20201211Staff 66-86 to Suez.pdf

DAYN HARDIE (ISB No.9917)MATT HUNTER(ISB No.10665)L:03DEPUTYATTORNEYSGENERALIDAHOPUBLICUTILITIESCOMMISSIONPOBOX83720
BOISE,IDAHO 83720-0074
[phone]
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-ABOISE,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-20-02INCREASEITSRATESANDCHARGESFOR)WATER SERVICE IN THE STATE OF IDAHO )FOURTH 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 followingdocuments and information as soon as possible,but no later than
MONDAY,JANUARY 4,2021.
This Production Request is to be considered as continuing,and Suez Water Idaho,Inc.is
requested to provide,by way of supplementaryresponses,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
telephonenumber of the record holder.
FOURTHPRODUCTIONREQUEST
TO SUEZ WATER l DECEMBER 11,2020
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.
REQUESTNO.66:Please provide a copy of the current contract(s)used to obtain
services for facility installations,new construction,and replacements.Please provide and
explain the following:
a.A list of all current contractors;
b.Terms of the fmal contract(s)(i.e.annual,project specific,etc.);
c.The contract development process including whether it is a competitive process;
d.The process describing how requests for proposals are advertised,along with an
example advertisement;
e.A list identifying all areas of specialization and the companies where multiple
companies are awarded contracts dependingon various specialization;and
f.A list identifyingthe specific tasks conducted under the contract(s)and explain if
they are developed as task orders or some other process.
REQUESTNO.67:Please describe the Company's contract services proposal review
process for facility installations,new construction,and replacements including whether the
proposals are reviewed by individuals or a committee composed of Company staff and/or
management,and whether specific review criteria are applied.If review criteria are applied,
please explain whether these criteria are included as part of the 'requests for proposals'(RFP).
Please provide a copy of the criteria and a sample RFP using the criteria.Please provide a copy
of the most recent requests for proposals.Please list the names and titles of the selection
committee involved in the review process.
REQUESTNO.68:For the attached list of work orders and projects,please provide the
source documents,including but not limited to invoices,contracts,bids,change orders,
timesheets,job costing information,budgeted amounts and changes to the initial cost,and all
other source documents and information pertaining to the decision and implementation of the
project.
FOURTH PRODUCTION REQUEST
TO SUEZ WATER 2 DECEMBER l1,2020
REQUESTNO.69:For the attached list of work orders and projects,please provide the
cost-benefit analysis,internal rate of return calculations,and any other metrics considered.
Please explain how that project was the least cost/least risk alternative.Please include the
approval signatures with the associated documentation for each project.
REQUESTNO.70:Please provide a schedule of Contributions in Aid of Construction
(CIAC)from December 1,2015 through September 30,2020 showing project names,dates,
amounts,and accounts used.Please include within your response any significant changes to
CIAC occurring in or planned for 2021.
REQUESTNO.71:With Reference to Exhibit No.11,Schedule 5,"Advances for
Construction,"please provide the source documents that show the additions and refunds
impacting the advance account for years 2016 through June 30,2020,starting with the balance
for December 31,2015.Please provide a schedule of Advances for Construction showing
project names,dates,amounts and accounts used.
REQUESTNO.72:Please provide a list identifyingby month the number of
disconnections for non-payment for calendar years 2017 through 2020 to date.For comparison,
please include the number of customers served,and the number of disconnections as a
percentage of total residential customers for the same period.
REQUESTNO.73:For residential accounts identified as having been disconnected for
non-payment in the Request No.72,please provide the number of accounts that received Suez
Cares benefits by month for calendar years 2017 through 2020 to date.How many of those
customers were subsequently disconnected for non-payment during the followingtwo months?
REQUESTNO.74:Without revealing customer identities or other confidential
information,please provide a spreadsheet showing the average monthlyconsumption of all
customers receiving assistance through the Suez Cares program for calendar years 2017 through
2020 to date.
FOURTH PRODUCTION REQUEST
TO SUEZ WATER 3 DECEMBER 11,2020
REQUESTNO.75:Please provide an update on the Suez Cares program including any
changes to the program since 2015.Please include monthly and annual data for calendar years
2017 through 2020 to date by Company contributions,customer contributions,total dollar
amount awarded to customers,total number of customers assisted,and total amount provided to
El-Ada for administration.
