. SUEZ believes Eagle Water Company served approximately 3,450 customers at that time. Reference has also been made by SUEZ to a November 2007 City of Eagle website Question and Answer page concerning its contemplated purchase of Eagle Water Company and creation of a Local Improvement District to finance the purchase. In that Q&A page, the City indicated that a 2002 valuation performed by JUB Engineering based on a “Replacement Cost Depreciated Method” produced an estimated asset value of $6,728,593.00. SUEZ also believed the purchase price to be reasonable, and fair, based on the relative investment per customer it represents. CPA review of purchase price is file Response to Production Request 24 – Exhibit A.pdf RESPONSE TO STAFF PRODUCTION REQUEST NO. 24 - PAGE 2 OF 3 JUB Eng. valuation reference is in file Response to Production Request 24 – Exhibit B.pdf at pg. 4 of 4. Commission Staff noted improper accounting as a result of its audits of Eagle Water Company and as noted in Staff Comments January 16, 2019 in Case EAG-W-15-01 Page 2 “Staff discovered that the Company (referring to EWC) had incorrectly expensed capital improvements, commingled funds between its regulated and unregulated operations, and has negative rate base resulting in over-earnings during 2015-2017.” The Joint Settlement Stipulation Order 34225 also provides for a “one-time elimination of negative rate base in 2008 by reducing $1,236,375 in year 2008 contributions in aid of construction”. Because the books and records of Eagle Water Company have not accurately reflected the historical value of its assets due to accounting inconsistencies as noted by Staff, SUEZ relied on its due diligence investigation, in addition to the considerations outlined in SUEZ’s Production Response No. 5, to determine a fair value for Eagle Water assets. Through an arm’s length negotiation with H2O Acquisitions, a mutually acceptable purchase price was established. The negotiated purchase price and estimated value of the Eagle Water system assets to SUEZ was substantiated by the avoided capital investment as outlined in Ms. Cooper’s Direct Testimony starting on page 5. Including the $10M Eagle Water purchase acquisition price, SUEZ estimates that $11.7M of additional planned capital investment would be avoided or deferred, while addressing the supply needs in the northwest area of the SUEZ system faster. In that respect, the value of the Eagle Water system acquisition to SUEZ could be valued up to $21.7M. For comparison, the SUEZ acquisition price of the South County Water Company system in 1998 was $761 per customer, not adjusted for inflation, as referenced in case UWI-W-98-2 Mr. Linam’s testimony pages 6-8. In SUEZ’s 2015 general rate case no. UWI-W-15-01, SUEZ’s system investment at the time was approximately $1,924 per customer. SUEZ’s $10M Eagle Water proposed purchase price represents an approximate investment per customer of $2,380. In RESPONSE TO STAFF PRODUCTION REQUEST NO. 24 - PAGE 3 OF 3 comparison, recent SUEZ small system acquisitions in New Jersey and Pennsylvania areas averaged between $3,000 and $5,000 investment per customer. A higher level analysis estimating the value of Eagle Water Company assets also has been prepared and is being produced in file Response to Production Request 24 – Exhibit C.xlsx. This analysis is based on today’s SUEZ average cost for installing facilities similar to Eagle Water Company’s infrastructure assets. Those values were discounted using the Handy Whitman cost trend for the Plateau Region according to the actual or estimated vintage year, and then depreciated. The analysis has been designated as CONFIDENTIAL – SUBJECT TO PROTECTIVE AGREEMENT and is produced separately. RESPONSE TO STAFF PRODUCTION REQUEST NO. 25 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Cathy Cooper, Director of Engineering, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 25: Under the federal Safe Drinking Water Act, 42 U.S.C. § 300f et seq. (1974) the Environmental Protection Agency has promulgated regulations requiring all owners or operators of public water systems such as the Eagle Water Company and SUEZ systems to comply with standards to protect the quality of drinking water. To SUEZ’s knowledge, Eagle Water Company currently meets all such water quality standards for public drinking water systems under this program. Unrelated to water quality are other state requirements that Eagle Water Company does not currently meet and which have been previously detailed in SUEZ’s Response to Staff’s Production Request Nos. 9, 10 and 18. RESPONSE TO STAFF PRODUCTION REQUEST NO. 26 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Cathy Cooper, Director of Engineering, SUEZ Water Idaho Inc. PRODUCTION REQUEST NO. 26: In Attachments 3 and 4 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. RESPONSE TO PRODUCTION REQUEST NO. 26: Consistent with operations of SUEZ’s wells, SUEZ would use 12.5% liquid sodium hypochlorite at each well house to provide disinfection. The chlorination system will include a small storage tank, a containment basin, and a dosing pump added at each well house. The sodium hypochlorite is dosed into the discharge pipeline at each well house through an injection quill, with the dosage controlled by the flow rate from the well. SUEZ targets a chlorine residual leaving the well house of 0.8 to 1.0 mg/l. RESPONSE TO STAFF PRODUCTION REQUEST NO. 27 - PAGE 1 OF 4 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Cathy Cooper, Director of Engineering, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 27: a. Current Rate Structure Isn’t Sustainable and Doesn’t Support Regular System Upgrades To SUEZ’s knowledge, Eagle Water has not made any capital investments over $50,000 in the last three years. As PUC staff knows, this has a circular effect. Zero capital investment results in no allowance for a rate increase, perpetuating a cycle of Eagle Water Company not being able to pay for reasonable and necessary system upgrades. Further, a review of Eagle Water Company’s history of owner investment in the system versus its accumulated depreciation demonstrates a non-optimal capital RESPONSE TO STAFF PRODUCTION REQUEST NO. 27 - PAGE 2 OF 4 investment strategy over many years. The calculated negative rate base of $1,208,792 as of December 2017 indicates that the long-term capital investment needs of the system are not being met under current conditions. In addition, Eagle Water’s reliance on emergency surcharges, most recently from 2009 through 2016, is indicative of how stressful reactive repairs have been for this water system. Responding to urgent repairs is part of utility operations, but it should not become an immediate funding obligation to customers. In contrast, SUEZ invested net capital expenditures for system upgrades of $11,675,000 in 2016, $19,621,000 in 2017 and $16,538,000 in 2018. SUEZ plans net capital expenditures for system upgrades of more than $20M per year for upcoming budget years. b. Replace Meters SUEZ believes the cost-benefit analysis supporting the installation of new automated meters for Eagle Water Company customers is fully addressed in SUEZ’s Response to Staff Production Request No. 15. c. Upgrade Generators The Idaho Department of Environmental Quality requires that during a power outage a water system must be able to provide average day demand for 8 hours plus fire flow. SUEZ has determined that Eagle Water Company is currently short on generator capacity by 425 gpm (detailed in SUEZ’s Response to Staff Production Request No. 9) to meet this requirement. RESPONSE TO STAFF PRODUCTION REQUEST NO. 27 - PAGE 3 OF 4 In addition, older generators can be unreliable in emergency situations. The Eagle Water Company Well 7 generator appears to have been manufactured in 1972 or 1973. This generator would be upgraded. d. Add Critical System Disinfection The need and benefits for system disinfection are addressed in SUEZ’s Response to Staff Production Request No. 10. Chlorination has many benefits for any system. Chlorine maintains sanitary conditions by neutralizing any microbial contamination that may enter a water system from a backflow or leak. Chlorine also serves as an indicator for system operators of potential contamination since a sudden decline in chlorine residual can be easily and quickly measured in the field. Chlorine residual is a low level of chlorine that remains in the water after its initial application that provides a safeguard against risks of subsequent microbial contamination. e. Ensure Adequate Fire Protection Eagle Water Company currently has a redundant fire pumping capacity shortfall of 1,375 gpm. The $7.014M in projects to benefit Eagle Water customers that SUEZ would complete to remedy Eagle Water Company’s identified fire pumping capacity shortfall, as well as its non-fire pumping capacity shortfall (1175 gpm) and its emergency operation