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HomeMy WebLinkAbout20201231Suez to Staff 60-64.pdfMichael C. Creamer (lSB No. 4030) Preston N. Carter (lSB No. 8462) Givens Pursley LLP 601 W. Bannock St. Boise, lD 83702 Telephone: (208) 388-1200 Facsimile: (208) 388-1 300 mcc@qivenspurslev.com p resto nca rte r@o iven sp u rslev. co m !N THE MATTER OF THE APPLICATION OF SUEZ WATER IDAHO INC. FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO i. , .:: f ii i., i}i r ili9 ;I;; Hi i I fifi ll}: Stu il',; t. ,-, *, t:J ,--r ;'a 'i', , ': r;ol'tilltl,;.: *,,=:;:rr.Sii#;'i Attorneys for SUEZ Water ldaho lnc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case No. SUZ-W-20-02 SUEZ WATER IDAHO INC.'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF SUEZ Water ldaho lnc., ("SUEZ Watef or "Company") submits the following responses to the Third Production Request of the Commission Staff to SUEZ Water, dated December 3,2020. DATED: December 31, 2020 SUEZ WATER IDAHO INC. / *-----.: * 4__t* By: Michael C. Creamer Preston N. Carter Attorneys for Ap plicant SUEZWATER'S RESPONSE TO THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF.l 1 5461 224 _1 .DOCX [30-209] CERTIFICATE OF SERVICE I certify that on December 31,2020, a true and correct copy of the foregoing was served upon all parties of record in this proceeding via electronic mail as indicated below: Commission Staff Jan Noriyuki, Commission Secretary Electronic Mail Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A Boise, lD 83714 ian.norivuki@puc.idaho.clov Dayn Hardie Matt Hunter Deputy Attomey General ldaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A Boise, lD 83714 davn.hardie@puc.idaho.oov matt. h u nter@puc. idaho.oov lntervening Parties Ada County: Lorna K. Jorgensen John C. Cortabitarte Ada County Prosecuting Aftorney's Office Civil Division 200 W. Front Street, Room 3191 Boise, lD 83702 civi I pafiles@adaweb. net CAPAI: Brad M. Purdy 2019 N. 17th Street Boise, lD 83702 bmpurdy@hotmail.com lnteruenors: Marty Durand Piotwrowski Durand PLLC 1020 Main Street, Suite 440 P.O. Box 2864 Boise, lD 83701 martv@idunionlaw.com SUEZWATER'S RESPONSE TO THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF.2 1 5461224_1.DOCX [3G209] Electronic Mail Electronic Mail Boise City: Abigail R. Germaine Deputy City Aftorney Boise City Attorney's Office 150 N. Capitol Blvd. P.O. Box 500 Boise, lD 83701-0500 ao erm a i ne@cityofbo ise. o rq Suez Water Customer Group: Norman M. Semanko Parsons Behle & Latimer 800 W. Main Street, Suite 1300 Boise, ID 83702 NSema nko@ parsonsbehle.com Boisedocket@ parsonsbeh le. com ldaho Fair House Council, lnc. Ken Nagy Attorney at Law P.O. Box 164 Lewiston, lD 83501 knaov@lewiston.com Micron Tech nology, I nc. Austin Rueschhoff Thorvald A. Nelson Holland & Hart 555 17tt' St., Suite 3200 d aru esch hoff@ hol la nd ha rt. com tn elson@ holland hart. om aclee@ hol la nd ha rt.com olqaroanoamari@hollandha rt.com Jim Swter Greg Harwood Micron Technology, lnc. 8000 S. FederalWay iswier@micron.com obharwood@micron.com ,, P; a-_-u Preston N. Carter SUEZ WATER'S RESPO]ISE TO THIRD PRODUCTION REQUEST OF THE GOiltrllSSlON STAFF - 3 1W|u4_1.OOCX[3G200] Preparer/Sponsoring Witness J. Cary REQUEST NO. 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. RESPONSE NO. 60: The Company records an incremental adjustment to its bad debt reserve to reflect the expected credit losses associated with the effect of the COVID-19 pandemic. The adjustment is based on a combination of the results of two financial models. The accounts receivable aging model is reflecting the effect of the increase in the aging buckets year over year, and the second mode! is using the methodology from the American Water Works Association ("A\AA//A') COVID-19 financial impact report on water utilities. The A\ A/VA model incorporates the impact of the unemployment rate factor before and after the pandemic to determine the expected incremental delinquencies. The Allowance is calculated based on the historical rolling S-year average of uncollectible Accounts Receivable broken out by the age of the amounts outstanding (i.e. 0-30 days, 31-60 days, 61-90 days, 91-120 days and greater than 120 days) per the Accounts Receivable aging report. The analysis is updated on a monthly basis. Once the general reserye calculation is performed, the initial reserve balance is compared to the historica! S-year write-off average. The greater of the calculated initial reserve and the historical 5- year write-off average will be included in the month's reserve balance. For SUEZ Business Units with annual revenue Iess than $10 million, '100o/o of the Accounts Receivable balance that is outstanding for more than 90 days will be reserved for. ln addition, a reserve may be increased for specific one-off items, such as bankruptcies, lawsuits and back billing initiatives. Corporate Accounting posts a journal entry in the General Ledger in PeopleSoft to adjust the Allowance for DoubtfulAccounts and is recorded as a Bad Debt Expense - Provision. Write-offs are coded as a direct debit to Bad Debt Expense - Write-off and a credit to Customer Accounts Receivable. The procedure of writing off a customer Account Receivable within the CC&B billing system falls under the responsibility of the Customer Service department and is approved in accordance with the approvalauthority in the Delegation of Authority schedule. In response to the COVID-19 pandemic the Company ceased all collection activities in mid-March 2020 tor every customer class as well as reconnected services for previously disconnected customers who were past due on their account. All customers continue to receive water service regardless of their ability to pay through the end of 2020. suz-w-20-02 IPUC DR 60 Page 1 of2 SUEZ WATER IDAHO INC. GASE SUZ-W-20-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Customers continue to receive billing invoices, courtesy notifications if no payment has been received on their account, and reminders to contact the Company should they require extended payment arrangement plans or are in need of an additional assistance. While the majority of customers continue to make payments on their account regularly, a portion of customers have not made a payment on their account since March, are more than one bill payment behind and are requiring additional time to bring their account balance to current. Beginning in late December 2020, the Company resumed collections activities in a limited capacity. Commercial customers with large dollar amount past due balances will receive reminder notices, followed by disconnection warning notices if no payment is received on the account or no extended payment arrangement has been established. Potential service disconnections for Commercial customers would restart no earlier than January 2021. Residentia! customer collections activities will remain on hold through the end of 2020 and wil! be re-evaluated for restart after the New Year. While the full economic impact of the pandemic on customers' ability to pay is difficult to predict, the Company's Accounting staff have calculated the anticipated bad debt expense impact due to COVID-19 as of November 2020 as $412,061. Please see Attachment 1 for the calculation of the bad debt reserve. This amount is updated monthly. The bad debt reserve adjustment included in the Company's filing Exhibit 10 Schedule 1 Adjustment 18 at that time reflected a July 2020 anticipated impact due to COVID-19 of $327,930 as shown in Attachment2. Due to the suspension of collections activities, the amount of actual bad debt expense reflected on the Company's books as of November 2020 is lower than prior year's level. The impact to bad debt expense will become more evident after collections activities resume for all customer classes. As of November 2020, the Aged Accounts Receivable (for water service agreements without excess credits) over 30 days past due amount reflects a $1.1M balance versus same period 2019 of $0.6M, or a $0.5M increase, while the balance 0 to 30 days balance increased by $O.gfvl. Through November 2020, 1260 customer accounts carry a past due balance over 180 days old compared to just 234 customer accounts as of November 2019. There are 64 active bankruptcies as of November 2020 compared to 57 for the prior year. Despite the Company's efforts to encourage customers to establish payment arrangements for those struggling with keeping their account current, the number of customers in an active payment arrangement plans with a balance due has decreased from 370 in 2019 to 123 in 2020. As collections activities resume however, the number of customers utilizing the Company's extended payment arrangement plans including the 12-month option are expected to grow significantly. suz-w-20-02 IPUC DR 60 Page 2 ol 2 CASE NO. SIJZ-W.20-02 Response No. 60 Affachment 1 Excel Spreadsheet Provided Separately in Native Format CASE NO. SUZ.W.2O-02 Response No. 60 Attachnent2 Excel Spreadsheet Provided Separ ately in Native Format SUEZ WATER IDAHO INC. cAsE suz-w-20-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness :J. Cary REQUEST NO. 61: PIease provide supporting documentation for the following transportation expenses as shown in Witness Cary's Exhibit No 10, Schedule l, Page 21.|n 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. !nsurance f . Depreciation g. VA Allowance RESPONSE NO. 61: See attachment 1 for supporting details a. Lease Cost ! PIease see aftachment 2. The projected amounts include estimates for potentia! replacements of expired leases on 31 vehicles. There are additional estimates on 2 new 2020 Ford Ranger trucks just received in December 2020.2021 estimates also include 1 new Ford F-450 as a replacement for the valve maintenance truck, 1 new Ford F-150 for a new T&D Supervisor and 1 new Ford Ranger for use in the meter reading group. b. Fuel ! 2021 forecasted estimate is based on 50,500 gal. priced at $2.35/gal estimate and 10,000 ga!. diesel priced at $2.13/gal estimate c. P-card maintenance materials, outside service, GPS Fees n 2021torecast based on anticipated return to normal maintenance suz-w-20-02 IPUC DR 61 Page 1 of2 and other costs. 2020 had severa! unplanned larger maintenance repairs. d. Mechanic payroll and benefits ! 