20201118Staff 41-59 to Suez.pdf

DAYN HARDIE (ISB No. 9917)
MATT HUNTER (ISB No. 10665)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
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Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorneys 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 SERVICB IN THE STATE OF IDAHO
CASE NO. SUZ-W-20-02
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
SUEZ WATER IDAHO,INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie and Matt Hunter, Deputy Attorneys General, request that Suez Water Idaho,
Inc. provide the following documents and information as soon as possible, but no later than
WEDNESDAY, DECEMBER 9, 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.
SECOND PRODUCTION REQUEST
TO SUEZ WATER NOVEMBER 18,2020
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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.41: On Pages 3 and 4 of his direct testimony, Company Witness
Michaelson describes adjustments made to the average numbers of residential and commercial
customers. Please provide all workpapers used to calculate these adjustments in EXCEL format
with formulae and links intact.
REQUEST NO. 42: On Pages 4 and5 of his direct testimony, Company Witness
Michaelson describes the regression method used to adjust the consumption of residential and
commercial customers. Please provide all workpapers used to calculate these adjustments in
EXCEL format with formulae and links intact.
REQUEST NO. 43: On Page 4 of his direct testimony, Company Witness Michaelson
states that he used Palmer Zindex amounts taken from NOAA National Centers for
Environmental Information, Climate at a Glance (https://www.ncdc.noaa.gov/cagA. please
provide the Palmer-Z dataused to qeate the regression model in EXCEL format. please provide
all parameters that were selected to download the palmer-Zdata, including:
a. Parameter
b. Time Scale
c. Month
d. Start year
e. End Year
f. State
g. Climate Division
REQUEST NO.44: Please provide the data that supports the Customers per Employee
2000-2020 chart on Page 8 of Company witness Thompson's direct testimony.
REQUEST NO.45: Please provide the data supporting the Customer vs Employee
Count 2000-2020 chart on Page 8 of Company Witness Thompson's direct testimony.
SECOND PRODUCTION REQUEST
TO SUEZ WATER NOVEMBER 18, 2O2O2
The following questions refer to the direct testimony of Jarmila cary.
REQUEST NO.46: With reference to the Number of Positions on page 3 of the
testimony, please provide job descriptions and pay scales for all current positions.
REQUEST No' 47: With reference to the increase in staffing from the Company,s Test
Year levels described on Page 5 of the testimony, please provide the job description for each
position listed, as well as the proposed pay rates. For each new position listed, please indicate
whether the position has been filled, or the anticipated date that the position will be filled. please
also include a description of why these positions are needed by the Company and how they
benefit the customers of SUEZ.
REQUEST NO.48: With reference to the Wage Adjustments on page 3 of the
testimony, please provide a copy of the union contract showing the contractually obligated pay
increase for Bargaining Unit employees.
REQUEST NO.49: With reference to the Wage Adjustments on pages 3 and 4 of the
testimony, please provide the basis for the 2.5vo pay change over 2020. please include any and
all studies used to justify the2.5Vo wage adjustment.
REQUEST NO.50: With reference to the Wage Adjustments on page.l of the
testimony, please provide supporting documentation for the test year ratio of 6g. rovo ofthe opex
payroll to gross payroll.
REQUEST No. 51: With reference to the Stand-b y Pay,Shift pay, and overtime pay
on Page 4 of the testimony, please provide the policies governing when these pay rates are used
Please provide the supporting documentation and workpapers for calculating the three-year
average for overtime.
SECOND PRODUCTION REQUEST
TO SUEZ WATER NOVEMBER 18,20203
REQUEST NO.52: With reference to the Incentive Programs on page 4 of the
testimony, please provide a description of the Company's Short-Term Incentive plan, including
the goal targets and criteria requirements. Please provide descriptions and amounts of the target
awards based upon the job/salary grade, including the personal goals and Company goals.
REQUEST NO.53: With reference to the lncentive Programs on page 4 of the
testimony, please provide a description of the Non-Exempt Incentive program, including the
basis for the incentive payments and the amount or percentage of the incentive payment.
REQUEST NO. 54: With reference to Adjustment No. 2 Workers Compensation on
Page 5 of the testimony, please provide the supporting documentation and workpapers for the
adjustment, including the inputs for the three-year average of workers compensation.
REQUEST NO. 55: With reference to Adjustment No. 3 Pension Expense on page 6 of
the testimony, please provide the Actuarial Reports for years 2015 throu gh2020. Additionally,
please include all correspondence,letters, and emails between the Company and its actuaries for
years 2015 through 2020.
REQUEST NO.56: With reference to Adjustment No. 4 PBOP on page 6 of the
testimony, please provide supporting documentation and workpapers supporting the Towers
Watson actuarial valuation dated March2020 with a service cost of $207,049 and interest
component of ($560,205).
REQUEST NO.57: With reference to Adjustment No. 5 Employee Healthcare, Group
Term Life, and Long-Term Disability on Page 7 of the testimony, please provide documentation
and workpapers supporting the calculation of the adjustment. Additionally, please provide the
policies governing these benefits and the calculation for the 3.36Vo increase in healthcare costs.
REQUEST NO. 58: With reference to adjustment No. 7 Other Employee Benefits on
Page 7 of the testimony, please provide the policy for tuition assistance. please provide the
amount and type of tuition assistance by year for years 2015 throu gh2020.
SECOND PRODUCTION REQUEST
TO SUEZ WATER NOVEMBER 18, 2O2O4
REQUEST NO. 59: With reference to Adjustment No. 8 Payroll Overheads on page 8
of the testimony, please provide an overview of the fringe benefit allocation method. please
provide the calculation for this adjustment, including the inputs used and the source documents
for the inputs.
DATED at Boise, Idaho, this tvb- day of November 2020
Hardie
Deputy Attorney General
i:umisc:prodreq/suzw20.2dhmhtnc prod req 2
SECOND PRODUCTION REQUEST
TO SUEZ WATER 5 NOVEMBER 18, 2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18th DAY oF NOVEMBER 2020,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO SUEZ WATER IDAHO, INC., IN CASE NO. SUZ-W-2O-02,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 8370T-2720
E-MAIL: mcc @ givenspursle),.com
pre stoncarter @ givenspursley.com
DAVID NJUGUNA
MGR _ REGULATORY BUSINESS
SUEZ WATER MGMNT & SERVICES CO
461 FROM ROAD SUITE 4OO
PARAMUS NJ 07052
E-MAIL: David.lliuguna @ suez.com
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CERTIFICATE OF SERVICE