20201007Staff 1-40 to Suez.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-001 4
(208) 334-O3t2
IDAHO BAR NO. 9917
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Street Address for Express Mail:
II33I W CHINDEN BLVD, BLDG 8, SUME 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF SUEZ WATER IDAHO
INC.'S APPLICATION FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
CASE NO. SUZ.W.aO.O2
FIRST PRODUCTION
RBQUEST OF THE
COMMISSION STAFF TO
suEZ WATER IDAHO,INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Suez Water Idaho, Inc. provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
ocroBER 28, 2020.
This Production Request is to be considered as continuing, and Suez Water Idaho, Inc. is
requested to provide, by way of supplementary responses, additional documents that it, or any
person acting on its behalf, may later obtain that will augment the documents 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 identify the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO SUEZ WATER
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1 OCTOBER 7 ,2020
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide copies of the monthly trial balances from January
2017 through the most current month available. Please supplement your response when
additional months become available throughout 2020.
REQUEST NO. 2: Please provide a copy of the Company Chart of Accounts
REQUEST NO. 3: Please provide a list of all external attorneys who performed services
for the Company or who were paid by the Company for services during 2019 and2020 to date.
Please list the amounts paid, accounts charged, and date of payment. Please also provide a brief
summary of the services performed. If services were performed in support of a docketed
federal/state court or regulatory action, please identify the case narne, case number, and
jurisdiction.
REQUEST NO.4: Please provide the total amount that the Company spent on the
following activities for 2019 and202o to date, and show how the Company allocated the
amounts between its operating division and the rest of the Company and its subsidiaries:
a. The Company's annual report;
b. Rating agencies;
c. All software or information system-related issues;
d. Board of Directors compensation, travel expenses, and meeting expenses;
e. Travel and training for all shared executives of SUEZ NA and affiliates;
f. Insurance coverage;
g. Overhead items including utilities, property taxes, security services, and other
corporate headquarter expenses; and
h. All other allocated or shared expenses.
FIRST PRODUCTION REQUEST
TO SUEZ WATER 2 OCTOBER 7 ,2020
REQUEST NO.5: Please provide a matrix identifying the major capital expenditure
approval levels that includes the dollar level of authorization by employee title, division, and
company. Please include within your response the dollar level at which the individual capital
expenditures require approval by the Board of Directors.
REQUEST NO. 6: Please provide copies of the cost/benefit analysis, internal rates of
return, or similar analysis for each capital project included in the Company's response to Request
No.5.
REQUEST NO. 7: Please provide a schedule of all additions and retirements to Plant in
Service since the beginning of 2015, including installation date, account, installed cost, and
estimated depreciable life.
REQUEST NO.8: Please provide all journal entries related to additions and retirements
to Plant in Service since the beginning of 2015.
REQUEST NO. 9: Please provide an analysis of any sales of land and/or plant for the
years 2OI7 -2020 to date, if any. Please show gains, losses, and supporting documentation
including accounting entries for removal of items from rate base.
REQUEST NO. 10: Please provide details of any planned sales of land and/or plant for
the remainder 2020. Please include within your response the estimated date of these sales and
planned accounting treatment.
REQUEST NO. 11: Please provide a list of "out-of-period adjustments" and
"extraordinary items" for the years 2017 - 2020 to date.
REQUEST NO. 12: Please provide a schedule showing injuries and damages claims for
the years 2016 - June 30, 2020. Please include within your response the description of each
item, the amount for each item, and the account charged.
FIRST PRODUCTION REQUEST
TO SUEZ WATER OCTOBER 7 ,2020J
REQUEST NO. 13: Please provide a listing of all organizations the Company
participates in and the costs of participating in those organizations (e.g. NAWC, IACI, R&I
Alliance, etc.).
REQUEST NO. 14: Please provide detail of all advertising expenses recorded above the
line including account and subaccounts where posted, dates posted, vendor names, explanations,
and amounts posted during 2019 and2020.
REQUEST NO. 15: Please provide copies of all advertisements used during 2019 and
2O2O and correlate the advertisement with the specific detail provided in the Company's
response to Request No. 14.
REQUEST NO. 16: Please provide copies of all billing inserts for 2019 and2020 and
indicate the date they were sent. Please also provide a schedule showing the amount and account
numbers charged for all costs to produce, print, and distribute the inserts.
REQUEST NO. 17: Please provide copies of the monthly, quarterly, and annual
comparison of operating and capital budget to actual expenditures for 2016 -2020 to date.
Please include within your response a narrative explanation for budget variations. This should
include, but not be limited to, written operating and capital budget variance reports and
explanations used by Company officers and managers to monitor and control budgets under their
responsibility. Please supplement your response as additional information becomes available
throughout 2020.
REQUEST NO. 18: Please provide a list of all leased items in2OI9 and2O2O to date.
Please separate capital leases from operating leases and show the dates, terms, amounts, and
accounts used for each lease.
FIRST PRODUCTION REQUEST
TO SUEZ WATER OCTOBER 7,20204
REQUEST NO. 19: Please provide a schedule of prepaid items for 20L9 and 2020 to
date showing amounts posted, vendor names, explanations, and accounts to which these items
were booked. Please include within your response any significant changes to prepaid items
occurring or planned to occur in2019 and2020.