2021 forecasts mechanic Iabor of $69,802 plus 60% fringe estimate of $41,881 for a total of $111,683 e. lnsurance ! The 2021 insurance estimate is based on Suez corporate insurance policy and cost review. The updated insurance cost is not yet available. We will updated this response once we receive it. f . Depreciation! The202l depreciation forecast initially filed was based on a2020 budget estimate that was the most current information at the time. However, current monthly depreciation is $1500 which would result in an annual depreciation expense estimate of $18,000. g. VA Allowance ! Vehicle allowance for the General Manager of $916.66/mnth and, Director of Engineering, of $550/mnth. Totaling $17,600 annually. suz-w-20-02 IPUC DR 61 Page 2 of 2 HEE!Bol *4f;EOo_ :0,?rE)58 (o dz d,otatoG citr EH(!0pqrrlEN =aBaato to2 .9,6 ao .9 !lo oz o6 6/)u:l F(oci N(a 3s s$oo JJ66tDo88r.)Odo1.lF E o E 4a, o EI Eo oooiN (r)|('l.,oc, loFu! d, loF(n6 NoaC'GeEP o. c)d,("io oN@FN6 @qot C'oo oNC'd o6a ot! !tq(o ooodN rood (r: (i) a?G o(,t@Ai Nro6 t-(otl; (rtG6t a €EC' E=. :E (oF.!lnao oNqolo: (t:(!lodN 6raNciF cl@@ C,iat (':NNd oorO F. c, $ 5) E trI 2o c.Ioz dF o 6oooc6E6 eoc(U F- oEo oocEfoEog =o o-E(,otllotrzut.ul uJ (,o(, o ._c6oGosio C'Eo ql a,o Fzltzoc.o() ]ox E6ooocIGr 8.oc(! F oto d a)ocGcoc'6 =ooEo uJozel! too5 FU'oo oJoooIJJzu =FIJJt uio2 2uJFz =utJsE,lUF = oo-o uiuJuJILFzuJ =IIJo z = zooL =t!ioF dFo6lrJ&. oIJJ UJltui!IFo tDc oo.E(nc uJ 06 oCDGco =Eotroo op .c,0, zol- ooJJ oGI@(o 06 6ooEo 8ooI ooooop -co Ic EoN6ao 06o9 E E,qr6;.x> pu E.cg6d,88?J-9 i llmh fh. PurciraPrb. N.t BDIVCI r ot l0f25t2d flo rcRD F19sUPEXA8 4WD Lrar! arplrcd - P&ntal rcpL@frant undar nUil for D21 l.i...rnlr.d - D6L.lhl mDl.om.nt und.. dua 16r D1 1frA1EWF6163 IdO TENW TM U1-BBC @NV @ S DUMP IRULX,fir mrn rGn qrpFRaB lwD r.r-.r^|..i - ril.ilbl r.b..h.nt trna..de 6r Dl mltmebF mREGde l..o.r6lrd - p6t ntl.l r..lm.m.il u^d.r r.d& hr b21 rfratdtD(EMa .....rnld . pend.lr.tu6.nt md.r rtu br 2021 )daa6aD asr9F aD 3uv awo .....rnH - Dd.nd.l r.bh.Mt und.r r.tu6i 2Ol ..r. .rDlEd - Pohilhl nDhm.nt und.r nrfl tor 2el IOtatoro F19tE6 aB .r.. ddEd - Dabilhl n6bdn.nt o& ndd tur t21 mr!E6r6 Ers{rpttale ..o d6d - Pd.nu! r.ohen.nt und.r tu tu 421 ,d.hPD EiS ilPERdB 'WD ,O1BMD 'BSD'HNSAI .,...rnld - Dm^61-.L..mnt ud..ndd 6r t l r^rrhah aacnaHl<sra t ..n .tDr.d tov 2@o ' Pohnd.l ndelld und.r Elil ior I21 rEilirMs(Giom ,otl loRo 15ffi ,r- .r^l.J Nil dd , DaLnfi.l ddr.tunr nnd.r Eda 161 2orl 2d! XENW T& 121i88C @trV 6S,dt hcn Frs eF6 ale tn4 r---924c99.I 5*ats 3r o[FqD F1$SUPERASaWOmrrr6r6 Etcn qrDrRa a 6lw 5 12,S.O htD FTS$PER6 ,dTtotb Fi$qtpFRdB rmrr'wFMlqra tolTtoHN ald ucxHoE,otrhnD FlsEFG alB2wD 122 r---199E !3 a2 F19 REG 4 4WD 122 bil FoRD E1$$patdB4WD 145 FORD FSO$PER4'WD 145hrr.r ft Mrxr EYalvAloa lnEX[83ff17&3rffirrE2a1179 s-l._@a ctt6s ,fi e EorD yr^x<rra6NNEd dGO V il LW8 WiDR ,o20toRD f1s tFdlaB!t(EEr4 020 FotD fl$ e^N.EerYrqroEralt6fr B ,mr rnrh llxaEr $r9FAaAE ffi[ffidaovEHnB SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No.61 Attachment 2 Page 1 of 1 5UZ-W-2m |PUCOR6l lofl Preparer/Sponsoring Witness :J. Cary REQUEST NO. 62: Please provide a schedule showing the year, make, and model of the Company's currentfleet of vehicles, and the fleet used forWitness Cary's Exhibit No 10, Schedule l, 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. RESPONSE NO. 62: Please see Attachment 1 for a schedule showing the current fleet of vehicles and Attachmenl2for the fleet used for Exhibit No 10, Schedule I, Page 21. The increase from the current flegt of 63 vehicles to the projected 69 requested for in this rate case are as follows: . (2) additionalleased vehicles acquired in December2020 (both 2020 Ford Ranger 4x4 SuperCab). (1) new Ford F-450 planned for lease in 2021 for valve maintenance (heavier duty truck replacing lighter duty truck currently used. Replaced vehicle to be repurposed). (1) new Ford F150 4x4 planned for Iease in 2021 as new T&D Supervisor truck. (1) new Ford Ranger planned for Iease in 2021for use by Meter Reader group. (1) 1996 Ford Ranger (previously sold) inadvertently included in 2021fleet count but with no lease budget cost The only vehicle purchased outright and owned by Suez is the 2019 Deere 60G Mini Excavator. AII other vehicles are leased. suz-w-20-02 IPUC DR 62 Page 1 of I SUEZ WATER IDAHO INC. cAsE suz-w-20-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Llne NO-DoscrlDtlon (Yeor, Make Modol)Note vtN Leesedrowne d Purchale Prlco Nd Book Value c of 1U%m 1 2006 KENWOOD TsOO 121'BBC CONV CAB SBA DUMP TRUCK Lease expired 1NKD|"U9X16Rt29397 owned 2 2OO8 FORD RANGER SUPERCAB Lease exgired 1FrYR14E18PA88046 ovvned 3 2OO8 FORD RANGER SUPERCAB Lease expired 1FTYR14E08PA9it811 Owncd 4 2@9 FORD RANGER REG CAB Lease cxDired 1FTYR1OD89PAA6777 Owned 5 IO1O FORD F15O SUPERCAB '[WD Lease expired 1FTEX1EWXAFC53163 Owned 5 ZO1O KENW TsOO 12I'BBC CONV CAB SBA DUMP TRUCK Lease expired 1NKDt09X8At273562 Owned 7 2O11 FORD F2sOSD SUPERCAB 4WD Lease cxpircd 1FD7X2B588E468474 Owned 8 2012 FORD F15O REG CA8 Lasc cxDired 1FrMF1CM2CKD82755 owncd 9 2013 FORD F15O REG CA8 Lease exDircd 1FTMF1CM5DFC50897 Owned 10 2013 FORD F15O REG CAB Lease exDired 1FTMFlCM8DFC5O898 Owncd 11 2013 FORD F15O SUPERCAB Lease exDired 1FTVX1CTXDrc11111 Owned t2 2013 FORD F15O SUPERCAB Lease rxDir.d 1FTEX1CM1DXE99438 Own.d 13 2013 FORD F2sOSD SUPERCAB Lrase rxoirrd 1FD7X2A61DEB52625 ownad s t4 2014 FORD ESCAPE 4D SUV FWD fease aroired 1FMCUOF75EUD3313rt own.d (s 15 2014 FORD ESCAPE 4D SUV FWD Leas. axoi.ed 1FMCUOF73EUAO5795 owh.d t s 15 2O1' FORD F15O REG CAB Lease axoired 1FTMF1CM1EFB5(xI45 Ownpd s s t7 2O1A FORD F15O REG CAB faasc eroired lFTMF'CM3EF85II'!16 Owned s s 18 2014 FOND F15O REG CAB fEase aroired lFTMFlCMSEFB$XU7 owned s s 19 2014 FORD T15O SUPERCAB Lrese sDired IFTEXlCMSEFBs(xla8 ovvned s s 20 2O1A FORD F150 SUPERCAB faasa arbirad 1FTVXtCr6EKE59459 orryncd s 5 21 2014 FORD F15O SUPERCAB 4WD faa<a arbirad IFTEXlEMOEFBS(x)49 Owncd s s 7)2014 FORD F15O SUPERCAB 4WD Lease €xpirld 1FT\D(1ET6Erc59460 Owned s 2a 2014 FORD FIsO SUPERCAB 4WD lFTEX1EM5EKG1O7O9 Leased 393.90 AL 2014 JOHN 410 BAC|(HOE 1TO410t()('EE260336 Leas€d 4.881.(xr 25 2014 rOHN 410 BAC(HOE Lcase .xpired lT0410KXCEE259281 Owned 26 2OI5 FORD F2sOSD SUPERCAB lease expired 1FD7X2A69FEAs3697 Owned 27 2015 FORD F35OSD SUPERCAB Lcase expired 1FD8X3E63FEA47527 Owned 28 2015 FORD F550SD CHASSTS CAB Lease exDirad 1FDOX5GY8FEA839O2 Owned 29 2015 FORD F550SD CHASSTS CAB Lcase axDircd lFDOXSGY2FE800046 Owned 30 2015 FORD F650SO 3FRNX6.tP3FV646670 L€asad 1.511.63 31 2015 FORD F650SD 3FRNX5tP7FV546559 Leased 1.780.O9 32 2015 FORD F650SD 3FRNX6tP3FV646657 Leased 2.M7.5 33 2015 KENW T8(n 121"BBC CONV CAB SBA 1NKDL79X6FJ437746 Leased 19.920.0Ou2015 FORD F15O REG CAB 1FTMF1C83GKES5059 Leased 6.506.43 35 2016 FORD F15O REG CAB 4WD 1FTMF1E8XGFC48283 Leased 7.525.66 36 2016 FORD F15O SUPERCAB 1FTEX1C86GFC48284 Laased 7.SL).90 37 2015 FORD F15O SUPERCAB 4WD 1FTFXlEG6GXFOO275 Leased s 12.503_07 38 2016 FORD F3sOSD SUPERCAB DRW 1FD8X3G63GED30699 Lcased s 3 163o2.7t 39 2017 FORD F15O SUPERCAB 1FTEX1C87HKE2593S Leased s s 11.430.10 40 2017 FORD F15O SUPERCAB 1FTEX1C89HKE25936 Lcased s s 11.413.34 4t 2017 FORD FlSO SUPERCAB 1FTEX1C8SHKE25934 Ieased s S 12,/105.49 42 2O17 FORD F25OSD SUPERCAB AWD 1FD7X2861HEE(xl674 Leased s s 20.676.98 43 2017 FORD FSSOSD CHASSTS CAB 1FDOX5GY9HE841924 Laased s s 29.886.44 44 2017 rOHN /t1OL BACI(HOE 1T0410tXVHF31l38a Lcased s s 58.062.47 4E 2O1A FORD F15O REC CAB 2WD 122 lFTMFlCBXI(F17797 Llased s s 16.675.32 L6 2018 FORD F15O REG CAB 4WD 122 1FIMF1EB5JXF17798 Le.3ed s s 20.062.27 47 2018 FORD F15O REG CAB 4WD 122 lFTMFlE87.,XF17799 Lmsed s s 20.062.27 4a 2018 FORD F150 SUPERCAE 4WD t4s lFTEXIEBUKFTT8O2 Leased 20.802.96 49 2018 FORD F15O SUPERCAB 4WD I45 lFIEXlEBX'Kt17801 Leasad 20.097.80 so 2018 FORD F15O SUPERCAB 4WD 145 lFTEXlE83.lKF17803 Leased 20.802.96ql2019 FORD TRANSIT CONNECT CARGO VAN TWB WRDR NMOl.s7825K1391392 Leased 20.244.50 52 2019 FORD TRANS]T CONNECT CARGO VAN TWB WRDR NMots7827K1391393 Leased 20.244.50 53 2019 FORD TRANS]T CONNECT CARGO VAN TWB WRDR NM0ts7829Kl391394 Leased 20.244.15 54 2019 FORD TRANSIT CONNECT CARGO VAN TWB WRDR NM0LS7E23Kl39t391 Leased 31.014.25 55 2020 FORD F150 1FTEX1EBOLKE88778 Leasrd s s 33.178.71 56 2020 FORD F150 IFTEXlE89Lt(E88777 Leased s s 32.835.09 57 2020 FORO F150 IFTEX1E87LKE88776 Leased 34,581.00 58 2020 FORD F150 1FTEX1EB5TKE88775 Leased 35,111.12 59 2020 toRD F150 1FTEX1E83LKE88774 Leased 35,110.65 6{)2020 FORD F150 1FTEX1EB1TKE88773 Leascd 35.111.12 61 2020 FORD F150 1FTEX1EBXLKE88772 Leased s s 34.578.03 62 2020 FORD F-150 1FtEX1E51tKE74981 [eased s 33.212.59 63 2019 DEERE 5OG MINI EXCAVATOR lFFO60GXLK'291179 Orned s 106.892.52 93,530.95 TOTAT COUNT OF 63 VEHICTES SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 62 Attachment 1 Page 1 of 1 suz-w-20-02 IPUC DR 62 Attachment 1 1of 1 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 62 Atlachment 2 Page 1 of 1 h.dd6ntrs-It -hdCl l5t W t{d{tld PuraillaP.ha Nar Bmt Valua 0 of1lr?5'fr lo10 FoRD F1S SUPERAE 4WO ,^ir hr6 rffin <r9Frali lwD ,'- .rninl - p6t.nd,l r.bL..m.^t und.r r.dd 16. t21 )otlFopo EISREG ilg .r.. .y.l.d - DdilLl r6l...h.ht u^d.r add 6i 2021 m1aF6CD a(lpFtDsUVilD .!-.rulr.d - p6hntLl n6l.am.nt und.. r.dak 2021 .,o,.lnd - pdhilbl mdft.m.nt u^d.r ntu 61 2021 I .ro .r.lnd x^w ,Oa - D6b^d.l r.6Ldh.nr o.d.r r.vlr 16r I2i 20t5FOPO F6GO l..e .r6lr.d N6v d0 - eobtrd.l nd*.mnt und.r rcdd lor 2021 s Pl6FORO FlSREGru tfrMF1ffiXE8S9 ,OII '6ID FIGD SUDERd DRW MI7 hAD F'GD SUPFi 'IB'WD )orrFdnh EtsnFG a aawD tr2 3_17 uolE FORO F1$ $PERm 4WD 145 P19D€ERE ffi MI{I EXqVTIOI d.^rG6vAN r wR whDn 9 16192.52 t rc,@.5S 915s.sI 20 2&S lFEXIENTEU'I lN(duqx1&12930 SUEZ WATER IDAHO INC. cAsE suz-w-20-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness:J. Cary REQUEST NO. 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. RESPONSE NO. 63: Attachment 1 is a draft of the forthcoming Suez North America Fleet Policy and Attachment 2 is the prior policy. Suez ldaho has not performed any specific studies in the last five years relating to vehicle replacement. Suez Idaho operates fleet management under the principals of maximizing lease terms while maintaining a manageable and stable lease expense. Section 8.1.4 below describes the vehicle replacement guidelines: 8.1.4 Company vehicles will be replaced because of business initiatives or when economically justified based on analysis by the fleet operations. Vehicles deemed to meet the criteria for replacement must be surrendered. Certain Iimited-use, low annual mileage vehicles may be excluded from the replacement cycle (i.e. plant vehicles). Any other exceptions to the replacement cycle require business justification and approvalfrom the company. suz-w-20-02 IPUC DR 63 Page 1 of 1 2 SUEZ Water ldaho lnc. Case SUZ-W-20-02 1. Policy Purpose 1.1 Purpose 2.'