shortfall (425 gpm) are described in SUEZ’s Response to Staff Production Request No. 9. f. Improve System Monitoring SUEZ recommends that the Eagle Water system be monitored around-the-clock through a supervisory control and data acquisition (SCADA) system operated by two licensed, qualified operators. System monitoring would, among other things, provide oversight and control of the quantities of water being produced when compared to the diversion RESPONSE TO STAFF PRODUCTION REQUEST NO. 27 - PAGE 4 OF 4 rate and volume limits imposed on its state-issued water rights, to develop accurate demand and production records and to provide immediate notices of system outages. Ms. Cary’s Direct Testimony at page 6 discusses the projected operating costs for the Eagle Water system to add a dedicated SCADA operator at an estimated cost of $60,000 in payroll expense, plus benefit costs. Ms. Cooper’s testimony starting on page 10 discusses the anticipated $532,000 cost for adding SCADA controls at each Eagle Water facility. $250,000 of this capital investment includes a SCADA control room, database, historian, radio path survey etc. which Eagle Water would need as a stand-alone system and that SUEZ already has in place. RESPONSE TO STAFF PRODUCTION REQUEST NO. 28 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Cathy Cooper, Director of Engineering, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 28: Yes. SUEZ personnel have conducted several site visits where inspection information was collected. In addition, title commitment searches and property surveys have been completed for all real property assets that would be acquired in the purchase. The exhibit included with SUEZ’s Response to Staff Production Request 23 includes all of the due diligence information that resulted from the SUEZ’s inspections, portions of which have been designated by SUEZ as Confidential and subject to the Protective Agreement among the parties. RESPONSE TO STAFF PRODUCTION REQUEST NO. 29 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Cathy Cooper, Director of Engineering, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 29: No. SUEZ determined not to have formal environmental assessments prepared for the real property assets being acquired. Based on the nature and use of the properties to be acquired and of the neighboring properties, SUEZ believes that the likelihood of storage, disposal or release of hazardous substances on the properties and/or contamination potential is very low. SUEZ did review the Idaho Department of Environmental Quality’s website for UST (Underground Storage Tank) locations in the Eagle area, and no UST’s are located close to the Eagle Water facility sites. In addition, no contaminants are present in the water quality sampling results taken from the Eagle Water Company wells based on information available on the Idaho Department of Environmental Quality web site. RESPONSE TO STAFF PRODUCTION REQUEST NO. 30 - PAGE 1 OF 2 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: NAME, TITLE, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 30: Under the terms of the SUEZ-Eagle H2O Acquisitions Asset Purchase Agreement, all purchased assets are to be conveyed at closing free of all liens. Based on title commitments issued by TitleOne Corporation (the “Title Commitments”), Wells Fargo Financial National Bank is the Trustee under a 2007 Deed of Trust securing a promissory note given by Eagle Water Company to Wells Fargo Bank, NA in the principal amount of $75,000 (the “Deed of Trust”). The Deed of Trust constitutes a lien on what is referred to as Eagle Water Company’s “Yard Booster Pump” site located on Old Horseshoe Bend Road. The Yard Booster Pump site makes up a portion of a larger parcel owned by Eagle Water Company that would not be acquired by SUEZ. SUEZ contemplates that it will acquire permanent easements, including an exclusive easement for the Yard Booster Pump site and associated facilities, for access to, and the location, operation and maintenance of the booster pump and water lines. Eagle Water Company is expected to either pay off the Wells Fargo note and obtain a reconveyance of the Deed of Trust or obtain a subordination of Wells Fargo’s lien to the easements to be granted to SUEZ prior to closing. A copy of the Wells Fargo Deed of Trust is attached as Exhibit A. RESPONSE TO STAFF PRODUCTION REQUEST NO. 30 - PAGE 2 OF 2 The Idaho Secretary of State’s business records show the existence of Uniform Commercial Code financing statement filings (the “Financing Statements”) by D.L. Evans Bank as successor in interest to Idaho Banking Company. Furthermore, the Title Commitments pertaining to Well Site 4 and Well Site 6 show the existence of UCC-1 fixture filings by D.L. Evans as successor in interest to Idaho Banking Company (the “Fixture Filings” and together with the Financing Statements, the “UCC Filings”). SUEZ understands the UCC Filings to be associated with historical loans that have been paid off and no longer constitute a lien on Eagle Water Company property. A copy of the Idaho Secretary of State’s Lien Search Results is attached hereto as Exhibit B, and copies of the Fixture Filings can be viewed via the hyperlinks in the Title Commitments, which are being produced in SUEZ’s Response to Staff Request No. 23. SUEZ has requested that Eagle Water Company cause termination statements to be filed by the parties identified as secured parties under the UCC Filings on or before closing. Finally, the Title Commitment for Well Site 1 reflects that 2016 and 2017 real property taxes for that site are delinquent, and therefore may constitute a lien against the property. The original amount of real property taxes for each of those years is $4.50. 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CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: NAME, TITLE, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 31: A litigation search of state courts, State of Idaho and federal courts for the District of Idaho indicate that Eagle Water Company currently is a plaintiff in Case No. CV01-18-20378 before the District Court, Fourth Judicial District, Ada County. The Verified Complaint against Todd Stewart Salon, LLC, Defendant alleges default on the repayment of an unsecured loan made by Eagle Water Company to the Defendant in January 2006 and evidenced by a promissory note in the principal amount of $23,660.00. The Complaint seeks damages in the amount of at least $16,290.33 and attorney fees. Trial to the Court is set for June 17, 2019. Copies of the Verified Complaint and the Case Information Report are produced as Exhibits A and B to this Response. This civil action is not expected to affect the acquisition. 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CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 32: The existing SUEZ Idaho Collective Bargaining Unit Contract expires on March 31, 2019 and renegotiations will be taking place in March. For the purposes of this response, existing contract wages were used for the analysis. OPERATOR – The existing collective bargaining contract current hourly wages for Operators based on years of service and qualifications range from $22.67 (75% of full wage for most newly hired Operator positions) to $30.22 (full wage, generally attained after 5 years of employment), with additional certification pay for professional certification levels achieved as required by the Idaho Bureau of Occupational Licenses. Certification pay for achieving Operator Level I is an additional $0.15 per hour, Level II $0.35, Level III $0.55, Level IV $0.70. Therefore the annual wages for Operators generally start from $47,466 ($22.67 + $0.15 Level I certification * 2,080 hours) for newly hired, less experienced employees, and can range up to $64,314 ($30.22 + $0.70 Level IV certification * 2,080 hours) for Operators with 5 years or more experience or where special circumstances warrant a new, well qualified employee to be placed at an advanced step in the wage progression scale. RESPONSE TO STAFF PRODUCTION REQUEST NO. 32 - PAGE 2 OF 3 Operator 1 and Chief Operator roles include supervisory oversight responsibilities, which would not apply to this role initially and were not included in the wage analysis. The current average wage for existing SUEZ Idaho Operator employees, including applicable certification pay, is $29.97 hourly or $62,338 annually. The bargaining contract also includes provisions for scheduled rotating standby time, for monitoring the system and responding to system needs, and alarms outside of a regularly scheduled shift, which would be in addition to the wages shown above. METER READER – A newly hired meter reader will generally start at $22.30 per hour, $1.00 less than the current established Meter reader Wage of $23.30. The anticipated annual wage for a newly hired meter reader is currently $46,384. While performing