20201223Staff 111-122 to Suez.pdf

DAYN HARDIE (ISB No, 9917')
MATI HUNTER (ISB No. 10665)
DEPUTY ATTORNEYS GENERAL
TDAHO PUBLIC UTILITIES COMMTSSION
PO BOX $72A
BOISE,IDAHO 83720-W74
(208) 334-03 r 2
[phone]
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDC 8, SUITE 2OI-A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE TIIE IDAIIO PUBLIC UTILITIES COMMISSION
IN THE IT{ATIreR OF SUEZ WATER IDAHO
INC.'S APPLICATION FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
WATER SERVICE IN TIIE STATE OF IDAHO
cAsE NO. SUZ-W-2042
SIXTH PRODUCTION
REQUEST Or THE
coMIldISStON STArr 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 ldaho,
Inc- provide the following documents and information as soon as possible, but no later than
WEDNESDAY, JANUARY 13, 202I.
This Production Request is to be considered as continuing, and Suez Water ldaho, Inc. is
reguested 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 dccuments 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
SD(TH PRODUCTTON REQUEST
TO SUEZ WATER DECEMBER 23, 2O2O
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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. 111: Please update the projected amounts in Witness Cary's Exhibit
No. 11, Schedule No. 2 with actual amounts as available. Please provide in Excel format with all
formulas intact.
REQUEST NO. 112: Please provide the monthly plant-in-service balances from 2018 to
present in the same format as Witness Cary's Exhibit No. 11, Schedule No. 3, Page No 2. please
provide in Excel format with all formulas intact.
REQUEST NO. 113: Please provide supporting documentation for the cash
contributions stated in Witness Cary's Exhibit No. 10, Schedule No. 1, Page No. 28. please
include an explanation of each contribution detailing the customer benefit and prudency.
REQUEST NO. 114: Please provide supporting documentation of the Deferred
Customer Payment Fees stated in Witness Cary's Exhibit No. 10, Schedule No. 1, Page No. 31.
REQUEST NO. 115: Please provide a schedule of the maintenance deferred and
overtime accrued due to staffing levels that will be cured by the hiring of ten employees. Please
quantify the dollar amount of overtime attributable to understaffing that is currently included in
the test year ending June 30,2020, and in the pro forma adjustments.
REQUEST NO. 116: In 2015, the Company was able to function in a safe, reliable
manner with 882 customers per employee. Please explain why the Company now proposes to
operate at 816 customers per employee.
REQUEST NO. 117: Please provide a copy of the company credit card and purchase
card policy, if applicable.
SXTH PRODUCTION REQUEST
TO SUEZ WATER 2 DECEMBER23,2O2O
REQUEST NO. 118: Please provide justification, including why no adjustments are
needed for the Unadjusted Operating and Maintenance Expenses not included in test year
adjustment amounts, such as adjustments 14, 15, 16, and 18.
REQUEST NO. 119: Please provide the transaction detail reports for the following
FERC accounts, in Excel format with formulas intact:
a. 50650 - Include all sub accounts - Office Expense;
b. 50655 - Include all sub accounts - Miscellaneous Expense;
c. 91860 - Include all sub accounts - Other Awards;
d. 92300930 Bank Charges-A&G Ops Miscellaneous General;
e. 92600920 Other G&A Exp-A&G Ops Pension &Benefit;
f. 92600930 System Water Use-A&G; and
g. 92600932 Other G&A Exp-A&G Maintenance planr.
REQUEST NO. 120: [n reference to Production Request No. 14, please provide the
cost/benefit analysis and identify all benefits Idaho ratepayers receive from hiring Red Sky Inc
and Donahoe Pace & Partners LTD.
REQUEST NO. 121: Please provide the cost/benefit analysis, business case, and
Internal Rate of Return for the new Consumer Confidence Report (CCR). Please provide
documentation supporting and explain all requirements for the change to send customers the
CCR biannually startingin2O2l. How many additional bill inserts will the software provide in
2021? Please provide a breakdown of the additional advertising cost for production,
advertisement placement, and postage for distributing the CCR twice a year.
REQUEST NO. 122: Please provide a detailed list of all assets retired, gross salvage
value, and the cost to remove for years 2004 through end of 2019,for the following accounts.
Please provide the response in excel format with formulas intact.
a. 303 Land, Land Rights & Water Rights;
b. 304 Structures and Improvements;
c. 307 Wells and Springs;
SXTH PRODUCTION REQUEST
TO SUEZ WATER DECEMBER23,2O2O3
d. 311 Pumping Equipment;
e. 320 Purification Systems;
f. 331 Transmission and Distribution Mains;
g. 333 Services;
h. 334 Meters; and
i. 346 Communication Equipment.
DATED at Boise, Idaho, this )! dLu, of Decemb er 2020
Matt Hunter
Deputy Attorney General
i:umisc:prodreq/suzw20.2dhmhtnc prod req 6
SXTH PRODUCTION REQUEST
TO SUEZ WATER 4 DECEMBER23,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23.d DAY OF DECEMBER 2020,SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSTON STAFF TO SUEZ WATER IDAHO, INC., IN CASE NO. SUZ-W-20-O2.BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GTVENS PURSLEY LLP
POBOX2720
BOrSE D 83701-2120
E-MAIL: mcc @ givenspursley.com
prestoncarter @ givenspursley. com
LORNA K. JORGENSEN
JOHN C. CORTABITARTE
ADA COUNTY PROSECUTING
ATTORNEY'S OFFICE
CIVIL DIVISION
2OO W. FRONT STREET, ROOM 3191
BOISE, ID 83702
E-MAIL: [e-mail]
SCOTT B. MUIR
DEPUTY CITY ATTORNEY
BOISE CMY ATTORNEY'S OFFICE
150 N. CAPMOL BLVD.
P.O. BOX 500
BOISE,ID 83701-0500
E-MAIL: boiseci attorney@ org
BRAD M. PURDY
20lg N. 17rH ST.
BOISE, D 83702
E-MAIL: [e-mail]
DAVID NJUGUNA
MGR _ REGULATORY BUSINESS
SUEZ WATER MGMNT & SERVICES CO
461 FROM ROAD SUITE 4OO
PARAMUS NJ 07052
E-MAIL: David.njuguna@ suez.com
NORMAN M. SEMANKO
PARSONS BEHLE & LATIMER
8OO W. MAIN ST., STE.13OO
BOISE, D 83702
E-MAIL: [e-mail]
B oi sedocket @parsonsbehle.com
MARTY DURAND
PIOTROWSKI DURAND PLLC
1O2O MAIN ST., STE. 440
P.O. BOX 2864
BOISE,ID 83701
E-MAIL: martli @idunionlaw.com
KEN NAGY
ATTORNEY AT LAW
P.O. BOX 164
LEWISTON, ID 83501
E-MAIL: knagy @lewiston.com
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF
THORVALD A. NELSON
555 17rH ST., STE. 3200
DENVER, CO 80202
E-MAIL: darueschhoff @ hollandhart.com
tnelson @ hollandhart.cqm
aclee@ com
gl garganomari @ hollandhart.com
JIM SWIER
GREG HARWOOD
MICRON TECHNOLOGY, INC.
SOOO S. FEDERAL WAY
BOISE,ID 83707
E-MAIL: [e-mail]
[e-mail]
Y
CERTIFICATE OF SERVICE