.t.2 2.1.3 1.1.1 This policy is for SUEZ Water in North America based employees and contractors operating a fleet vehicle. This policy covers all SUEZ Water North American based businesses. This policy does not apply to rentals procured during travel or perconal vehicles. Policy Scope: 2.1 Scope 2.1.1 SUEZ may require employees to utilize leased and/or owned vehicles to facilitate company business. Company vehicle use implies acceptance by the employee and his/her business of this policy which: a) ldentifies requirements for eligibility and participation in the program b) Establishes procedure for acquisition, assignment and replacement of vehicles c) Establishes vehicle classifications - custodialvs pooled/facility or other classes as determined by the business based on job titles d) Establishes procedures for the operation of the vehicles e) Defines employee financial responsibility, vehicle assessment, and IRS reporting (where applicable to accommodate personal use tax and/or annual mileage reporting) 0 lndicates insurance provided for company vehicles g) Defines use of personalvehicles and rentals for company business h) Addresses violations of the policy Employees who violate company vehicle policy are subject to disciplinary actions which may include verbal and written warnings, suspension of vehicle privileges, termination and legal action. lmportant note:\Mere applicable, vehicles may have tracking devices (telematics) installed for electronic logging devices (ELD) purposes or to ensure employees' safety and promote cost efficiencies for the fleet. lf installed, telematics devices may not be removed at any point in time without prior written authorization from the company. 3. Eligibility 3.1 Driver/Vehicle/Role eligibility 3.1.1 Eligibility for use of any vehicle is determined by the company and may change at any time. a) Drivers in a fleet eligible, custodial role must maintain 10,000 business miles/16,000 business kilometers per year to be eligible for a fleet vehicle. Request No. 63 Attachment 1 Page 1 of 19 (e*Blsuez SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Page: Dec 8 ,20201of19 SUEZ North America lnternal Uncontrolled When Printed "t fh'g-ydfiff Electronically Attachment 1 Page 1 of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 1 Page 2 of 19 @suez SUEZ North America Fleet Policy REf NO: lssue No: lssue Date: Page: July 8 ,2020 2ot19 b) Drivers in a fleet eligible role who do not maintain 10,000 business miles/16,000 business kilometers per year may be transitioned to re-imbursement model and need to turn in their fleet vehicle within 30 days of notification. c) Drivers who are in a fleet eligible role and are expected to or have historically driven over 10,000 business miles/16,000 business kilometers will not be eligible for reimbursement and will be transitioned into an appropriate fleet vehicle for their role. d) Commuting miles are considered personal mileage by the IRS/CRA and do not count toward the required 10,000 business miles/16,000 business kilometers per year. e) Specific roles require that a fleet vehicle be operated in order to perform the role's function and are not subject to the mileage requirement, such as pooled and plant vehicles which are exempt from the eligibility criteria. 0 Erpats will be subject to this Fleet Policy except for situations specifically covered in the Expat Policy. Please refer to that policy for more details. 3.1.2 SUEZ employees in a fleet eligible role who have completed and passed the required motor vehicle record check (i/MR) are authorized to operate a company vehicle. 3.1.3 Employees determined "eligible" to participate in the fleet program will be required to complete the following: a) Must be 21 years of age or older b) Proof of a valid driver's license (including foreign/expat) c) Consent to a motor vehicle record check upon offer letter into a driver eligible position. d) lssues that arise because of the lvlVR review will be discussed with the employee and respective HRM prior to issuance cf a fleet vehicle e) Employees aro not pennitted to drive on behalf of SUEZ until deemed eligible. 0 Spouse/domestic partners, with a valid license who are qualified under the same driver eligibility IVIVR prooess as outlined in this policy may operate the fleet vehicle as a secondary driver as needed. 3.2 ln cases where an employee's driving privileges have been suspended, their fleet vehicle must be returned within a maximum of 30 days through one of the following return procesaes: 3.2.1 Vehicle return processes: a) Facility return: !f vehicle is to be returned to facility employee should make arrangements through their manager for a facility contact take possession of and complete the vehicle return b) Move company retum schedule the vehicle pick up by the move company as soon as possible and within the 30-day turn-in timeline c) Employee turn in: If the vehicle is being handed over to another SUEZ employee please work with your manager to make arrangement for the vehicle hand-off SUEZ North America lnternal Uncontrolled When Printed ", ffffydflff Ebctronically Attachment 1 Page 2 of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 1 Page 3 of 19 @suez SUEZ North America Fleet PolicY Ref No: lssue No: lssue Date: Page: Dec 8, 2020 3of19 3.2.2 Vehicle return checklist: a) 2 sets of vehicle keys with fob b) Floor mats c) Owne/s manual in the glove box d) Fleet management company seMce card in the glove box e) Remove all personal items 0 Safety kit should be left in the trunUvehicle g) Snow tires should be left in trunk /vehicle if applicable (snowbelt vehicles only) h) All upfitting should remain with the vehicle Faiture to comply with the vehicle tum in process may result in the employee being liable for the co,sts of the vehicte'inctuding but not timited to monthly tease payment & fuel charges for the time/period of ineligibility. 4. Motor vehicle records/abstracts (tlVR) check 4.1 MVR Record Check 4.1.1 Upon hire or transfer to a role which requires a company vehicle or operating a vehicle on behalf of the company SUEZ wil! collect driver lWRs/abstracts. SUEZ will also run annual re-checks of abstracUMVR's. SUEZ's selected vendor partner will administer the collection and scoring of motor vehicle records (driver history abskacts) with respect to employees covered by this policy. A motor vehicle record check is required to determine an lmpbyee's ongoing eligibility to be a driver. The protection of personal information c6neaeO in connection with providlng -II4V.E services is important to SUEZ. Your results will be kept private and confidential. tvlVR results will only be shared on a need to know basis within the organization. SUEZ's setected vendor for JTIVR's will contact you upon hire/transfer, and from then on annually, with instructions on the process for Suez to obtain an [IVR/abstract. Please pay close attention for this communication and respond within the given time frame: a) Drivers with a high-risk profile (Tier 2 as outlined in example 1) will have their MVR abstract reviewed quarterlY. b) Post-accident [\lMR's will be required for allfleet drivers in a company vehicle. Post-accident MVR's will be required for all fleet drivers in a personal vehicle white on company business, time or during the employee's regular hours of work. c) Failure to comply with a required MVR/abstract review may result in loss of driving privileges. d) ln the event an employee relocates to a different state or province and is required to obtain a new driver's license, they are required to report and provide a copy of the new license to HR & and SUEZ',s chosen MVR provider within 30 days. 4.',1.2 4.2 Disciplinary action: 4.2.1 Violation(s) of motor vehicle laws and/or this policy may result in suspension, SUEZ North lnternal or Electronically Attachment 1 Page 3 of '19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 6. Vehicle/driverclassifications 6.1 Classifications Request No. 63 Aftachment 1 Page 4 of 19 including termination of employment. Some examples of violations include, but are not (6sud'git"d to the followins:'- v a) Driving a company-provided vehicle on company business or personal use or driving any vehicle on company business while impaired by alcohol, illegaldrugs, or prescription medication that impairs safe driving. b) Conviction of a felony as a result of acts or omissions while driving a company- provided vehicle or any other non-company owned vehicle while on company business. c) Causing a motor vehicle accident that results in property damage or personal injury while operating a company-provided vehicle or operating any vehicle on company business. 4.2.2 Failure to report accidents and/or moving violations as required may result in disciplinary action up to and including termination of employment. Any authorized driver who is charged as a result of an accident or moving violation of the motor vehicle laws may be prohibited from driving a company-provided vehicle pending resolution of the charges. Defer to requirements outlined in the company drug and alcoholpolicy 4.2.3 lf an employee's job requires operating a rohicle (company-provided or private) and the employee loses his/her license or is suspended from driving due to the employee's driving record or pending charges, the employee may be subject to suspension or termination of employment. Employees must immediately report to their manager any suspension, revocation or any status to their driver's license that impac{s their ability to drive during work. Safe Driver Policy ilVR Tier Time Period Tier2 High Risk 36 Months 0 to 4 points 5 to 9 points 10 or more points 5. Driverineliglbillty 5.1 lneliglble drivers 5.'1.1 Drivers who fail to meet eligibili$ requirements may have driving privileges revoked, may be subject to suspension and/or termination, and may be unabte to return to work in a driving role untilthey are able to meet the minimum eligibility requirements set forth in this policy. !n the event an employee's driving eligibility relies on a future court date or other proceeding and other methods of transportation are not available, the employee may be subject to suspension until resolution. Upon resolution of any matterpreventing an employee from becoming an eligible driver, the employee must provide adequate documentation to their HR manager prior to being returned to work in a role that requires them to drive in any capacity. 5.1.2 ln the event an employee who is required to drive is unable to meet the minimum eligibility requirement, they will have their case reviewed by their senior human resources leader. (See vehicle return process abovel 6.1.1 Custodial vehicles are utilized by one assigned employee for company business and SUEZ North ca When Printed or Electronically Attachment 1 Page 4 of '19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 6.1.2 6.1.3 Request No. 63 Attachment 1 Page 5 of 19 issued to a SUEZ employee (the custodian). Please note drivers of a custodial fleet vehicle will be responsible for reporting personal use mileage upon request, no less than annually for IRS tax reporting purposes. Assigned custodialvehicles may be utilized: For business purposes by the custodian, other SUEZ fleet eligible employees. Limited and reasonable personal use by assigned driver. 