20201217Staff 87-110 to Suez.pdf

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DAYN HARDIE (ISB No.9917)
MATT HUNTER (ISB No.10665)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE,IDAHO 83720-0074
[phone]
[phone]
Street Address for Express Mail:
11331 W CHINDEN BLVD1 BLDG
BOISE,ID 83714
Attorneys for the Commission Staff
8,SUITE 20 I-A
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-20-02
)
FIFTH 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
MONDAY,JANUARY 11,2021.
This Production Request is to be considered as continuing,and Suez Water Idaho,Inc.is
requested to provide,by way of supplementary responses,additionai 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
FIFTH PRODUCTION REQUEST
TO SUEZ WATER DECEMBER 17,2020
RECEIVED
2020December 17, PM 1:27
IDAHO PUBLIC
UTILITIES COMMISSION
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
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.87:Please explain the increase in the Field Contractors CE 641015
account for the test year expense compared to years 2017 through 2019 provided on Page No.14
of Exhibit No.10,Schedule 1.Tn the explanation,please identify the specific changes resulting
in the increase compared to those three years.
REQUEST NO.88:Please provide additional details of the requirement change for
Synthetic Organic Chemical (SOC)monitoring mentioned on Page Nos.10-11 of Witness Cary’s
direct testimony.In the response,please include:
a.A description of SOC monitoring and why it is required;
b.The reason why the change in requirements has occurred;and
c.An itemization of the $20,000 cost required for SOC monitoring.
REQUEST NO.89:Please provide additional details of the “Notify”customer
notification system mentioned on Page No.12 of Witness Cary’s direct testimony.In the
response,please include:
a.An itemization of the annual costs required for the “Notify”system,and
b.An explanation why the system is required.
REQUEST NO.90:Please provide additional details of the “Cityworks”license
mentioned on Page No.12 of Witness Cary’s direct testimony.In the response,please include:
a.An itemization of the annual costs required for the “Cityworks”licensing costs;
b.The number of current licenses and new licenses that will be obtained,and
c.An explanation why additional licenses are required for new employees.
FIFTH PRODUCTION REQUEST
TO SUEZ WATER 2 DECEMBER 17,2020
REQUEST NO.91:Please provide additional details for the “SAMS Water Quality”
management software mentioned on Page No.12 of Witness Cary’s direct testimony.In the
response,please include:
a.An itemization of the annual costs required for the “SAMS’software costs;and
b.An explanation why the “SAMS”software is required.
REQUEST NO.92:Please explain the increase in the Safety Expense account for the
test year expense (Line No.5)compared to the expenses in years 2017 through 2019 provided on
Page No.24 of Exhibit No.10,Schedule I.In the explanation,please identify the specific
changes resulting in the increase compared to these years.
REQUEST NO.93:Please provide additional details for asbestos training mentioned on
Page No.17 of Witness Cary’s direct testimony.In the response,please include:
a.An itemization of the $3,750 annual cost required for asbestos training;
b.A description of asbestos training and cite the safety requirement(s);
c.An explanation for why asbestos training was not included in the test year
expense;
d.A description of how the training is administered (e.g.,online,in person);and
e.If multiple methods of administering the training is available,the cost difference
of the different methods provided in part (d)above.
REQUEST NO.94:Please provide additional details for asbestos and chemical
exposure assessment mentioned on Page No.17 of Witness Cary’s direct testimony.In the
response,please include:
a.An itemization of the S8,000 annual cost required for the asbestos and chemical
exposure assessment;
b.A description of asbestos and chemical exposure assessment and cite the safety
requirement(s);and
c.An explanation for why the asbestos and chemical exposure assessment costs
were not included in the test year expense.
FIFTH PRODUCTION REQUEST
TO SUEZ WATER 3 DECEMBER 17,2020
REQUEST NO.95:Please provide additional details for the personal protection
expense mentioned on Page No.17 of Witness Cary’s direct testimony.In the response,please
include:
a.An itemization of the S 10,663 annual cost required for personal protection;and
b.A description of personal protection expense and cite the safety requirement(s).
REQUEST NO.96:Please provide additional details for Tank Painting mentioned on
Page No.18 of Witness Cary’s direct testimony.In the response,please include:
a.The size and type of tank for the Barber,Hulls Gulch,and Hidden Hollow tanks;
b.An explanation why painting of the Barber tank interior,Hulls Gulch interior and
exterior,and Hidden Hollow exterior painting projects were required;
c.An itemization of the costs for painting the Barber tank interior,Hulls Gulch
interior and exterior,and Hidden HoLlow exterior painting projects;
d.The budgeted and actual expense for the Barber tank interior,Hulls Gulch interior
and exterior,and Hidden Hollow exterior painting projects;
e.All quotes received for the Barber tank interior,Hulls Gulch interior and exterior,
and Hidden Hollow exterior painting projects;and
f.The expected number of years before the Barber tank interior,Hulls Gulch
interior and exterior,and Hidden Hollow exterior painting projects will need to be
painted again.