Customer Person Field Service duties including completing field work orders, turning water on and off, troubleshooting and maintenance, the role would earn between $23.80 per hour for newly hired employees to $24.80 for established employees. CUSTOMER SERVICE REPRESENTATIVE – The anticipated new hire wage for a CSR is between $14.70 and $14.99 per hour, determined in part by the annual Boise CPI inflationary index and relevant years of experience. At 1,950 hours annually, the starting wage range would be between $28,665 and $29,231. However, with relevant years of experience, the wage may be adjusted up by 1% per year, up to a maximum of 15% or $17.24 per hour and $33,618 annually for well qualified candidates. a) The job descriptions and salary ranges for the three employee classification are the same as the current positions within SUEZ’s existing Idaho service territory. b) The addition of these three positions will allow SUEZ to serve the anticipated 4,200 Eagle Water Company service area customers without impacting SUEZ’s existing Idaho customers. This staff addition is expected to allow SUEZ to initially dedicate an Operator and Meter Reader to the Eagle Water Company service territory. SUEZ’s Customer Field Service Person staff respond to meter issues, perform on/offs, meter and AMI troubleshooting and RESPONSE TO STAFF PRODUCTION REQUEST NO. 32 - PAGE 3 OF 3 maintenance, etc. A well qualified Meter Reader would be able to perform meter reading duties and Customer Field Service Person work in the Eagle Water Company service area. SUEZ’s long term operating strategy however, is for field employees in the given job classifications, to be able to perform all necessary work and respond appropriately anywhere within the SUEZ service area. This includes new growth and service area expansions. It is vitally important for all such trained employees to be able to respond to any such facility and perform work in any portion of the service area, particularly in case of emergencies and provide adequate work coverage during scheduled vacation time off or absences. The addition of a Customer Service Representative to SUEZ’s customer service staff would allow the call center and billing staff to accommodate the workload to respond to the additional customer contacts and process monthly billing for an estimated additional 4,200 customers. A newly added Customer Service Representative position would not be dedicated solely to Eagle Water Company customers. In SUEZ’s experience it would be inefficient and result in poor customer service to have a single representative dedicated to addressing only the needs of a certain segment of customers. SUEZ Customer Service Representatives are trained and respond to all customer call center requests and inquiries without regard to service area or classification. This ensures that an available call center representative can immediately address the next customer’s call without leaving the customer waiting on hold or transferring a customer’s call to a single dedicated representative. SUEZ’s call center staff of employees address the needs of approximately 97,000 bi-monthly billed customers. The addition of 4,200+ customers who are billed monthly would likely generate a higher than normal number of customer inquiries, contacts and requests versus those that are billed bi-monthly. The addition of one customer service representative to accommodate the increase in customer contacts and to accomplish monthly billing, is expected to be adequate to provide service to Eagle Water Company area customers. United Water Idaho Bargaining Unit Field Service -Meter Reading Meter Reader Title: Meter Reader Incumbent: Dept: Commercial Field/Office: Location: United Water Idaho List other incumbents in position: _______________ _ I Position Content: Position Description: Reads and interprets water consumption meters and re~~tial and commercial customer usage. Perfonns meter box maintenance, meter inspection, and meter change-out. Reports to Field Service Foreman. / --------Representative duties may include: • Reading meters and inspecting for tampering, insuring that lids are secure, meter registers are readable, and meter box is accessible. • Responding to customer and general public questions concerning billing and meter reading. • Inputting data for reports (i.e. monthly meter count, hazard codes, damage reports, location and meter condition information, etc.). • Trimming around meters. • Inspecting and changing meters. • Giving proper leak notification to customers and/or company. • Performing field service duties as required, both day and evening shifts. Requirements: • High school diploma or equivalent. • Satisfactory completion of a high school level course in general mathematics. • Ability to read meters with an error rate not to exceed I% within 90 days. • Ability to walk for extended periods of time over uneven terrain in inclement weather. • Valid state driver's license. • Ability to read and interpret maps. • Ability to carry 5 pounds. • One year's experience in meter reading or utility customer service preferred. United Water Idaho Bargaining Unit Production f Operator I Title: Operator Incumbent: Dept: Production Field/Office: Location: lJnited Water Idaho List other incumbents in position:----------------- I P~sl~lo-;;Content: I Position Description: Maintains water production and quality for public consumption. Regulates system pressure, monitors booster stations and storage facilities, and observes treatment conditions. Operates and maintains Class IV water treatment plants, green sand/ammonia plants and well systems on-site and using Supervisory Control and Data Acquisition computer equipment and personal computers in the most efficient manner. May report to Operator I, Chief Operator, Groundwater Supervisor or Production Manager. Representative duties may include: • Conducting routine water testing and recording test results. • Monitoring all charts, gauges, and other operating equipment. • Calculating the chemical feed rate required, calibrating feed equipment, and adjusting feed rate per lab tests or supervisor instructions. • Performing and recording routine and special installation, maintenance and/or repair of all equipment and grounds, and maintaining good housekeeping procedures. • Preparing and submitting routine state and regulatory reports for review. • Analyzing system parameters and determining when additional help is required (e.g. a main break). • Maintaining appropriate chemical inventory levels. • Operating water treatment plants, wells and appurtenant equipment using computers. • Other duties as assigned. Requirements: • High school degree or equivalent to include coursework in Chemistry, Biology, Algebra, and Geometry. • Appropriate state operator's license or water certificate required either at start of employment or within 1 year after the minimum time frame as established by the Idaho State Board of Drinking Water and Wastewater Professionals. • Valid state driver's license. • Basic knowledge of water treatment methods, water chemistry, federal, state and local drinking water regulations, and water distribution/collection systems. • Basic knowledge of computer control systems, programmable logic controllers, and instrumentation for monitoring and control. (Cont'd on Next Page) • Familiarity with routine maintenance procedures for production, treatment, and control equipment. • Ability to transport up to 80 lbs., physical ability/dexterity to perform maintenance/repairs, and basic ability to use microcomputer. • Previous experience in laboratory practices or water treatment preferred. Americans with Disabilities Act {ADA): Are there any physical tasks, (e.g., lifting, carrying, keyboard/telephone usage that are an essential part of the position) for which reasonable accommodation cannot be made? If so, please fill out the ADA questionnaire in the appendix of the manual. Human Resources C0100 www.mysuezwater.com POSITION: Customer Service Representative DATE: 2018 INCUMBENT: ANALYST: DEPARTMENT: 060RIID304 APPROVAL: LOCATION: Manager Approval: REPORTS TO: Summary: The customer service representative operates on three (3) functional levels, call center (entry-1), front office/bad debt (mid-level-2), and back office/billing (max-level-3).The customer service representative is responsible for providing professional, effective, and efficient customer service for all internal and external customers by using excellent, in-depth knowledge of company policies and procedures and Idaho Public Utilities Commission requirements. The call center performs primary customer contact, is responsible to take high volume of customer calls, process customer requests to turn on and off water and make payment plans. The front office/bad debt processes monies to the bank, assists all walk in customers, and processes closed accounts and prepares delinquent