20201203Staff 60-64 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 83720-0074
[phone]
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-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 )CASE NO.SUZ-W-20-02
INCREASE ITS RATES AND CHARGES FOR )
WATER SERVICE IN THE STATE OF IDAHO )THIRD PRODUCTION
)REQUESTOF 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
THURSDAY,DECEMBER 24,2020.
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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
THIRD PRODUCTION REQUEST
TO SUEZ WATER 1 DECEMBER 3,2020
RECEIVED
2020December 3, PM 4:03
IDAHO PUBLIC
UTILITIES COMMISSION
In addition to the written copies provided as response to the requests,please provide all
EXCEL spreadsheets and electronic ñles on CD with formulas intact and enabled.
REQUESTNO.60:Please provide supporting documentation for the anticipated impact
of post COVID-19 pandemic economic downturn on bad debt expense as stated in Witness
Cary's Exhibit No 10,Schedule 1 Page 18.
REQUESTNO.61:Please provide supporting documentation for the following
transportation expenses as shown in Witness Cary's Exhibit No 10,Schedule 1,Page 21.In your
response,please identify any additional costs necessary for future employees proformed into the
Company's revenue requirement.
a.Lease Cost &GPS fees
b.Fuel
c.P-card maintenance materials,outside service
d.Mechanic payroll and benefits
e.Insurance
f.Depreciation
g.VA Allowance
REQUESTNO.62:Please provide a schedule showing the year,make,and model of
the Company's current fleet of vehicles,and the fleet used for Witness Cary's Exhibit No 10,
Schedule 1,Page 21.For each vehicle,please state whether it is leased or owned by the
Company,along with the purchase price and net book value..
REQUESTNO.63:Please provide a copy of the Company's vehicle replacement
policy and any studies the Company has performed in the last five years relating to vehicle
replacement.
REQUESTNO.64:Please provide a schedule showing actual rate case costs incurred
to date.Please supplement this response each month as additional costs are incurred.
THIRD PRODUCTION REQUEST
TO SUEZ WATER 2 DECEMBER 3,2020
REQUESTNO.65:Please provide the details and narrative of how the Company
calculated the power deferral as shown in Witness Cary's Exhibit No 10,Schedule 1,Page 28.
DATED at Boise,Idaho,this day of December 2020.
ayn Hardie
Deputy Attorney General
i umisc prodreq/suzw20.2dhmhtne pod reg 3
THIRD PRODUCTIONREQUEST
TO SUEZ WATER 3 DECEMBER 3,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 36 DAY OF DECEMBER 2020,
SERVED THE FOREGOINGTHIRD PRODUCTION REQUESTOF THE COMMISSIONSTAFFTOSUEZWATERIDAHO,INC.,IN CASE NO.SUZ-W-20-02,BY E-MAILING
A COPY THEREOF TO THE FOLLOWING:
MICHAEL C CREAMER DAVID NJUGUNA
PRESTON N CARTER MGR -REGULATORYBUSINESS
GIVENS PURSLEY LLP SUEZ WATER MGMNT &SERVICES CO
PO BOX 2720 461 FROM ROAD SUITE 400
BOISE ID 83701-2720 PARAMUS NJ 07052
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
S CRET RY
CERTIFICATEOF SERVICE