REQUEST NO.97:In Witness Cary’s direct testimony,Page No.11,line 18-19,please
provide a copy of the new payment processing agreement/contract with the re-negotiated
processing cost reduced from $1.99 to $1.20 per transaction.
REQUEST NO.98:Please provide an update to the SUZ-W-19-0l Semi-Annual
Deferred Convenience Fee Report filed in November 2020 to include costs through November
2020.
FIFTH PRODUCTION REQUEST
TO SUEZ WATER 4 DECEMBER 17,2020
REQUEST NO.99:Please provide additional information related to the 20%purchase
of SUEZ Water Resources LLC by P0GM as stated in Witness Cagle’s direct testimony,Page
No.3,Line Nos.17 and 18.Please identify all SUEZ Water Idaho ratepayer benefits from the
sale?
REQUEST NO.100:Please provide a list of all M&S Shared Services positions that
allocated time to SUEZ Water Idaho.Please include their salaries and the number of hours spent
on SUEZ Water Idaho,Inc.directly.Please also include the percentage pay increase received
per year for each employee since 2015.
REQUEST NO.101:Please provide additional descriptions of the M&S Shared
Services departments and the cost-benefit analysis of them being located outside of Idaho.
REQUEST NO.102:Please provide the amounts of the M&S Shared Services by
department allocated to SUEZ Water Idaho for the last five years.
REQUEST NO.103:Please provide a detailed cost breakout,by employee,in Excel
format with formulae intact,of the SUEZ Water Idaho labor found on M&S Shared Assets,tab
2020 Alloc Factors,of $7,111,919.
REQUEST NO.104:Please provide additional description of the M&S Shared Services
BTS department #424,425 and 426.Include in your response the work they perform and
invoices,plus all relevant information directly associated with SUEZ Water Idaho.
REQUEST NO.105:Please provide a description of the work the M&S Shared
Services,Legal,directly performed for SUEZ Water Idaho.
REQUEST NO.106:Please provide a copy of the 2018 and 2019 reports of the M&S
Shared Services,Internal Audit,performed on SUEZ Water Idaho.What were their findings and
any concerns reported?Were changes made based on any findings or concerns?
FIFTH PRODUCTION REQUEST
TO SUEZ WATER 5 DECEMBER 17,2020
REQUEST NO.107:Please provide the cost-benefit analysis of the M&S Shared
Services provided to SUEZ Water Idaho in all departments.
REQUEST NO.108:Please provide a copy of the approval from SUEZ Water Idaho
management agreeing to the new 3-factor allocation method used to allocate M&S Shared
Services.
REQUEST NO.109:The M&S Shared Assets workpapers,tab labeled 12m 6302020,
has a description stating “Period Ending Dec.31,2019”but the sheet includes 2020 numbers.
Please explain the discrepancy and how a report ending in December 31,2019 includes 2020
numbers.If done in error,please provide an updated excel spreadsheet to include current 2020
numbers through June 30,2020.Please also provide supplemental information through
November 30,2020 in your response.
REQUEST NO.110:Tn Order No.34405 approving the Company’s assumption of
responsibility for the cost of handling Western Union transaction costs,the Commission stated,
“We also expect cost reductions in other areas to offset at least a portion if not all of these
transaction costs.”The Commission further stated,“We expect Suez to reflect reduced costs not
only in the test year for the general rate case,but to show associated costs reductions that can be
quantified in the regulatory accounts during the deferral period.”Please provide a schedule
showing the cost reductions in other areas that offset the transaction costs,identifying the
accounts and the amounts recorded.
DATED at Boise,Idaho,this day of December 2020.
Harie
Deputy Attorney General
i:urnisc:prodrcq/suzw2O.2dhnihtn prod req 5
FIFTH PRODUCTION REQUEST
TO SUEZ WATER 6 DECEMBER 17,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS lTh DAY OF DECEMBER 2020,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE COMMISSION
STAFF TO SUEZ WATER IDAHO,INC.,IN CASE NO.SUZ-W-20-02,BY E-MAWING
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
P0 BOX 2720 461 FROM ROAD SUITE 400
BOISE ID 8370 1-2720 PARAMUS NJ 07052
E-MAIL:mcc@ givenspursley.com E-MAIL:[e-mail]
[e-mail]
SECRE ARY
CERTIFICATE OF SERVICE