accounts for off-site collections. The back office/billing audits high volumes of readings generated by field personnel and bills that have fallen outside specified billing time frames, processes daily orders, miscellaneous items, and ensures all new services are entereing into the billing system. Dimensions: Subordinates: N/A Budget: N/A # of Customers: 94,000 billed bi-monthly Education/Equivalent: High school diploma or equivalent Work Experience Needed: 2 years previous call center, front office, bad debt, back office, and/or billing customer service experience required; more years experience preferred. Regulated Utility or Municipality customer service experience preferred Experience using CC&B Customer Billing Information System or similar is preferred Special Skills/Abilities Needed: • Fine-tuned organizational, interpersonal, and problem solving skills to create positive interactions Human Resources C0100 www.mysuezwater.com with customers to include: o Strong communication (oral and written) and listening skills to understand the customer’s situation and respond effectively by phone, email, in writing, or in person, in a helpful and professional manner. o Practiced problem solving and critical thinking skills to determine solutions to a customer’s problem resolving issues effectively. o Ability to communicate escalated questions and or issues to the Lead CSR or Supervisor effectively. o Demonstrates patience and politeness, especially when interacting with difficult or irate customers. o Ability to work in a team environment in a cooperative and dependable manner in order to achieve internal customer satisfaction and meet company goals. o Flexibility - ability to fill-in as needed to cover critical tasks/roles o Attention to detail in order to follow company processes and Commission rules. o Integrity – ability to maintain confidentiality of customer information • Ability to prioritize and manage multiple competing work priorities successfully • Ability to function in the digital world, using computer, laptop, tablet, smart phone devices and software to communicate and perform and record work. • Proficiency with MS Office Suite Nature & Scope-Principal Areas of Responsibilities: • Ensure customer calls/contacts, billing, collections, cashiering, field orders, and other customer service functions, are handled effectively, timely, and efficiently in a knowledgeable and positive manner. • Receives, investigates and resolves customer calls, emails, complaints and inquiries pertaining to billing, collections, and other customer service functions • Responsible to achieve customer service metrics and satisfaction levels. • Ensure all service orders are complete and entered into the CIS • Assist with routing new development for meter reading and entry into CIS • Professionally perform reception and cashiering functions. Process customer payments, prepare daily deposits, maintain cash reports • Prepare billing adjustments • Efficiently and accurately prepares, updates, maintains and files a variety of customer billing and collections information, service orders, data, reports, and the like. • Promotes/explains company initiatives, programs, and processes to customers, and obtains appropriate information from customers (ACH, ebilling, conservation, etc.). Essential Functions: Work is primarily sedentary and requires exertion of up to 10 pounds of force occasionally. Work activities include, but are not limited to, reaching, finger dexterity, talking, hearing, grasping and repetitive motions. The position deals largely with interacting with customers by phone, basic accounting and use of a computer terminal. This position description is intended for the purpose of evaluation and salary positioning and is not a contract setting forth the full scope of employment. The employer retains the right to deviate from the description at its discretion, without notice. RESPONSE TO STAFF PRODUCTION REQUEST NO. 33 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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? RESPONSE TO PRODUCTION REQUEST NO. 33: SUEZ employs 12 full time Operators, 2 Operator 1 positions and 2 Chief Operator positions. Currently there are no vacancies for Operator positions, and none of them were filled within most recent 12 month period. The most recent Operator hired was in March of 2017. The Company employs 5 full time Meter Readers, with no vacancies and all 5 positions were filled recently, between March and October of 2018. There are 14 full time Customer Service Representatives, with no vacancies and 6 of those positions were filled between May and June of 2018. RESPONSE TO STAFF PRODUCTION REQUEST NO. 34 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 34: SUEZ Idaho’s Customer Service Manager is a full time position, and currently vacant. SUEZ’s Inside Customer Service Supervisor position is a full time position and is filled. SUEZ’s Outside Customer Service Supervisor position is a full time position and is filled. Current job descriptions for the Customer Service department managerial and supervisory positions are attached: Response to Production Request 34 – Exhibit A.docx for the manager position, Response to Production Request 34 – Exhibit B.docx for the inside supervisor, and Response to Production Request 34 – Exhibit C.pdf for the outside supervisor. Salary information for these positions has been designated as Confidential and subject to the Protective Agreement among the Parties and provided separately. www.unitedwater.com POSITION: Customer Service DATE: August 2013 INCUMBENT: Patty Foss-Cameron ANALYST: DEPARTMENT: Customer Service APPROVAL: Susan Gerard LOCATION: Boise, Idaho Manager Approval: Greg Wyatt REPORTS TO:General Manager Summary: The main responsibility of the Customer Service Manager is to define, implement, nurture and deliver a results-oriented team environment that meets operational performance expectations and delivers a customer experience which differentiates United Water from peers and competitors. All efforts should have a clear focus on delivering exceptional service to United Water's customers in-line with requirements defined by the Company, regulators and clients, and driven by customers’ needs and expectations. The scope of the position covers all aspects of office and field customer service activities including call center, billing, collections, meter reading, and field service activities for all areas served through United Water Idaho. This position requires very strong leadership, focus on policy, process adherence, and drive for improvement. Dimensions: Oversees total of 27 employees: Direct: 2 Supervisors & 4 Non-union Indirect: 21 Employees (12 Non-union & 9 Union) Budget Accountabilities: Department: ~ $2M Customers: 87,000 (billed bi-monthly) Annual Revenue: ~$44M Education/Equivalent: • Bachelors Degree in relevant field or equivalent work experience Work Experience Needed: • Minimum 10 years experience in Customer Service or related field, preferably at management/supervisor level. • Good understanding of and experience with budget development and accountability. • Strong working knowledge of general accounting, billing, collections, cash management, meter reading, and field service activities, processes and systems. • Experience working with guidelines of a union contract preferred. • Project Management experience in relation to system development and implementation Position Description www.unitedwater.com Special Skills/Abilities Needed: • Excellent leadership, management and supervisory skills • Strong problem-solving abilities. Ability to synthesize data and translate insights into relevant, usable, actionable, strategic and tactical recommendations • Strong interpersonal skills and ability to interact well with all levels of management, both internally and externally. • Strong communication skills, both written and oral. • Strong proficiency with Microsoft Office, especially Word and Excel. • Strong knowledge of state and federal rules, regulations, codes and laws relating to customer service, collections, and privacy practices preferred • Strong negotiation and conflict resolution skills • Ability to work under pressure and within deadlines • Self-reliant / self-motivated and able to lead and adapt to change • Demonstrated ability to deal with customers, clients and regulators in a courteous, professional and diplomatic manner • Ability to train, coach, and mentor others in effective customer service practices, methods, and techniques Nature & Scope-Principal Areas of Responsibilities: • Develop, communicate and enforce written policies, procedures and financial controls to harmonize, strengthen and support timely and consistent response to customer inquiries and complaints • Conduct continuous process improvements of departmental procedures and processes. • Ensure compliance with INCOME (CODIS), and