6.2 Pooled vehicle management 6.2.1 pooled/facility vehicles are utilized by multiple drivers (SUEZ employF,es only) for business purposes only and are housed at a SUEZ or customer site. Pooled vehicles are not to be used for any personal business, such as commuting from home to an office location or job site or commuting to meal events. The pooled vehicle must be assigned to ttre SUEZ employee (the keyholder) who is the current site lead or region manager who will assume controllership of the locations site/pooled vehicles. Vehicles in thiJcategory include but are not limited to work trucks, forklifts, trailers, cranes, loaders, dump trucks, etc. 6.2.2 The keyholder to whom the vehicle is assigned is responsible to: a) Ensure that only authorized persons operate thevehicle: emplo.yees with the required certifi&tions, motoi vehicle rdcord check and driver's licenses and must be over21 Years ofage b) Transfer keys to the new keyholder employee before changing roles or leaving employment. c) Facilitate and manage requests for fuel pins foreach_ pool/occasional driver. Fuel' pins must be issued-to ea-ch potential driver and will be used with the vehicle's iuel card - pins should nevei be shared between drivers. lmportant note: fuel pins should be cancelled in the event a driver leaves the company to avoid fuelfraud. Contact the fleet operations to request new pins or notify of pin cancellations needed. d) lt is required that the keyholder keep a log of which driver utilizes the vehicle and when. Logs should be kept in the office, not the vehicle. Driver logs will be referenced in the event of a violation, legal issues, or damages' SUEZ North America lnternal Uncontrolled When Printed or Electronically Attachment 1 Page 5 of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment I Page 6 of 19 @suee SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Page: July 8 ,20206of19 7. Leave of Absence/Termination/ Retirement: 7.f Extended absence & discontinuation of employment 7.1.1 Use of company vehicles during leave of absence At the discretion of the company, employees on any approved leave of absence may retain their fleet vehicle for a period not to exceed 26 weeks. Employees are required to contact their HRM prior to the leave of absence to update their home address and phone number. !n all cases of extended leave or parental leave, the company reserves the right to exchange the vehicle of the employee on Ieave to support the appropriate allocation of vehicles within the fleet. 7.1.2 Termination/Retirement All employees who leave the company, go on layoff status, or re@ive a severance package must surrender the vehicle prior to the last day of active employment. Vehicles are not to be utilized as part of a severance package. Stewards for pooled and facility vehicles should take the necessary steps to assign those vehicles to appropriate individuals. 8. Vehicle assignment policy 8.1 Vehicle Assignment 8.1 . 1 Vehicle requests will be fulfilled based on the following criteria: a) Existing idle fleet vehicle will be assigned whenever available b) lf no available idle vehicle alrailable, the driver will remain on reimbursement and a vehicle will be otdered c) Exception: !f there is no available idle and the employee has no personal vehicle a fleet vehicle may be procured out of dealer stock and an interim rental vehicle provided by the fleet managenrent company 8.1.2 Medical exceptions: a) lndividuals requiring non-standard or modified vehicles/equipment due to physical and/or medical conditions must submit a doctor note outlining the requirement in detail to their HRM for approva!. Each new vehicle procured for an employee with a medicalexception will rcquire a new doctor note and HRM approval. 8.1.3 New vehicle - selection, ordering, replacement, upfitting, branding, GPS/telematics The vehicle acquisition/replacement cycle usually occurs twice a year (spring & fal!). Under special circumstances, such as accident or mechanicalfailure an inoperative vehicle does not warrant repair, these vehicles may be replaced at times other than the specified cycles. 8.1.4 Company vehicles will be replaced because of business initiatives or when economically justified based on analysis by the fleet operations. Vehicles deemed to meet the criteria for replacement must be surrendered. Certain limited-use, low annual mileage vehicles may be excluded from the replacement cycle (i.e. plant vehicles). SUEZ North America lnternal Uncontrolled When Printed "r ffffiYffffff Electronically Attachment 1 Page 6 of 19 SUEZ Water ldaho lnc. Case SUZ-W-2&02 8.6.1 8.6.2 8.6.3 8.6.4 8.6.5 8.6.6 Any other exceptions to the replacement cycle require business justification and approval from the company 8.2 Upfitting 8.2.1 Vehicle selections offered will have pre-approved optional equipment, color choices, and upfit packages. Vehicle and Upfit packages will be offered based on job role and need. lssues with the current vehicle upfitting should be brought to your manager so they can be reviewed and approved or denied by fleet operations 8.3 Branding 8.3.1 SUEZ requires that all branding/decals/logos be requested, reviewed and approved through the SUEZ marketing team. SUEZ approued vendors only wil! be allowed to ensure a consistent brand. 8.4 GPSftelematics: 8.4.1 Some SUEZ vehicles will include a GPS/ELD device. These devices are criticalto ensuring driver safety and improving overallfleet efficiency. ln the event these devices require service please contact the fleet management company (FMC). 8.5 Left blank intentionally 8.6 lmportant notes: All options added to the vehicle become part of the vehicle and, as such, SUEZ property Under no circumstances are options, other add-ons (i.e. installed satellite radio, decals, window tint, detailing, or customizing, etc.), or upfifting to be added to the vehicle after delivery. Safety equipment is not to be removed, altered, or disabled. Costs associated with the driver paid options are non-refundable and will not be reduced from the employee purchase quote. Under no circumstances should a vehicle's suspension or tire size / load range / ply rating be modified or altered after delivery. The only tire size allowable on the vehicle is the one on the door stbker from the manufacturer Some vehicles include GPS tracking/ElD reporting tools. Under no circumstances should these devices be removed or tampered with. Request No. 63 Attachment 1 Page 7 of 19 @suez SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Paqe: July 8 ,20207ot19 SUEZ North America lnternal U n co nt rol led W he n P ri nted ", tlff yfffff E bct ro n i ca I ly Attachment 1 Page 7 of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 1 Page 8 of 19 @suee SUEZ North America Fleet Policy Ref No: lssue No: lssue Dale: Page: July 8 ,2020 8of19 9. Driver responsibilities for vehicle use 9.1 Responsibilities 9.1.1 All employee drivers must have a valid drive/s license or commercial motor vehicle learne/s permit appropriate to the type of vehicle being operated in accordance with state or federal law for the state in which they reside. lt is the responsibility of the driver to notify his immediate supervisor of any changes to the license in a timely manner. 9.1.2 Drivers and all occupants must wear seat belts, and/or any applicable restraints as required by law while the vehicle is in operation. 9.1.3 Being under the influence of alcohol and/or drugs while driving a company-provided vehicle at any time, or while driving a private vehicle on company business is strictly prohibited and will result in revocation of drMng privileges, bss of company vehicle and/or termination of employment. Any incident defined under this section must be reported to the employee's manager and division human resour@s within 24 hours. 9.1.4 Employees using a legal drug that may Gause conditions of impairment are required to report such drug use to their immediate supervisor prior to commencing work. Drivers should avoid driving any vehicle while taking prescription and/or over-thacounter medication that could impair the individual or affec,t safe operation of such vehicle. 9.1.5 The use of radar detectors is not allowed in any vehicle used for company business. 9.1.6 Transporting weapons, firearms, or the transport of hazardous materials is strictly prohibited unless the vehicle is commercially rated and transport of said materials is the intended use. 9.1.7 Vehicle doors shall be Iocked when the vehicle is in operation. 9.1.8 ln the event of a vehicle breakdown drivers should try to maneuver the vehicle off the road and remain in the vehicle, if on a public road, until help arrives. lf you are unable to obtain roadside assistance use whatever means you have at your disposal as to ensure your own safety and the safety of your passengers 9.1.9 Under no circumstances should a driver attempt to change their own tire. lf you are unable to obtain roadside assistance use whatever means you have at your disposal as to ensure your own safety and the safety of your passengers 9.1.10 The use of company-provided vehicles to pulltrailers, boats, or any other objects is not permifted when driving the vehicle for personal use. 9.1 . 1 1 Drivers of company4rovided vehicles must report accidents or citations for any moving violation (including those that have occurred in a personalvehicle) immediately to the employee's manager and HR manager within twenty-four (24) hours. 9.1.12 An employee issued a citation or convicted of violating motor vehicle laws while driving company-provided vehicles or private vehicles on company business will be responsible for his/her court costs and fines and is responsible for making the appropriate notifications as set forth above. Violations are not eligible for reimbursement. SUEZ North America lnternal Uncontrolled When Printed "r flfiYffi-ff Electronically Attachment I Page 8 of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 'l Page 9 of 19 @suee SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Page: July 8 ,20209of19 9.1 . 1 3 The use of laptops, tablets, or similar electronic devices while driving non-commercial vehicles is prohibited. Texting, emailing, web surfing or other'hands on" use is strictly prohibited while driving. This does not apply to hands-free GPS applications as allowed by locallaw. 