20200803Staff 1-9 to Suez Water.pdf

DAYN HARDIE
DEPUTY AT-IORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAIIO BAR NO. 99I7
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Street Address for Express Mail:
I I33I W C}IINDEN BLVD, BLDG 8, SUITE 20I.A
BOISE, ID 837I4
Attorneys for the Commission S1aff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF SUEZ
WATER IDAHO, INC. FOR AUTHORIZATION
TO ELIMINATE COLLECTION OF GROSS.UP
PAYMENTS ASSOCIATED WITH
CONTRIBT]TIONS IN AID OF CONSTRUCTION
CASE NO. SUZ-W-20-01
FIRST PRODUCTION
REQUEST OF THE
COI\IMISSION STAFFTO
SUEZ WATER IDAHO, INC.
The Staffofthe Idaho Public Utilities Commission, by and through its attomey ofrecord,
Dayn Hardie, Deputy Attorney General, requests that Suez Waler Idaho, Inc. provide the
following documents and information as soon as possible, but no later than MONDAY'
AUGUST 24,2020.
This Production Request is to be considered as continuing, and Suez Water ldaho, Inc is
requested to provide. by way ofsupplementary responses, additional documents that it, or any
person acting on its behalf, may later obtain that will augment the documents or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. and the name, job title, and telephone number of
the person preparing the documents. Please also identifu the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO SUEZ WAI'ER
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AUGUST 3, 2O2O
In addition to the written copies provided as response to the requests, please provide ail
Excel spreadsheets and electronic files on CD u,ith formulas intact and enabled.
REQUEST N0. 1: How many developers have opted to lorm and operate their olvn
small water systems 10 serve their developments since the tariff change on June I , 201 8 that
allowed the Company to gross-up the amount it charges to developers to account for the
taxability of contributions irr aid of construction ("CIAC")?
REQUEST NO. 2: Horv many developers have opted lo receive seruice from a
municipal u'ater system Ibr their developrnents since the tarifTchange on June 1. 2018 that
allowed the Company to gross-up the amount it charges to developers lo account for the
taxability of CIAC?
REQUEST N0, 3: Please provide a copy of the strike-outiunderline version of lhe
current tariff identified as Exhibit A in the Petition,
REQUEST NO. {: Has the Company, considered modi{ying the water main exlcnsion
tariff and the application of allorvances 1o address lhc issuc of lower than potential growlh due to
high upfront main extension costs? Ifso, please explain any modifications considered and
provide any analysis the Company has perlormed to evaluate the modjlications.
REQUEST NO. 5: The water main extensions section of the tarif'f states individual
residential customers shall receive a $500 Frec-Footage Allowance. SIJEZ Tariffl, Sheet 22. fl
63. Please indicate all customcr classes and/or developers eligible for this allowance.
REQUEST NO. 6: Please provide an explanation and rvorkpapers showing how the
F'ree-F-ootage Allowance in SUEZ TarilL Sheet 22, is calculated fbr water main extensions.
REQUEST N0.7: Besides the 5500 Free-Footage Allowance, please provide a list of
any other allorvances given lbr rvater main extensions and include rvho is eligible and how each
allovvance is calculated.
FIITST PRODUCl'rON REQUEST
TO SUEZ WATER 2 AUGIJST 3, 2O2O
REQUEST NO. 8: Are there any customer/developer requested water main extension
project costs included in base rates? Ifso, please explain.
REQUEST NO. 9: Please provide an explanation and workpapers showing how
overhead and inspection fees are calculated for water main extensions.
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DATED at Boise, Idaho, this - day ofAugust 2020.
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Deputy Attomey General
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FIRST PRODUCTION REQUEST
TO SUEZ WATER J AUGUST 3,2O2O
CERTITICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF AUGUST 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO SUEZ WATER IDAIIO, INC., IN CASE NO.
SUZ-W.2o-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: mcc(0sivenspursler..com
MARSHALL THOMPSON
SUEZ WATER IDAHO INC
8284 W. VICTORY RD
BOISE ID 83709
E-MAIL: marshall.t c()tTl
nrestoncaner(dq ir. en snurslev.cortt
SECRETARY
CERTIFICATE OF SERVICE