all regulatory and contractual requirements • Prepare, oversee, and be accountable for annual operating and capital budgets • Prepare detailed departmental operational and management reports • Prepare and oversee annual customer experience feedback programs • Participate in due diligence and acquisition integration when required • Participate on special management projects, as necessary • Use data relating to complaints, inquiries and customer experience feedback to improve service standards in line with customers’ expectations and continuously enhance communication with customers • Ensure customer satisfaction while maintaining Key Performance Indicator (KPI) levels within expected guidelines. • Act as primary liaison to regulatory commission (IPUC) for resolution of customer complaints and issues • Ensure compliance with all regulatory commission (IPUC) and/or contractual requirements as related to all aspects of customer service • Manage relationships with key service providers ensuring that all services are in-line with contractual specifications • Communicate with colleagues, internal and external customers, stakeholders, vendors/consultants and business partners/contacts in a clear, respectful and consistent manner • Establish and monitor annual goals for direct reports and ensure that all department employees receive an employee performance/development review at least once a year • Develop and continuously improve work processes, and document same via Standard Operating Procedures (SOP’s) • Ensure departmental compliance with all environmental, health, and safety policies and requirements • Other duties as assigned www.unitedwater.com Essential Functions: • Physical: Ability to travel when required. Ability to sit for extended time periods. • Sensory: Must be able to see clearly and hear. Must be able to speak to give direction and converse with others. • Mental: Must be able to read complex operations reports, write detailed reports and prepare and deliver presentations. Ability to analyze complex operational and technical challenges and resolve same. Ability to interpret and explain complex regulatory requirements. Must be able to reason, problem solve and analyze complex operational challenges and resolve same. Must be able to learn new technological advances in water industry and train personnel. Must be able to work under pressure and meet deadlines. This position description is intended for the purpose of evaluation and salary positioning and is not a contract setting forth the full scope of employment. The employer retains the right to deviate from the description at its discretion, without notice. www.unitedwater.com POSITION: Office Customer DATE: January2014 INCUMBENT: Linda McCuskey ANALYST: Grade 15 DEPARTMENT: Customer Service APPROVAL: LOCATION: United Water Idaho Boise, Idaho Manager Approval: REPORTS TO:Customer Service Manager Summary: The main responsibility of the Office Customer Service Supervisor is to implement, nurture and deliver a results-oriented team environment that meets operational performance expectations and delivers a customer experience which differentiates United Water from peers and competitors. All efforts should have a clear focus on delivering exceptional service to United Water's customers in-line with requirements defined by the Company, regulators and clients, and driven by customers’ needs and expectations. The scope of the position covers all aspects of office customer service activities including call center, cashiering, and collections for all areas served through United Water Idaho. This position requires very strong leadership, focus on policy, process adherence, and drive for improvement. Dimensions: Subordinates: 12-16 direct reports; depending on how job roles are allocated by the Manager Customers: 88,000 (billed bi-monthly) Budget Accountabilities: Department: ~$1M Annual Revenue: ~$44M Education/Equivalent: • Minimum High School diploma required • Bachelors Degree in relevant field preferred or equivalent work experience Work Experience Needed: • Strong experience and working knowledge in related areas to include call center operations, credit and collections, billing, payment processing, customer information systems, performance benchmarking, and work management. • Good experience in training and development of office Customer Service Representatives (CSR). • 5-7 years experience in a customer contact/call center environment. • 2-3 years supervisory experience in a customer contact/call center environment. Position Description www.unitedwater.com Special Skills/Abilities Needed: • Strong leadership, management and supervisory skills. • Strong problem-solving abilities. Ability to synthesize data and translate insights into relevant, usable, actionable, strategic and tactical recommendations. • Strong interpersonal skills and ability to interact well with all levels of management, both internally and externally. • Strong communication skills, both written and oral. • Ability to handle multiple tasks and employee demands with patience and diplomacy • Ability to work effectively and communicate with all levels of managements, customers and frontline employees. • Demonstrated ability to deal with customers, clients and regulators in a courteous, professional and diplomatic manner. • Experience with recruiting, hiring, training, and motivating. • Ability to train, coach, and mentor others in effective customer service practices, methods, and techniques • Good knowledge of state and federal rules, regulations, codes and laws relating to customer service, collections, and privacy practices preferred. • Strong negotiation and conflict resolution skills. • Ability to work under pressure and within deadlines. • Self-reliant / self-motivated and able to lead and adapt to change. • Proficiency with MS Word/Excel/PowerPoint. • Utility or telecommunication experience preferred. Nature & Scope-Principal Areas of Responsibilities: • Supervise and coordinate the work of assigned CSRs. Provide daily direction and communication to CSRs to ensure customer calls/contacts and field orders are handled in a proper, timely, efficient, positive, and knowledgeable manner. • Assist Customer Service Manager in conducting and implementing continuous process improvements of departmental procedures and processes. • Run, review, and monitor various daily/monthly reports generated through the CC&B customer information system to ensure department activities and operations are in line with expectations. • Respond and/or coordinate the response of other departments to Idaho Public Utility Commission complaints & resolve complex customer issues. • Remain abreast of and ensure implementation of relevant IPUC rules and regulations. • Review and approve customer billing adjustments, refunds, leak allowances, daily cash reports, accounts payable invoices, time sheets and other reports as deemed appropriate by the Customer Service Manager • Oversee accounts in bankruptcy and other related sensitive collection accounts. • Ensure customer collections methods and procedures are implemented that achieve stated accounts receivable targets and metrics. • Establish work procedures and processes that support company and departmental standards, procedures, strategies, and metrics. • Establish effective working relationships with internal customers and business partners (i.e. developers, builders, etc.) • Assist the Customer Service Manager in recruitment process and train and develop Customer Service Representatives. • Assist the Customer Service Manager with counseling, evaluation and motivation of personnel. Perform annual evaluations of staff. • Identify staff training needs, provide and deliver recommended training solutions. www.unitedwater.com • Provide direction for conflict resolution to Customer Service Representatives and field staff with customer contact and take an active role in the escalation process to ensure customer resolution and satisfaction. • Ensure departmental compliance with all environmental, health, and safety policies and requirements, and/or take corrective action to resolve safety concern(s). This includes but is not limited to conducting safety training and accident prevention awareness. • Conduct staff meeting and feedback sessions, and ensure appropriate work communication among personnel and departments. Perform regular call monitoring and performance feedback. • Work with other departments to ensure customer literature, promotions and/or campaigns are implemented accurately and timely. • Ensure all INCOME/CODIS controls are followed in line with agreed upon standards and perform periodic checks to validate compliance. Revise and maintain customer service procedure books. • Ensure customer satisfaction while maintaining Key Performance Indicator (KPI) levels within expected guidelines. • Establish and monitor annual goals for the department