9.1.'14 Do not handle your phone or any other electronic device when driving. Drivers are required to comply with applicable federal, state, and/or local laws regarding the use of any communication or electronic device while driving. 9.1 .1 5 Any private vehicle used for company business must be properly registered and insured and meet applicable state inspection requirements. Drivers are responsible for monitoring and ensure their vehicle is legal to operate at all times. 9.1.16 Drivers must adhere to all laws pertaining to motorvehicle operation. 9.1.17 Drivers are to review, understand and abide by the EHS safety policy provided by their business unit. 9.1 .1 I Questions related to the EHS vehicle safety policy should be refered to your business's EHS manager. 9. 1 . 19 Company vehicles may not be used to transport personal items strapped to the roof or hood or hooked to the hitch for any reason (bikes, ski's, canoes, boats, etc.) 9.1.20 Drivers will utilize and maintain vehicles in a manner that retains the validity of the manufacturer's warranty and ensure all options, upfitting & safety equipment provided are not tampered with, disabled, or removed. 9.1 .21 Drivers will obtain all necessary inspections, etc. in a timely manner for registration and maintain related documents. lt is the ernployee's responsibility to ensure documents are updated 3060 days prior to expiration if they have not yet received notification of renewal. Documents are to be transfened with the vehicle at time of vehicle surrender. 9.1.22 Drivers will ensure proper and timely preventative vehicle maintenance in accordance with the manufacturer recommendations. These Preventative Maintenance items include but are not limited to: a) Tire Pressure b) OilChanges c) Tire Rotations d) Fluid Levels 9.1.23 Drivers will utilize SUEZ's contracted maintenance program for all repairs and maintenance. 9.1.24 The use of any tobacco products including e-cigarettes, is prohibited in company vehicles. 9.1.25 Company vehicles may not be used to transport strangers/hitchhikers 9.1.26 Company vehicles may not be used for any non-intended 3t party business use such as uber, lfit, piza delivery etc. 9.1.27 Company vehicles may not be overcrowded or overloaded past the manufacturer limitations. SUEZ North America lnternal Uncontrolled when Printed "r fmydfl:ff Electronically Attachment 1 Page I of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 1 Page 10 of 19 @suee SUEZ North America Fleet Policy R,el No: lssue No: lssue Date: Paoe: July 8 ,2020 10 of 19 9.1.28 SUEZ will require a fleet policy acknowledgement upon hire or transfer to a fleet eligible position. An annual policy re-acknowledgement will be required as well. 9.1.29 Drivers eligible for personal use agree to the supply the company with personal use reports, specifically mileage, upon request and no less than annually. 9.1.30 Drivers will maintain a log of personal vs business trips separate from what is reported through the FMC as required by the !RS. 9.1.31 Assigned drivers are responsible to ensure vehicles are only operated by a fleet eligible driver. Drivers will be financially responsible for any damage/cost to SUEZ in the event of a non-authorized driver. 9.1.32 Pets are not allowed to be transported in a company owned vehicle. 9.1.33 Vehicles are not permitted to be modified in any way (including the installation of any type of hardware) without prior approvalfrorn the company's fleet operations team and the lessor if applicable. 10. Gross-Border use of Vehacles 10.1 Employees who live in the United States and utilize their personal vehicle for frequent business travelto Canada and Mexico should consult with their HRM and/or EHS representative to ensure travel is compliant with SUEZ and localjurisdiction requirements. 10.2 C3tr3fi - Crossing the border into Canada orfrom Canada to the US with a company vehicle for businesE purposes requires advance approvalfrom the authorized business approver. ln all cases, when vehicles are driven into Canada, drivers must have a cross border letter and insurance card obtained by calling the fleet management company prior to travel. Under no circumstances is a company vehicle to be driven into Canada from the US or into the US from Canada for personal use. r0.3 Merlco - Crossing the border into Mexico with a company vehicle for business or personal use is prohibited. Rentalshould be procured, with appropriate insurance coverage, for business use as needed through T&L. I l. Driver Financlal Responsibilities: 11.1 Traffic violations 1 1.1 .1 Employees are financially responsible for expenses incurred because of haffic violations, related court expenses, vendor/supplier seMce charges, and repairs resulting from impairment due to alcoho!, drugs or other illegal behavior while operating the vehicle for business or personal use. SUEZ North America lnlernal Uncontrolled when Printed "ffiAttachment 1 Page 10 of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 'l Page 11 of 19 11.2 Perconal use costs 11.2.1 Custodial employees are financially responsible to pay for tolls and other costs associated with non-incidental personal usage (including but not limited to extended weekend trips & vacations). 11.3 Vehicle misuse and damage 11.3.1 Employees are financially responsible to pay for damages resulting from policy violations and/or vehicle misuse, including but not limited to use of tobacco products, driving under the influence of drugs or alcohol, un-authorized drivers, and unauthorized vehicle alterations. f 2. Safety Training 12.1.1 Refer to your required EHS safety training 13. Driver Compliance- class A, hazmat, DOT 1 3.1 . 1 Refer to the commercial driver compliance requirements and policy UncontroiledwhenPrinted.rryptyt'ffff Electronically Attachment 1 Page 11 of19 {@suez SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Page: July 8 ,2020 1'1 of 19 SUEZ North America lnternal SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment'l Page 12 of 19 15. lnsurance 15.1 Coverage & Reporting 15.1.1 Coverage for bodily injury and propefi damage is provided and is in force only when an authorized individual drives the vehicle. 15.1.2 Vehicles are self-insured for comprehensive and collision coverage. Losses that arise are charged to the cost center for the specific vehicle. Insurance does not extend to employees' personal propefi within the vehicle. a) Al! accidents, vandalism, and stolen vehicles must be reported to the Fleet Accident Services (800-231-1044), within 24 hours of the occurrence. Attachment 1 SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Page: July 8 ,2020 12 ot'19 SUEZ North America lnternal Uncontrolled When Printed or Page 12 of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 1 Page 13 of 19 iu.f}}lsuee SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Page: July 8 ,2020 13 of 19 b) c) Accidents involving bodily iniury must also be reported immediately to the business EHS manager. Please refer to the fleet management company's accident driver's packet for more information and requirements. lf you need proof of insurance, please contact the fleet management company or use the mobile app to request a replacement insurance card. 16. Fuel 16.1 FuelCards 16.1.1 16.1.2 16.1.3 16.1.4 16.1.5 16.1.6 16.1.7 Each fleet vehicle is enrolled in the fleet management companies fuel program. The fleet management company will issue a service card & fuel pin. The service card should arrive in a plain envelope The service card will be active upon receipt Service card is swiped for pay at the pump fueling transactions Drivers are required to enter a current odometer reading and their assigned fuel pin # for each fueling transaction Driverwill receive a fuelpin via e-mailwith their program "welcome" kit. Note: Please reference your fleet management company welcome letter kit or the mobile APP for more information on the fuel program 16.2 Allowable types of fuel 16.2.1 Use regular 87-otane unless your vehicle is a flex-fuelthat allows for blended fuels 16.2.2 lf your vehicle is a diesel you will fuelwith biodiesel 16.2.3 Ensure you understand the type of fuel required for the vehicle you are operating - if you are unsure please reach out to the FMC to confirm prior to fueling 16.3 Fuel card restrictions 16.3.1 Do not use premium fuel 16.3.2 Two (2) Pay-at-the-pump car washes per calendar month are allowed. Vehicles too large for gas station car washes should go through the FMC's maintenance program locate a truck wash that can be utilized as needed but no more than 1X per month 16.3.3 No other non-fuel items should be purchased through the fuel program. Fluids, wiper blades and other incidental items should be purchased at the time of preventative maintenance or repairs through the maintenance process. SUEZ North America lnternal Page 13of1I Uncontrolled When Printed "t tflftiffil"ffi Electronically Attachment 1 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Requesl No. 63 Attachment 1 Page 14 of 19 {irc$l suez SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Page: July 8 ,2020 14 of 19 16.4 Fue! fraud is real and very costly to the organization. Please follow these tips to help manage potential fuel fraud: 16.4.1 Do not share or write down your fuel pin 16.4.2 Watch for and report any pay-at-the-pump mechanism that appears to be tampered with 16.4.3 ln the event you pay inside the station enter your own fuel pin - do not provide to the attendant 16.4.4 ln the event of full-service stations - get out and enter your fuel pin - do not provide to the attendant 16.4.5 lf your card is lost or stolen or compromised in any way, please contact the FMC immediately to request a replacement service card via express mail. 17. Maintenance / roadside assistance / warranty 17.1 Each fleet vehicle, trailer, and equipment are enrolled in the maintenance program. The same seruice card that is used to pay for fuel should be presented to the shop upon arrival to ensure the appropriate program parameters are followed. The FMC will pay the shop via PO for all approved work. You only needpresent your card at the time of arrival - you will have no out of pocket expense. The maintenance program will coordinate the following on the driver's behalf: 17.1 .1 Roadside assistance 17.1.2 Lock-out services 17.1.3 Glass replacemenUrepair 17.1.4 Repair negotiation 17.1.5 Warranty assistance 17.1.6 Recall repairs 17.1.7 Vendor payment 17.1.8 Like rentalwhen needed 17.2 Preventativemaintenance 17.2-1 Today's vehicles have an oil life monitoring system. Please follow your vehicle's monitoring system for oil changes. At the time of your oil change the maintenance vendor will rotate tires, top off fluids, replace windshield wipers and work with fleet management company to obtain approvalfor any additional maintenance that is needed. SUEZ North America lnternal Uncontrolled when Printed "r ?Htii[h1{i{ Etecrronicafly Attachment 1 Page 14 of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 18. Accidents 18.2 18.3 18.1 Accident administration 1 8.1 . 