REQUEST NO.20: Please provide the following direct labor related information as
recorded for the twelve months ended December 31,2017 - 2019 and the six months ended June
30,2020. Information, where applicable, should be listed by O&M expense, other expense,
construction, and other account groups (listed by functional categories, i.e. generation,
transmission, distribution, customer, A&G, etc.). Please provide the information on a system-
wide basis. The response should include wages and salaries for each employee category (officer,
exempt, non-exempt, and union), paid time-off, overtime, bonuses, incentive pay, and overheads
for pension, benefits, and payroll taxes. Please also include average and year-end number of
employees by employee category. Include part-time and temporary employees as full-time
equivalents.
REQUEST NO.21: Please provide the quantifiable savings from any cost/workforce
reduction programs during the past five years. Please provide any additional workforce
reduction programs planned for 2OI9 - 2020 to date.
REQUEST NO. 22: Please summarize all benefit and retirement plans provided to any
classification of Company employees. Please also include any changes that have occurred to the
benefits/accruals during the past five years.
REQUEST NO.23: Please provide copies of the Company's pension and actuarial
reports for the years 2017 - 2020. Also, please provide any actuarial calculations and
documentation that shows the development of FAS 87 expenses (ASC 715 Compensation -
Retirement Benefits as codified), Company contributions, balances, and assumptions.
FIRST PRODUCTION REQUEST
TO SUEZ WATER OCTOBER 7 ,20205
REQUEST NO. 24: Please provide access to copies of all studies used to determine
employee compensation, including executive compensation, and explanations of how the
Company applied them in the years 2018 - 2020 to date.
REQUEST NO.25: Please provide the yearly percentage pay rate increase by employee
and position since the last general rate case in 2015. Please provide in excel spreadsheet with
formulas intact.
REQUEST NO.26: Please provide access to the Board of Directors' meeting minutes
for each meeting in 2018 -2020 to date.
REQUEST NO.27: Please provide copies of the Board of Directors' materials
distributed forlat meetings from 2018 - 2020 to date. Please also include the same for the
Compensation Committee.
REQUEST NO.28: Please provide an estimate of the outside rate case expenses the
Company expects to incur for this case.
REQUEST NO. 29: Please provide a copy of the Company's property tax bills for 2019
and2O2O.
REQUEST NO. 30: Please provide all Company bank statements for 2019 and2020.
REQUEST NO.31: Please provide statements for any Company credit cards that
include spending during 2Ol9 and2020 to date.
REQUEST NO. 32: Please provide a list of all property that the Company leases to
others. Please provide copies ofall lease contracts.
FIRST PRODUCTION REQUEST
TO SUEZ WATER OCTOBER 7,20206
REQUEST NO.33: Please list all the Company's long-term debt issuances. Please
include the following: dates of issuance and expiration, amounts, premiums or discounts, interest
rates, dates of pre-payment, and payment schedules for each issuance.
REQUEST NO. 34: Please provide a list of all contractors used in 2017 ,2018,2019 and
2020 to date. Please include with this response the contract amount, project narne, project
location, and completion date.
REQUEST NO.35: Please provide a current hydraulic model of the Company's water
system.
REQUEST NO.36: Please provide the most recent version of the Company's Drinking
Water Facilities Capital Plan.
REQUEST NO. 37: Please provide a copy of the Company's policy for water main
extenslons.
REQUEST NO.38: For each of the Company's wells, please provide the quantity
(gallons) pumped for each month between January 2017 andJtne 2020.
REQUEST NO.39: Please provide the Idaho Department of Water Resources unique
identifier (e.g. Well TaglD-Tag Number) for each of the Company's wells.
REQUEST NO.40: Please provide the following for each meter size for each month
from January 2Ol7 through June 2020:
a. Number of Billed Customer Charges;
b. Gallons of water provided to customers at no charge as part of the Minimum
Charge; and
c. Gallons sold to customers in excess of the maximum gallons allowed in the
Minimum Charge.
FIRST PRODUCTION REQUEST
TO SUEZ WATER 1 OCTOBER 7 ,2020
DATED at Boise, Idaho, this ?fL day of October 2020.
Dayn Hardie
Deputy Attorney General
i:umisc:prodreq/suzw20.2dhtnc prod req I
FIRST PRODUCTION REQUEST
TO SUEZ WATER 8 OCTOBER 7,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7ft DAy OF OCTOBER 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO SUEZ WATER IDAHO, INC., IN CASE NO. SUZ-W-20-02, BY E-MAILING A
COPY THEREOF TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GTVENS PURSLEY LLP
POBOX2720
BOISE D 83701-2720
E-MAIL: mcc@ givenspursley.com
prestoncarter @ givenspursley.com
DAVID NJUGUNA
MGR - REGULATORY BUSINESS
SUEZ WATER MGMNT & SERVICES CO
461 FROM ROAD SUITE 4OO
PARAMUS NJ 07052
E-MAIL: David.njuguna@ suez.com
SECRET Y
CERTIFICATE OF SERVICE