and ensure that all assigned employees receive an employee performance/development review at least once a year. • Continuously improve work processes, and document same via Standard Operating Procedures (SOP’s). • Participate on special management projects, as necessary. • Perform all other duties and projects as assigned by the Customer Service Manager. Essential Functions: • Physical: Ability to travel when required. Ability to sit and/or stand for extended time periods viewing computer screens and using keyboard and mouse. • Sensory: Must be able to see clearly and hear. Must be able to speak, give direction, and converse with others fluently in English. • Mental: Must be able to read complex operations reports, write detailed reports and prepare and deliver presentations. Ability to analyze complex operational and technical challenges and resolve same. Ability to interpret and explain complex regulatory requirements. Must be able to reason, problem solve and analyze complex operational challenges and resolve same. Must be able to learn new technological advances in water industry and train personnel. Must be able to work under pressure and meet deadlines. Must be able to multi-task. Must be able to make calm independent decisions, exercise good judgment and flexibility. This position description is intended for the purpose of evaluation and salary positioning and is not a contract setting forth the full scope of employment. The employer retains the right to deviate from the description at its discretion, without notice. RESPONSE TO STAFF PRODUCTION REQUEST NO. 35 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION REQUEST NO. 35: Please provide an organizational chart for SUEZ Water Idaho. RESPONSE TO PRODUCTION REQUEST NO. 35: Please refer to attached file Response to Production Request 35 – Exhibit A.pptx SUEZ Idaho Operation Organization Chart 2019_02 ID L3 –SUEZ Idaho Utility Organization L2 L1 L0 Contractor WTS L3 Vice President GM Idaho MARSHALL THOMPSON Director Finance JARMILA CARY GIS Manager SHANE LIM HR Generalist JUSTY THOMAS EH&S Manager PETE WAGNER Manager Communications JANE KRELLER Customer Service Dept Vacant T&D Dept Brian Tucker Production Dept Seth Goertz Director Engineering CATHERINE COOPER Manager Operations JOHN LEE ? Idaho Organization –January 2019 Idaho Operations 3 I Vice President & General Manager Manager of Operations Operations Planner T&D Manager T&D Operations Supervisor Locator Crew Chief Utility Person Utility Person I Mechanic Cross Connection Control Specialist Inspector Production Manager Control Systems Tech (3) Production Operations Supervisor Chief Operator Operator Operator I Control Systems Tech (1) Chief Operator (Plants) Operator (Plants) Water Quality Specialist GIS Manager Control Systems Specialist GIS Coordinator GIS Specialist Automated Tech. Systems Specialist Director of Finance Sr. Financial Planning & Reporting Analyst Finance Clerk Customer Service Manager Field Customer Service Supervisor Field Customer Service Person Meter Reader Customer Service / Back Office Billing Supervisor CSR Director of Engineering Project Engineer Sr. Project Engineer Construction Supervisor Project Manager Hydro-Geologist Project and AdminAssistant Engineering Design Tech. Manager, Communications & Community Outreach Communications & Community Outreach Specialist EHS ManagerHR Generalist Management 4 I Vice President & General Manager Marshall Thompson Manager of Operations John Lee Director of Finance Jarmila Cary Customer Service Manager Vacant Director of Engineering Cathy Cooper Manager, Communications and Community Relations Jane Kreller GIS Manager Shane Lim EHS Manager Pete Wagner HR Generalist Justy Thomas Customer Service 5 I Director of Finance Jarmila Cary Customer Service Manager Vacant Customer Service Supervisor Marie Flores) Lead CSR (Phones) Mary Ann Michaelson Customer Service Representatives (8) Lead CSR (Back Office / Billing) Debbie Hammons Customer Service Representatives (Back Office / Billing) (6) Field Customer Supervisor Marty Barker Field Customer Service Persons (4) Meter Readers (5) Director of Engineering Cathy Cooper Sr. Project Engineer Roger Greaves Project Manager Rob Barrett Project Engineer Russell Brooks Construction Supervisor Nate Crofts Hydro-Geologist Roger Dittus Engineering Design Tech Robert Jensen Project and Administrative Assistant Katie Birkenstein Engineering 6 I Director of Finance Jarmila Cary Sr. Financial Planning & Reporting Analyst Michael Wilson Finance Clerk Tammy Weber Communication & Finance 7 I Manager, Communications & Community Relations Jane Kreller Communications & Community Outreach Specialist Vacant Manager of Operations John Lee T&D Manager Brian Tucker Production Manager Seth Goertz Water Quality Specialist Camille Cegnar Ops Planner Rob Martinez Operations 8 I Production -Operations 9 I Production Manager Seth Goertz Production Operations Supervisor Bob Lawrence Chief Operator (1) Operator 1 (2) Control Systems Tech. (1) Operator (10) Chief Operator (Plants) (1) Operator (Plants) (2) Control Systems Tech (3) Operations -Systems Maintenance DistributionFormerly T&D 10 I T&D Manager Brian Tucker T&D Operations Supervisor Jim Wade Locator (1) Crew Chief (3) Utility Person (19) Utility Person I (1) Mechanic (1) Cross Connection Control Specialist (1) Inspector (2) GIS Manager Shane Lim Automated Tech Systems Specialist Kelly Garden GIS Coordinator Kevin Smith GIS Specialist Kori St. Marie Control Systems Specialist Vacant Technology & Systems Information -Operations 11 I RESPONSE TO STAFF PRODUCTION REQUEST NO. 36 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson, VP & General Manager, SUEZ Water Idaho Inc. PRODUCTION 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? RESPONSE TO PRODUCTION REQUEST NO. 36: Employees in the Meter Reading job classification would not be assigned meter installation work as part of their normal duties. The vast majority of AMI meters would be installed by SUEZ employees in the separate Utility Worker job classification. Exceptions to this would be meter installations conducted by outside contractors as part of more extensive serviceline replacement work. Any installation of this type would be reviewed and accepted by company Inspectors prior to service activation. RESPONSE TO STAFF PRODUCTION REQUEST NO. 37 - PAGE 1 OF 2 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 37: Estimating bills may be unavoidable due to lack of access to the meter, or the inability to complete an actual meter reading before the billing open window passes due to staff availability or other issues. Reason codes for estimates are reflected in the billing system only when a meter reader enters a meter remark code or comment during the meter reading route completion. These remarks can range from the meter being blocked or obstructed, meter box filled with dirt, fogged meter, car parked on meter, damaged meter, bees/insects preventing access to the meter box, etc. Estimation during the winter months is generally due to snow and ice obstructing meter box access or when the temperature falls significantly below freezing. In such circumstances, a management decision is made to stop reading manual meters to minimize the risk of causing meters to freeze as the meter box is opened in order to obtain a reading. The winter months of 2017-2018 which produced significant and persistent amounts of snowfall in the Boise area not only precluded the ability to physically located and read many meters but also resulted in limited access into certain subdivisions and customer premises for extended periods. During the period of interest, the Meter Reading department also experienced numerous medical related absences and staff turnover impacted meter readings. The Company utilized RESPONSE TO STAFF PRODUCTION REQUEST NO. 37 - PAGE 2 OF 2 temporary contract workers to help supplement staff absences. The following tables are included in Response to Production Request 37 – Exhibit A.xlsx Meter Read Remarks – Estimates Estimates 2016 2017 2018 Jan 3,237 27,705 9,438 Feb 706 17,173 2,321 Mar 373 3,699 1,883 Apr 117 3,023 783 May 104 1,464 556 Jun 94 4,764 2,817 Jul 195 2,694 5,283 Aug 232 1,404 5,162 Sep 313 1,096 4,520 Oct 932 1,599 9,382 Nov 361 3,392 5,215 Dec 6,081 4,060 3,099 TOTAL 12,745 72,073 50,459 Estimates 2016 2017 2018 Jan 3,237 27,705 9,438 Feb 706 17,173 2,321 Mar 373 3,699 1,883 Apr 117 3,023 783 May 104 1,464 556 Jun 94 4,764 2,817 Jul 195 2,694 5,283 Aug 232 1,404 5,162 Sep 313 1,096 4,520 Oct 932 1,599 9,382 Nov 361 3,392 5,215 Dec 6,081 4,060 3,099 TOTAL 12,745 72,073 50,459 Meter Read Remarks - Estimates 2016 Jan Feb Mar Apr May Jun Bees/Insects - - - - - - Blocked/Covered/Can't Locate 177 57 51 15 18 19 Flooded/Fogged/Full of Dirt 4 1 2 - 1 - Damaged/Frozen/Other 134 61 38 10 12 14 2016 Total Meter Read Remarks 315 119 91 25 31 33 2017 Bees/Insects - - - - 