REQUESTNO.76:Please provide the number of incoming calls handled by the
customer service representatives by month for calendar years 2017 through 2020 to date.Are all
incoming calls handled within the Boise office?If not,how are incoming calls handled?
REQUESTNO.77:Please provide a breakdown of the number of incoming calls and
emails from customers to the Company by category (e.g.,payment arrangements,start/stop
service,high bills,disconnections,etc.).Please include all calls,including those calls routed to
another department.Please provide the information by month for the years 2017 through 2020 to
date.
REQUESTNO.78:Please describe the customer self-help tasks that can be handled by
the Interactive Voice Response (IVR)or online (e.g.,bill payment,payment arrangements,etc.).
REQUESTNO.79:Please provide the Company's performance objectives for handling
incoming calls,include objectives for both IVR and customer service representative (CSR)
handled calls.What steps does the Company take if it fails to meet its performance objectives?
REQUESTNO.80:Please provide the average speed of answer for CSR-handled calls
by month for the calendar years 2017 through 2020 to date.
REQUESTNO.81:For calendar years 2017 through 2020 to date,please provide the
information requested below:
a.the number of customers the Company has identified as having a cross connection
control device interconnectedwith their potable water service connection;
FOURTH PRODUCTION REQUEST
TO SUEZ WATER 4 DECEMBER 11,2020
b.the number of customers sent a notice regarding their cross-connection control
device and the reason for the notice,(missing or expired test certificate,improper
device or installation,or other failure to comply with the Company's cross
connection control program,etc.);
c.the number of customers who provided the required test certificates;and
d.how many customers were disconnected for failure to provide remedy?
REQUESTNO.82:Please provide a copy of and describe the Company's policy for
determining the minimum size of meters for new residential or commercial service locations i.e.,
5/8 inch,¾inch,one inch or larger.Does the Company install new 5/8 inch or ¾inch meters
when it replaces old or malfunctioningmeters in residential and business locations?
REQUESTNO.83:Please provide the number of complaints made directly to the
utility for years 2017 through 2020 to date pursuant to Rules 400 to 402 of the Commission's
Utility Customer Relations Rules (IDAPA 31.21.01.400-402),the general nature of their subject
matter,how the complaints were received (in person,by letter,telephone,or email),and whether
a Commission review was conducted.Did the Company change its practices in response to its
analysis of those complaints?If so,please explain the changes and/or modifications made.
REQUESTNO.84:Please provide the audit parameters the Company uses to detect
slowing or stopped meters.How often are reports reviewed,and within what time frame are
field investigations conducted and corrective action taken if necessary?Please provide the
number of meters replaced in years 2017 through 2020 to date,because of age or malfunction.
How does the Company determine whether to rebill customers for usage when a meter
malfunctions?
REQUESTNO.85:Please provide the number and total dollar amount of deposits the
Company is currentlyholding for residential and commercial accounts.Please report the
numbers based on the reason the deposit was requested (termination of service,
misrepresentation of identity,damages,unauthorized service,failure to pass credit screen,
FOURTH PRODUCTION REQUEST
TO SUEZ WATER 5 DECEMBER 11,2020
indebted household,new commercial customer,bankruptcy,etc.)and the customer's rate
schedule.
REQUESTNO.86:Please provide a detailed explanation of the Company's policy for
handling calls after hours,whether for reconnection after a disconnection for non-payment or for
emergency shut-off because of leaks.The Company's office hours are listed as 8:00 a.m.to
4:30 p.m.and the reconnection is offered at a higher charge between 4:31 p.m.and 6:30 p.m.
a.Does the Company offer reconnection or emergency shut-off outside the listed
hours or on weekends or holidays?
b.How does the Company provide support for fire and police emergencies after
hours?
DATED at Boise,Idaho,this day of December 2020.
Dayn Hr ie
Deputy AttorneyGeneral
i:umise:prodreq/suzw20.2dhmhtnc prod req 4
FOURTH PRODUCTION REQUEST
TO SUEZ WATER 6 DECEMBER 11,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11"DAY OF DECEMBER 2020,
SERVED THE FOREGOING FOURTH PRODUCTION REQUESTOF 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 DAVID NJUGUNA
PRESTON N CARTER MGR -REGULATORY BUSINESS
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:mcc givenspurslev.com E-MAIL:David.niuguna suez.com
[e-mail]
SECRETAR
CERTIFICATE OF SERVICE