1 The fleet management company will manage all accidents. The fleet management company willwork directly with the SUEZ lnsurance company as well as the 3'pafi insurance company as needed. 18.2.1 Drug Testing Requirements Any employee involved either directly or indirectly in a workplace accident or incident, and in which reasonably alcohol or drugs may have been a contributing factor, may be required to submit to a drug and/or alcohol test, unless prohibited by applicable law. SUEZ company premises, company property, offsite work, or customer site: Refers to all land, buildings, structures, property, facilities, trains, airCraft, vehicles, or ships that are used to conduct the business or services of SUEZ. If required, following an accident that occurs while operating a fleet vehicle, the employee is required to call and schedule the required drug testing within 24 hours. The FMC will provide drug testing contact information for your business. Accident reporting process 18.3.1 Basic accident process is outlined below: 18.3.2 Stay calm - lf injuries - contact emergency services immediately as needed 18.3.3 lf a 3d party is involved contact the police and request a police report is filed - ensure you obtain a copy as it will be needed 18.3.4 Obtain the 3d party name and insurance information 18.3.5 Do not express fault or apologize as this could be observed as admitting fault 18.3.6 Report the accident as soon as possible to fleet management company '18.3.7 Report the accident to your immediate manager and HR/EHS manager within 24 hours or as soon as yoir are able. Please ensure you are following allintemalaccident reporting protocol, including drug testing (if required by law), required by your. business unit. lf you are unsure of the internal accident requirements, please ask your HR or EHS manager 18.3.8 SUEZ's FMC will arrange and manage the following as part of the repair process: a) Tow your fleet vehicle if not operable b) Schedule a rental if your fleet vehicle is not operable c) Schedule a rentalwhile your vehicle repairs are completed d) Assign a contracted repair vendor for your repair e) Work with the contracted repair vendor to assess damages and obtain a repair estimate 0 Negotiate all repairs directly with the repair vendor 18.3.9 You will have no out of pocket expenses. FMC willcoordinate allpayments. ln the event you are asked for payment please redirect the requester to the FMC Request No.63 Attachment 1 Page15of19 @suee SUEZ North America Fleet PolicY Ref No: lssue No: lssue Date: Paqe: July I ,2020 15 of 19 SUEZ North America lnternal Uncontrolled when Printed "r. tl'fiy$ffff Ebctronically Attachment 1 Page 15 of 19 SUEZ Water ldaho Inc. Case SUZ-W-20-02 Request No. 63 Attachment 1 Page 16 of 19 , .'ir, SUge SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Paqe: July 8 ,2020 16 of '19 18.3.10 In the event of vehicle theft or vandalism follow the accident reporting process -ensure a police report is completed and you receive a copy to pass on to FMC. 18.3.11 lf any SUEZ laptop or cell phone are stolen please follow the EHS reporting procedure 18.3.12 Post-accident motor vehicle record (MVR) checks will be completed for allfleet vehicle accidents where the fleet vehicle is in operation. (moving or stopped but running) 19. Title & license - initial title, renewals, state transfers, violations 19.1 Fleet legalization 19.1.1 Each fleet vehicle needs to be legal to operate in your location. As the assigned driver or pool vehicle manager you are responsible for ensuring your vehicle meets all the requirement for legal operation based on the local laws - Please ensure you are reviewing and managing the following proactively: 19.2 lnitial title: 19.2.1 ln the event you receive a new vehicle or replacement vehicle from a dealership conform you have the following prior to leaving the dealership or confirm when you will receive these required items: a) Hard license plates should be affixed to the front and/or back of your vehicle depending on state law. lf you do not have hard plates confirm with the dealership representative that you have a valid temporary tag, how long the temp tag is active, and when and how you will receive your hard plates b) Current registration should also be provided along with the vehicle's hard plate. lf you do not receive a copy of the registration with the plates, please ensure the dealership is providing and when you willreceive c) lf an escalation is needed for expiring temp tag or missing license plate or registration, please escalate with the FMC. 19.3 Renewals/re-reg: 19.3.1 Your fleet vehicle is enrolled in registration renewal program as soon as a valid license plate, plate state, and expiration date is provided to the FMC for the vehicle. Please ensure the FMC has the correct plate and expiration information for your vehicle. 19.3.2 The registration renewal process will being 120 days prior to expiration. You will receive a communication from the FMC advising if any documentation is needed from you. a) lf no documents are needed the FMC will proceed with the renewal and you will receive updated tabs and registration within 2 weeks of plate expiration b) lf documents (i.e. safety inspection, smog, emissions certificates, etc.) are required the FMC will request these documents from you via e-mail. Please ensure the required documents are supplied to the FMC within 60 days of expiration to ensure your vehicle can be renewed on time. SUEZ North America lnternal UncontrotledwhenPrintedorfl pf, f,'$ff er".tr*trrrrv Attachment 1 Page 16 of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 1 Page 17 of 19 @suez SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Page: July 8 ,2020 17 ol 19 c) lf you do not provide required documents the FMC will not be able to renew your tabs/reg and they will send you a power of attorney - it will then be your responsibility to complete the re-reg and expense the cost. 20. State transfers 20. 1 .1 !f you move to a new state/province, please report your new address to SUEZ and the FMC. The FMG will need to complete a vehicle title transfer on yourfleet vehiclewithin 30 days. 20.1.2 You are also required to obtain an updated driver's license (DL) in your new state/province within 30 days of arrival. Please ensure the motor vehicle record (lutvR) provider receives your updated driver's license (DL) information. 20.1.3 !f documents (i.e. safety inspection, smog, emissions @rt, etc.) are required the FMC will request these documents from you via e-mail. Please ensure the required documents are supplied to the FMC within 30 days of request 20.1.4 lf you do not provide required documents, the FMC will not be able to transfer your vehicle title to the new state/province. Your vehicle will also not be able to be renewed in the old state/province, so your plate willeventually elpire, and you will be responsible for any violation charges for expired tags 21. Violations 21.1 Violations 21.1.1 ll you are issued a violation while assigned to your fleet vehicle it is your responsibility to pay that violation ouhof-pocket. Molations are not an eligible expense item. 21.1.2 lf you are a "custodial" driver (you are the only person assigned to and driving the fleet vehicle) you will be enrolled in the driver accountability program. Our FMC along with their violation's management company will partner directly with you and the transit authorities to transfer the liability of violations associated with your company provided fleet vehicle. You will receive a registration e-mail upon vehicle assignment. Please complete your registration within 2 weeks of receipt. 21.1.3 The violation program @vers violations not issued to you directly by a police officer. Examples: parking, photo enforced, and toll. You will have an opportunity to dispute or pay each violation transfened to you. Payment can be made via on-line link or US Mail. 21.1.4 !f you are a pool manager and a violation is issued to one of your assigned fleet vehicles the FMC will pay and bill the violation back to your cost center. SUEZ North America lnternal Uncontrolled When Printed ", flffiYdflff Electronically Attachment 1 Page 17 of 1s SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 1 Page 18 of '19 @suee SUEZ North America Fleet Policy Ref No: lssue No: lssue Date: Page: July 8 ,2020 18 of 19 22. Rentals 22.1 22.2 22.2.1 Rental vehicles will be provided in the folloving circumstances through the FMC. There will be no out of pocket expense for you. 22.1.1 FMC rentals will be issued when: a) Extensive maintenance/repairs are needed on your fleet vehicle b) During accident repairs on your fleet vehicle c) In the event your fleet vehicle is in-operable d) New hire rentals must be requested by your manager and will only be issued when new hire has no personal vehicle to utilize while awaiting a fleet vehicle e) lmportant note: Like rentalvehicles (i.e. sedan for sedan, etc.) wilt be issued - no rental upgrades are allowed. Fueling a rental Please use your fleet fuel card, if available, to fuel your rental. Please use odometer reading 99,999 when fueling a rental. lf your fleet fuel card is no longer active you will need to elpense fuel until a new vehicle is assigned and a new service card arrives. Your fuel pin will not change. 23. Tolls/out of pocket expenses 29.1 Tolls 23.1.1 lf you reside or operate in an area with toll roads you are responsible for setting up a toll account unless your fleet vehicle/s is enrolled in a toll program through the FMC. Business only toll charges are eligible for reimbursement and will need to be expensed. lf you are enrclled in a tdl program through the FMC, your tolls wil! be paid by the FMC and would not require a reimbursement process. 