1 2 Blocked/Covered/Can't Locate 4 116 113 94 134 178 Flooded/Fogged/Full of Dirt - 7 2 21 4 14 Damaged/Frozen/Other 8 127 113 108 133 153 2017 Total Meter Read Remarks 12 250 228 223 272 347 2018 Bees/Insects - - - - 1 2 Blocked/Covered/Can't Locate 396 465 413 115 67 285 Flooded/Fogged/Full of Dirt 23 11 22 4 2 23 Damaged/Frozen/Other 260 93 156 47 36 95 2018 Total Meter Read Remarks 679 569 591 166 106 405 Jul Aug Sep Oct Nov Dec Total 5 1 8 2 - - 16 21 35 54 84 102 151 784 2 - 9 7 3 9 38 30 60 48 57 77 60 601 58 96 119 150 182 220 1,439 15 27 12 1 - - 58 171 218 187 134 170 460 1,979 9 29 15 18 8 15 142 124 235 158 133 86 116 1,494 319 509 372 286 264 591 3,673 3 9 8 9 2 - 34 160 250 164 278 255 557 3,405 16 26 19 42 15 36 239 121 82 93 141 114 225 1,463 300 367 284 470 386 818 5,141 RESPONSE TO STAFF PRODUCTION REQUEST NO. 38 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION REQUEST NO. 38: How many customers received two or more consecutive estimated bills at any time during the period of 01/01/16 and 12/31/18? What steps can the Company take to minimize the number of estimated bills? RESPONSE TO PRODUCTION REQUEST NO. 38: From 2016 through 2018 9,275 customers received two or more consecutive estimated bills – source Consecutive Estimates Report. SUEZ customer service department takes the following steps to help ensure that the number of consecutive estimates are minimized: • Replace existing manually read meters with AMI meters - Automated Metering Infrastructure • All new meter installations are AMI meters • Provide training to employees and ensure meter is installed correctly the first time • Closely monitor billing and meter reading schedules • Maintain minimum staffing levels with no more than 25% of workforce unavailable • Establish a daily target of 1,500 meter reads per day to stay on or ahead of schedule • Establish a buffer, read meters 1-2 days ahead of schedule to allow for unexpected absences • Attempt to obtain actual read for any skipped reads from the previous day • Utilize an authorized amount of overtime to accomplish meter reading targets and buffer • Customer Service Field Persons to fill-in to help meet meter reading deadlines as needed • Customer contact(s) for obstructed meters – letters mailed to customer, phone calls, schedule a field visit with customer to resolve • Monitor consecutive estimates, schedule follow-up field service orders RESPONSE TO STAFF PRODUCTION REQUEST NO. 39 - PAGE 1 OF 2 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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? RESPONSE TO PRODUCTION REQUEST NO. 39: SUEZ’s goal is to answer all incoming calls as quickly as possible and provide a “one call and done” experience. The call center Customer Service Representative target for speed of answer is within 45 seconds along with an abandoned call rate of 3% or less. SUEZ customer service department takes the following steps to help ensure speed of answer and abandoned call rate targets are being met: • Maintain minimum staffing levels with no more than 25% of workforce unavailable • Stagger Customer Service Representative (CSR) lunch hours and break times, avoid peak call times • Call Center team leader role (implemented July of 2018) to monitor and respond to call flow • Digital call boards posted in call center allow CSR’s to monitor call flow • CSR side work tasks are set aside to answer calls when calls waiting in que • Additional Customer Service Representatives who perform billing, bad debt and collections, and cashiering will augment dedicated call center staff as needed • Customer Service Supervisor and Manager will answer calls • Utilize an authorized amount of overtime to augment peak call times (shorter lunch hours) and to accomplish side work tasks outside of a regularly scheduled workday • Call metrics tracked by day, by CSR and reported regularly • Continued training, feedback and coaching provided to CSR’s on a regular basis • Coordination with Manager of Communications and other company departments on communication efforts to ensure CSR staff has available up-to-date information to answer customer inquiries. • Provide customer information and contacts in various forms – electronically, MySUEZWater.com website, bill inserts, bill messages, social media, etc. RESPONSE TO STAFF PRODUCTION REQUEST NO. 39 - PAGE 2 OF 2 • Utilize a call routing and call answering system that will provide customers with information and direct calls to an appropriate extension as needed. • Call metrics included as part of employee evaluations. RESPONSE TO STAFF PRODUCTION REQUEST NO. 40 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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. RESPONSE TO PRODUCTION REQUEST NO. 40: Number of incoming customer service call center calls answered - Agent Summary Report 2016 2017 2018 Jan 6,048 6,679 6,750 Feb 7,426 6,246 5,775 Mar 7,593 7,293 5,330 Apr 6,999 6,700 5,435 May 7,629 7,281 5,623 Jun 8,574 7,899 6,684 Jul 7,748 7,100 7,418 Aug 8,495 7,536 7,656 Sep 8,069 6,340 6,065 Oct 7,879 6,315 6,737 Nov 7,321 5,758 5,106 Dec 6,968 5,692 4,436 Total 90,749 80,839 73,015 RESPONSE TO STAFF PRODUCTION REQUEST NO. 41 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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. “Service level” is the percentage of calls answered within a certain number of seconds, e.g., 80% of calls answered within 20 seconds. RESPONSE TO PRODUCTION REQUEST NO. 41: SUEZ’s existing call center database is not capable of reporting on percentage of calls answered within a certain target number of seconds. It does track percentage of calls lost > 5 second target, percentage of calls lost > 10 seconds and calls lost > 15 seconds as shown in file Response to Production Request 41 – Exhibit A.xlsx. Group Hour Summary Report Calls Lost > Lost > Lost > Jan-16 3.36%3.21%3.12% Feb-16 3.84%3.66%3.58% Mar-16 2.80%2.62%2.53% Apr-16 2.98%2.91%2.87% May-16 3.10%3.01%2.94% Jun-16 7.40%7.11%7.00% Jul-16 8.91%8.78%8.66% Aug-16 Sep-16 6.92%6.69%6.51% Oct-16 8.89%8.73%8.54% Nov-16 6.90%6.74%6.69% Dec-16 7.88%7.69%7.54% Jan-17 10.09%9.87%9.74% Feb-17 4.76%4.59%4.48% Mar-17 7.22%7.05%6.95% Apr-17 10.84%10.68%10.56% May-17 10.15%9.91%9.77% Jun-17 7.68%7.47%7.40% Jul-17 25.72%25.55%25.30% Aug-17 23.45%23.26%23.07% Sep-17 32.12%31.95%31.78% Oct-17 28.04%27.85%27.57% Nov-17 10.28%10.09%9.84% Dec-17 11.73%11.64%11.57% Jan-18 16.41%16.14%15.93% Feb-18 10.11%9.92%9.81% Mar-18 21.37%21.05%20.83% Apr-18 16.39%16.03%15.83% May-18 9.27%9.12%9.03% Jun-18 1.85%1.78%1.72% Jul-18 4.50%4.34%4.32% Aug-18 4.48%4.35%4.18% Sep-18 7.22%7.10%6.96% Oct-18 3.40%3.31%3.24% Nov-18 3.17%3.06%2.98% Dec-18 2.16%2.10%2.03% Data not available RESPONSE TO STAFF PRODUCTION REQUEST NO. 42 - PAGE 1 OF 2 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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? RESPONSE TO PRODUCTION REQUEST NO. 42: SUEZ’s customer service hours of operations are from 8:00AM – 4:30PM Monday through Friday, excluding holidays. After-hour calls are answered by a designated “late” Customer Field Service Person until 9:00PM, with calls being routed by a local after-hours call answering service for customer service issues ranging from a back on from leak investigation, repairs, to an emergency turn off or on. From 9:00PM until 8:00AM the next morning, the Transmission & Distribution department staffs an on-call person who responds to all customer calls routed through the after- hours answering service. The after-hours answering service has outlined procedures for what the types of customer after-hours calls and concerns constitute an emergency requiring immediate dispatch to SUEZ staff. These emergency situations include: • When a customer calls informing of a leak in the street, immediate dispatch to SUEZ on call personnel • When a customer calls with a leak at their home, dispatched to SUEZ after they are notified of some details RESPONSE TO STAFF PRODUCTION REQUEST NO. 42 - PAGE 2 OF 2 • When Digline locating service calls with an emergency, dispatched with information to SUEZ • If a discolored water call comes in, they are asked a few questions and asked to run their cold water for several minutes, if they have not already, then dispatched to SUEZ if not resolved • If any other water quality issue is reported, dispatched to SUEZ • If the customer says at any time they have an emergency, are agitated, irritated or insistent, dispatched to SUEZ • If the answering service does not know the proper response, dispatched to SUEZ RESPONSE TO STAFF PRODUCTION REQUEST NO. 43 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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? RESPONSE TO PRODUCTION REQUEST NO. 43: SUEZ’s target for responding to written customer correspondence is 10 days. The Company responds to written customer correspondence – i.e., mailed letters, emails, and other electronic communications generally within one day, well below the 10 day target. Customer Service Representatives are responsible to proactively monitor and respond to written customer correspondence including letters, emails and the Company MySUEZWater.com website portal for customer inquiries and requests. The Lead call center Customer Service Representative assigns written correspondence to CSR’s and monitors the portal, mail and Company customer service email. The website on-line customer communications portal, tracks incoming communications, assigns responsibility and tracks progress on each request. The portal is accessible to all Customer Service Representatives, Supervisor and Manager for monitoring and provides a dashboard which tracks status by CSR and request. If written correspondence response time were to approach or exceed the 10 day target, other available CSR’s would be assigned the task of responding to written requests, then the Customer Service Supervisor and Manager would augment the CSR’s in answering written correspondence and the Manager of Communications would provide assistance. RESPONSE TO STAFF PRODUCTION REQUEST NO. 44 - PAGE 1 OF 2 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION REQUEST NO. 44: For 2016, 2017 and 2018 by type/category of complaint, please provide the number of complaints received by the Company directly from a customers or other interested parties. RESPONSE TO PRODUCTION REQUEST NO. 44: Additional details below. SUEZ - COMPLAINTS RECEIVED Year/Month CUSTLEAK DISC WTR DISPUTE HIGH BILL C HIGH BILL I NO WATER SUPERVISOR T&O WTP I WTP O WTR QUALITY TOTAL COMPLAINTS 2016 Totals 148 531 290 1550 1727 647 178 141 140 86 134 5572 January 6 11 3 90 92 83 8 4 3 4 14 318 February 11 23 2 74 53 38 18 2 1 1 13 236 March 18 47 5 54 86 208 28 7 21 3 10 487 April 25 95 6 42 43 41 21 12 24 11 14 334 May 12 35 7 49 35 29 9 78 24 14 10 302 June 28 8 2 102 106 29 8 10 13 6 11 323 July 7 29 4 110 109 30 18 1 9 13 19 349 August 15 36 4 224 132 36 16 10 4 9 10 496 September 9 26 241 128 352 42 20 5 16 9 11 859 October 6 132 10 593 569 13 10 6 6 7 6 1358 November 7 18 6 68 127 21 11 3 9 5 13 288 December 4 71 16 23 77 11 3 10 4 3 222 2017 Totals 587 259 11 1270 180 393 164 25 73 64 34 3060 January 558 37 814 63 317 22 1 8 3 3 1826 February 7 14 10 4 16 14 3 5 73 March 1 50 2 69 11 3 8 1 1 3 1 150 April 1 36 3 80 4 7 11 3 4 6 8 163 May 8 25 25 15 5 7 2 10 6 4 107 June 4 8 2 25 12 7 17 3 8 8 5 99 July 1 25 1 48 9 11 8 3 9 13 4 132 August 1 20 69 12 7 13 9 9 2 142 September 1 20 1 51 16 5 16 3 6 3 5 127 October 3 6 47 23 7 10 2 9 3 2 112 November 2 9 2 14 7 7 8 3 5 2 59 December 9 18 4 1 30 1 4 3 70 2018 Totals 45 66 6 172 46 42 71 13 31 7 7 506 January 2 9 15 4 5 12 2 6 1 1 57 February 1 10 1 15 3 4 8 3 4 2 1 52 March 3 7 14 7 9 5 2 3 1 3 54 April 9 19 1 10 2 2 7 2 4 1 1 58 May 18 7 1 14 4 10 3 1 58 June 3 3 3 2 3 5 1 20 July 7 3 7 1 5 9 2 34 August 2 1 21 3 2 7 2 1 39 September 2 29 4 2 2 2 41 October 5 17 5 5 4 1 37 November 1 11 3 2 1 18 December 2 16 8 11 1 38 Grand Total 780 856 307 2992 1953 1082 413 179 244 157 175 9138 RESPONSE TO STAFF PRODUCTION REQUEST NO. 44 - PAGE 2 OF 2 CODE CUSTLEAK DISC WTR DISPUTE HIGH BILL C HIGH BILL I NO WATER SUPERVISOR T&O WTP I WTP O WTR QUALITY Water Quality DEFINITION Customer Leak on Customer Service Premise Discolored Water Dispute Charge Reason/Status High Bill Case Created with Field Activity High Bill Inquiry Phone Review Only Report of No Water Request to speak with a Supervisor Taste and Odor Water Pressure Problem Incident/Break Water Pressure Problem Ongoing SUEZ - COMPLAINTS RECEIVED Year/Month CUSTLEAK DISC WTR DISPUTE HIGH BILL C HIGH BILL I NO WATER SUPERVISOR T&O WTP I WTP O WTR QUALITY TOTAL COMPLAINTS 2016 Totals 148 531 290 1550 1727 647 178 141 140 86 134 5572 January 6 11 3 90 92 83 8 4 3 4 14 318 February 11 23 2 74 53 38 18 2 1 1 13 236 March 18 47 5 54 86 208 28 7 21 3 10 487 April 25 95 6 42 43 41 21 12 24 11 14 334 May 12 35 7 49 35 29 9 78 24 14 10 302 June 28 8 2 102 106 29 8 10 13 6 11 323 July 7 29 4 110 109 30 18 1 9 13 19 349 August 15 36 4 224 132 36 16 10 4 9 10 496 September 9 26 241 128 352 42 20 5 16 9 11 859 October 6 132 10 593 569 13 10 6 6 7 6 1358 November 7 18 6 68 127 21 11 3 9 5 13 288 December 4 71 16 23 77 11 3 10 4 3 222 2017 Totals 587 259 11 1270 180 393 164 25 73 64 34 3060 January 558 37 814 63 317 22 1 8 3 3 1826 February 7 14 10 4 16 14 3 5 73 March 1 50 2 69 11 3 8 1 1 3 1 150 April 1 36 3 80 4 7 11 3 4 6 8 163 May 8 25 25 15 5 7 2 10 6 4 107 June 4 8 2 25 12 7 17 3 8 8 5 99 July 1 25 1 48 9 11 8 3 9 13 4 132 August 1 20 69 12 7 13 9 9 2 142 September 1 20 1 51 16 5 16 3 6 3 5 127 October 3 6 47 23 7 10 2 9 3 2 112 November 2 9 2 14 7 7 8 3 5 2 59 December 9 18 4 1 30 1 4 3 70 2018 Totals 45 66 6 172 46 42 71 13 31 7 7 506 January 2 9 15 4 5 12 2 6 1 1 57 February 1 10 1 15 3 4 8 3 4 2 1 52 March 3 7 14 7 9 5 2 3 1 3 54 April 9 19 1 10 2 2 7 2 4 1 1 58 May 18 7 1 14 4 10 3 1 58 June 3 3 3 2 3 5 1 20 July 7 3 7 1 5 9 2 34 August 2 1 21 3 2 7 2 1 39 September 2 29 4 2 2 2 41 October 5 17 5 5 4 1 37November11132118 December 2 16 8 11 1 38 Grand Total 780 856 307 2992 1953 1082 413 179 244 157 175 9138 CODE CUSTLEAK DISC WTR DISPUTE HIGH BILL C HIGH BILL I NO WATER SUPERVISOR T&O WTP I WTP O WTR QUALITY Water Quality DEFINITION Customer Leak on Customer Service Premise Discolored Water Dispute Charge Reason/Status High Bill Case Created with Field Activity High Bill Inquiry Phone Review Only Report of No Water Request to speak with a Supervisor Taste and Odor Water Pressure Problem Incident/Break Water Pressure Problem Ongoing RESPONSE TO STAFF PRODUCTION REQUEST NO. 45 - PAGE 1 OF 2 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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? RESPONSE TO PRODUCTION REQUEST NO. 45: SUEZ plans to allow Eagle Water Company customers to sign up for Budget Billing, to be able participate in its Leak Adjustment credit program, and apply for affordability assistance using the SUEZ Cares Program after the purchase is approved and the customer receive service from SUEZ. There is a condition on the ability of all SUEZ customers to sign up/participate in Budget Billing. To enroll in Budget Billing, customers must have a minimum of 12 consecutive months of service at the current location (billing history with SUEZ) and have no past due balance owing at the time of enrollment. The Company’s billing system is not capable of calculating a budget bill amount without 12 months of billing history available. Former Eagle Water Company customers would qualify for participation in the SUEZ Leak Adjustment program, once the customer exceeds one year of established billing history with SUEZ. Elmore Ada Community Action Partnership administers the SUEZ Cares program and makes a determination of a customer’s eligibility based on established federal level poverty guidelines. If the asset purchase is approved, current Eagle Water Company customers who are RESPONSE TO STAFF PRODUCTION REQUEST NO. 45 - PAGE 2 OF 2 determined to be eligible for assistance would receive the full $75 per year affordability credit allowed under the SUEZ Cares Program from the date of initial account activation with SUEZ. Despite paying fractional SUEZ rates during the proposed 3-year rate phase-in, Eagle Water customers would be eligible for the full affordability credit from the first day of acquisition. RESPONSE TO STAFF PRODUCTION REQUEST NO. 46 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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 at 9. RESPONSE TO PRODUCTION REQUEST NO. 46: The Company proposal that the tariff rate for newly established customers after the acquisition be at the full phased-in amount is intended to be consistent with the Commission’s prior order concerning this issue. According to Commission Staff Order 27798 in UWI-W-98-2 regarding United Water Idaho Inc.’s acquisition of South County Water Company page 10 states that We find that new customers in the South County area, whether new by the result of new construction or sale/purchase, are not subject to rate shock and cannot be perceived as having any reasonable expectation of lower South County rates. RESPONSE TO STAFF PRODUCTION REQUEST NO. 47 - PAGE 1 OF 1 SUEZ WATER IDAHO INC. CASE SUZ-W-18-02 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary, Director of Finance, SUEZ Water Idaho Inc. PRODUCTION 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”? RESPONSE TO PRODUCTION REQUEST NO. 47: SUEZ does not 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.” Such changes are considered “record only” changes that would not cause an established account to become a new account unless the premise on the account was sold to a new unrelated customer. In that situation, the new customer purchasing the property and requesting service would be establishing a new account.