23.1.2 Reminder: Violations are pleligible for reimbursement 23.2 Miscellaneous out of pocket expenses: 23.2.1 The following out of pocket expenses are eligible for reimbursement through T&L expense: Tolls as a result of business Smog, safety, or emissions inspections Depending on your state requirements you may be able to use your maintenance card to pay for any required annual inspection - it will depend on the locations the states allow. lf not able to utilize a maintenance vendor these state requirements willbe reimbursed Local parking permits required based on your location and loca! law All other local inspections and requirements needed to keep your fleet vehicle compliant a) b) c) d) e) SUEZ North America lnternal Uncontrolled When Printed "r Yffimi{ Electronically Attachment 1 Page 18 of 19 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 1 Page 19 of 19 Wsuez 2.0 June 1,2 19of1 Change log ijuZ-W-z['J.Oz IPUC DR 63 Attachment 1 Page 19 of 19 Ref No: lssue No: lssue Date: Page: SUEZ North America Fleet Policy Period of time the record should be kept Enmples:. lndefinitdy. Minimwn 3 Years Describe Record (add nor rows as needed) where is record formally l(ept, what systern, provide enough info to provicle direc*ion on hor to rctrieve it Who as in wlnt function is responsible fur ensudng the record is stored in the designated location. How LonRecordWhereWho UNITED WATER VEHICLE POLICY Request No. 63 Attachment 2 Page 1 of13 Policv Obiective & Intended Puroose It is the policy of United Water and each of its subsidiaries to provide an appropriate vehicle allowance to employees where the Company determines those employees are eligible for this perquisite. For those employees who currently are provided a leased vehicle, they will transition to an appropriate vehicle allowance when the lease on their vehicle expires, unless the extensive business use of a vehicle justifles giving an employee the choice of an allowance or leased vehicle according to the Policy Terms in section 3. The purpose of this policy is threefold: (i) to identifo those individuals who qualify to receive an allowance (or leased vehicle); (ii) to set repofting requirements necessary to assure that Company policy is followed and that applicable tax rules and reporting requirements are satisfied; and (iii) to set reasonable parameters and guidelines. The Company may at any time change this vehicle policy, and may discontinue paying a vehicle allowance to an employee at any time it determines it is appropriate to do so. Scooe of Policv This policy applies to United Water and its subsidiaries and affiliates (the Company). This policy does not apply to the employee operation of pool vehicles, such as repair/maintenance vehicles, utility trucks and fleet vehicles, for business or operational purposes. Policv Terms Employee Eligibility Employees with salary grade levels of 22 or above, qualify to receive a monthly vehicle allowance. This allowance shall be paid through the Payroll Department via Human Resources authorization. Leased Vehicle Justification There may be situations where the extensive business use of a vehicle justifies giving an employee the choice of an allowance or leased vehicle. For an employee to qualify, they must drive 8,000 or more business miles annually. In such a situation, the EMT member ultimately responsible for the employee, in coordination with the Senior Vice President of Human Resources, will make the determination of whether the employee needs to use a personal vehicle to properly carry out their responsibilities, and therefore qualifies to receive a choice of a vehicle allowance or leased vehicle under this policy. If a leased vehicle is chosen, that vehicle will be a standard Company car assigned by the Company. All employees, regardless of past practice, must conform to the reporting requirements as set forth herein, and will be subject to tax treatment as required. A. Employees with salary grade levels of 2L or below and who, as of l2/3t/2009, had received a leased vehicle or vehicle allowance will be grandfathered to remain eligible for this perquisite. All new employees with salary grade levels of 2t or below will not be eligible for a vehicle or allowance, unless their position qualifies under the conditions set forth in section 3.2. 3.3 Amounts of Vehicle Allowances, Fuel Reimbursement and Other Expenses Vehicle Policy - Revised L2l3Ll2OOgPage 1 of 13 suz-w-20-02 IPUC DR 63 Attachment 2 Page 1 of13 SUEZ Water ldaho lnc. Case SUZ-W-20-02 1 1.1 t.2 1.3 2. 2.1 2.2 3 3.1 3.2 x,""*. UNITED WATER VEHICLE POLICY SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 2 Page 2 of 13 3.4 3.5 The standard monthly vehicle allowances are set forth on Attachment #L, and may be modified from time to time. Under no circumstances may an employee receive a leased vehicle and a vehicle allowance simultaneously. Employees who receive an allowance or a company provided vehicle will only be reimbursed for the cost of fuel used for business mileage at the standard IRS fuel rate (also set forth in Attachment #1). Reimbursement for fuel for business miles should be requested on properly completed expense reports, and should be supported by a record of such business miles either on or attached to the expense report (use of the standard company auto mileage log form shown as Attachment #2 is encouraged). Employees with vehicle allowances are not permitted to submit any other expenses for reimbursement relative to personal vehicles, such as oil changes, tune-ups, car washes, tire/brake replacement or maintenance, etc., nor are employees permitted to use any master -billing (company-paid) accounts to obtain such items. Guidelines for Vehicles & Use Vehicle Insurance - The employee, who receives a vehicle allowance, is responsible for the cost of being properly insured for both personal and business use of the vehicle. Licenses and Comoliance with Laws - In using a personal vehicle for company business, the employee shall obey all traffic and other laws governing the use of such vehicle. The operator shall not operate a vehicle while impaired, including while under the influence of alcohol or drugs. The company also requires every person in a vehicle to wear a seat belt. Any fines, tickets, summonses or other citations resulting from the violation of traffic or other laws are the employee's responsibility. Avoiding Duolicate Expense - The Company incurs expense in providing an employee with an allowance. Consequently, employees who receive an allowance are strongly encouraged to use their vehicles for business trips, including travel to and from airports in their home location. However, when using a taxi or limo service is less expensive than fuel costs, tolls and airport parking for the duration of a trip, the employee is encouraged to use such a taxi or limo service. Reporting and Taxes Overview - The Company intends that this vehicle policy qualify as an "accountable plan" under IRS regulations. Accordingly: . Each employee who receives a company-provided vehicle under this policy must repoft his or her vehicle mileage and business use each month on a Vehicle Usage Log (See below and Attachment #2). o Employees who receive a vehicle allowance must document their business expense under the Company's accountable plan by (i) tracking their total vehicle mileage and business use mileage on a Vehicle Usage Log or similar record and (ii) repofting this information, plus their actual business costs if they so desire, shortly after the end of each vehicle fiscal year (the vehicle fiscal year ends October 31't) by filing an Annual Employee Vehicle Allowance Statement (Attachment #3, hereinafter referred to as the "Annual Statement") by November 15th each year. This form is available in electronic spreadsheet form. Vehicle Policy - Revised L2l3Ll2OOgPage 2 of 13 suz-w-20-02 IPUC DR 63 Attachment 2 Page2of13 *."{--"..Li,,1,,(l UNITED WATER VEHICLE POLICY SUEZ Water ldaho lnc. Case SUz-W-2Go2 Request No. 63 Attachment 2 Page3of13 Employees who receive a vehicle allowance may select from two documentation approaches. Under the simpler of the two, the employee maintains a record of their business miles, and their documented business expense would be equal to their business mileage multiplied by the standard IRS per mile rate (net of the amount per mile reimbursed by the company for fuel). Under the alternative (more complex) method, an employee electing to use this method would also keep track of and repoft their total mileage and the actual expenses of the personal vehicle they use; the business portion of the allowance received would be equal to the business percentage of their total mileage times the actual expenses. In each case, the reporting is required to be made on a signed Annual Statement. The employee must provide his or her Annual Statement to the company no Iater than November 15th each year. Please note that the employee's daily commute to and from his / her normal place of business is personal mileage, and must not be recorded as business mileage. Vehicle Usaoe Logs - * The vehicle usage log is intended to represent a factual record of the employee's qualifying business mileage for both the month and the vehicle fiscal year to date. Employees will need this mileage information to properly complete the Annual Statement. These logs are impoftant tax documents and are required by the IRS to suppoft the business use of a company-provided vehicle and to properly document the business portion of an allowance. Employees are required to prepare and submit such a log or record each month. A sample auto log is presented as Attachment #2. Reoortino - For tax purposes, the company must make an annual determination of the personal income portion of the company-provided vehicle and the allowance paid, based on the business and total usage of the vehicle used for the twelve months ended October 31't. No later than November 15th (two weeks after the end of the vehicle tax fiscal year), each employee who received an allowance during the year should submit an Annual Statement. These employees should report on that Annual Statement the business mileage for the twelve months then ended (or such shorter period during which an allowance was received), and must elect either to use the standard IRS mileage allowance or to itemize the actual costs of the personal vehicle used for business purposes. The company reserves the right to request reasonable additional documents it deems necessary to support the mileage or the expenses reported on the Annual Statement. Note that the reporting on the Annual Statement is for the twelve months ended October 31"t each year. The IRS permits this early annual cut-off for the vehicle fiscal year so that companies may have sufficient time to calculate the employee's imputed taxable income (if any) and deduct the appropriate taxes from the employee's pay in that current calendar year. Calculation of Taxable Income - The taxable value of the personal use of a company- provided vehicle or the personal portion of a vehicle allowance must be added to the employee's W-2 each year, and certain taxes must be withheld by the company. Such taxable income will be determined as follows: i The taxable value of the personal use of a company-provided vehicle will be calculated in accordance with the appropriate IRS requirements. Currently, taxable income must include two items: (a) the imputed value of the personal use of the vehicle determined by multiplying the personal use percentage (per the employee's Vehicle Policy - Revised Lzl3Llz00gPage 3 of 13 suz-w-20-02 IPUC DR 63 Attachment 2 Page 3 of 13 4,ov- 7. Request No. 63 Attachment 2 Page 4 of 13 final auto log) times the IRS determined lease value (based on the fair market value of the vehicle when first put into service) and (b) the value of any personal-usage fuel paid for or provided by the Company (the IRS fuel rate times the personal mileage). ii The taxable portion of an allowance provided to the employee is that portion of the allowance that is not supported as business use expense by the employee on the Annual Statement. The excess (if any) of the allowance paid over the employee's repofted business expense will be considered personal lncome subject to tax. Should the employee's business expenses exceed the allowance received, there will be no additional payment by the Company, nor will the Company use such amount to reduce the employee's taxable income. As mentioned in the Overview (above), the business expense portion of the allowance can be based on one of two documentation approaches for employees recelving an allowance. Employees with a company -provided vehicle must provide an auto log with their documented business mileage. Business Mileage Method - This is the simpler of the two methods. The employee must record their business miles on a log or similar document, and the documented business expense is the result of multiplying their total business mileage for the year times the standard IRS mileage rate (net of the amount per mile reimbursed by the company for fuel; see Attachment #1). Actual Expense Method - Under this more complex method, the employee would track and repoft both their business mileage and their total vehicle miles, and would also keep records of the actual expenses of the personal vehicle they use. The business poftion of the allowance received would be calculated by multiplying the business percentage of their mileage times the actual expenses. The business percentage is the percentage derived by dividing their business miles for the year by their total miles. Once a method is used for a given vehicle, it must be used in all future years for that same vehicle. The employee's qualifying costs of the vehicle may include lease payments or depreciation (but not both, unless two different vehicles were used at different times during the year, one of which was owned and one of which was leased), insurance, repairs, maintenance, inspections, interest (on a loan for an owned vehicle) and other expenses. The vehicle expenses included on the Annua! Statement must not contain any expenses reimbursed by the Company outside of the vehicle allowance program (such as fuel, tolls and parking reimbursed on an expense repoft), and should conform to the necessary IRS rules regarding deductible expenses. It is each employee's responsibility to determine the appropriateness for tax purposes of the expenses included on the employee's Annual Statement, and the employee should seek his or her own tax advice in this regard. Allowances paid to employees wil! not be considered taxable income during the year. Should the employee timely submit an Annual Statement for the year, the Company will report in such employee's taxable income for the year only the non-business (personal) portion of each employee's vehicle allowance as calculated on the Annual Statement (subject to adjustment for errors discovered in the company's review of such Statements). Should the company discover errors or dispute any amounts on an employee's Statement, it will advise the employee of such discrepancy in an attempt to Vehicle Policy - Revised 1-2l3Ll2009Page 4 of 13 suz-w-2G,02 IPUC DR 63 Attachment 2 Page 4 of 13 SUEZ Water ldaho lnc. Case SUZ-W-20-02 UNITED WATER VEHICLE POLICY SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 2 Page 5 of 13 resolve it. The Company will add any personal amount as income to the employee's W-2 and will withhold any FICA and other required taxes. If an employee reasonably expects that a portion of the allowance received will be considered taxable personal income, the employee may wish to adjust their Federal, state or local income tax withholding to consider this additional taxable income. IMPORTANT WARNING - Although the company may periodically remind employees with allowances or company-provided vehicles of their annual reporting requirements, failure by the employee to timely submit the required documentation, regardless of whether a reminder was sent by the employer, will require that the Company report the entire amount of the vehicle allowance or company-provided vehicle value as taxable compensation on the employee's W-2. 3.6 Responsibility for and Control over Allowances: Atlowances - The determination of who wil! qualify to receive an allowance below salary grade 22 is to be made by the Segment President ultimately responsible for the employee, or, for Corporate M&S employees, by the Senior Vice President of Human Resources. Once it has been determined that an employee will receive an allowance, the manager responsible for the employee should complete a Notification of Vehicle Allowance Form (Attachment #4), have it approved by the appropriate EMT member and forward it to Human Resources. HR will file that form in the employee's personnel file, will maintain a list of all employees with Company allowances, and will send Payroll a copy of each Notification Form. HR will also send that employee a letter with this policy attached, requiring that a copy of the letter be signed & returned by the employee acknowledging his or her responsibilities under this policy. Compliance - Payroll will ensure that the employee receives the monthly allowance. Human Resources will be responsible to maintain a record of all employees receiving allowances. The Tax Department will work with Finance to monitor the submission of Annual Statements, and with Payroll to coordinate the calculation of imputed income and the tax withholdings required in November and December each year. Resoonsibilities 4.L Policv Settino - Senior Vice President - Human Resources 4.2 Imolementation - Human Resources DepaftmenVProcurement Depaftment 4.3 Reoorting & Compliance - Controller, Tax Director Attachments: 5.1 Schedule of Vehicle Allowances and Vehicle Mileage & Fuel Reimbursement Rates 5.2 Recommended Monthly Vehicle Usage Log 5.3 Annual Employee Vehicle Allowance Statement Vehicle Policy - Revised L2l3U2OOgPage 5 of 13 suz-w-20-02 IPUC DR 63 Attachment 2 Page 5 of 13 4 5 -r,"k""-j' I' rl UNITED WATER VEHICLE POLICY SUEZ Water ldaho lnc. Case SUZ-W-2G'02 Request No. 63 Attachment 2 Page6of13 5.4 Notification of Vehicle Allowance Form suz-w-2G02 IPUC DR 63 Attachment 2 Page 6 of 13 Vehicle Policy - Revised L2/3Ll2O09Page 6 of 13 Position In Company Annual Allowance EMT $14,000.00 Grade 22-23 $11,000.00 G rade20- 2 1 *g ra ndfathe red $6,600.00 Others(grandfathered or specifically approved by Segment president member or SVP of HR based on business need) Up to $400.00 per month Standard Vehicle Allowances Amounts as of July 1, 2O1O Schedule of Vehicle Mileage & Fuel Reimbursement Rates Mileage Reimbursement Amount per Mile Official IRS Per Mile Rate for Business Use of a Personal Vehicle 2010 - 50 +,*f** Fuel Rate per Mile for Business Use for an Employee Who Receives an Allowance or Leased Vehicle 2010-13.54x Note: *The official IRS rate per mile includes an amount for fuel. Therefore, the rate used in the business mileage method of determining business expense on the Annual Employee Vehicle Allowance Statement is the Official IRS Per Mile Rate less the per mile fuel rate shown above. *xAmount per mile as amended from time to time by the IRS SUEZ Water ldaho lnc. Case SUZ-W-2G.02 Request No. 63 Attachment 2 Page 7 of 13 ATTACHMENT #1 Dated July 1, 2OlO suz-w-2().02 IPUC DR 63 Attachment 2 Page 7 of 13 Vehicle Policy - Revised t2l3tl200gPage 7 of 13 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 2 Page 8 of 13 ATTACHMENT #2 Revised TlU2OlO United Water Company - Provided Vehicles, Allowances & Use of Personal Vehicles Reporting and Taxes Sample Vehicle Mileaqe Loq Employee: Location: Company: Odometer Readings & Mileage: United Water Vehicle Usage Log Vehicle Year Ended October 3l' 20- 1 2 Log 3 End of prior I current month Beginning of "Period" Mileage for Period Less Business Miles (below) Personal Miles B C=A-B D =C-D =E/c I certify that the above is a true and accurate record of the use of this vehicle Employee Signature Perconal Percentage for Year to Date < Total Business Mileage for Month suz-w-20-02 IPUC DR 63 Attachment 2 Page 8 of 13 November 2004 Prior Mo. YTD Current Month Current YTD Business Mileage for Current Month (daily odometer readings are optional) Odometer Finish Business Mileage Eig[ Description of Business UseDate Day of Week Odometer Start IIII Vehicle Policy - Revised L2l3Ll2OOgPage 8 of 13 Date SUEZ Water ldaho lnc. Case SUZ-W-20-02 Lease Payments (if vehicle is leased) Depreciation (if you own the vehicle) Insurance Taxes Registration Fees Repairs and Maintenance Other (describe): Garage Rental Total Expenses Business Poftion of Employee Expenses: Business Percentage from Final Mileage Log (see above) Business Portion of Employee Expenses lilAlternative - Business Mileage times IRS Mileage Rate * Vehicle Policy - Revised L2l3tl2009Page 9 of 13 Request No. 63 Attachment 2 Page 9 of '13 ATTACHMENT #3 Dated July, 2O1O United Water Company - Provided Vehicles, Allowances & Use of Personal Vehicles Sam e Annual Em Vehicle Allowance Statement UNITED WATER ANNUAL EMPLOYEE VEHICLE STATEMENT For Employees Receiving a Vehicle Allowance Vehicle Year Ended October 31, 20_ Employee Name: Location: Company: Auto Year & Itlake I Period During Year When Allowance Was Date From To # of months Total Total Allowance Received x 12 months Summary of Vehicle Year l{ileage(November to October) Odometer Reading - End of Period (normally Oct 3lst) Odometer Reading - Beginning of Period (normally Nov 1st) Total Vehicle Miles Business Miles Business Percentage IIf Expenses of Vehicle Used for Business Purposes: List expenses only for the period during which an allowance was received. Do NOT include any expenses for which you received a separate reimbursement from the company (parking, tolls, etc.) < < List All ptional =B*C IPUC DR 63 Attachment 2 Page I of 13 x Rate SUEZ Water ldaho lnc. Case SUZ-W-2G'02 Request No.63 Attachment 2 Page 10 of 13 suz-w-20-02 IPUC DR 63 Attachment 2 Page 10 of 1 3 Vehicle Policy - Revised tzl3Ll200gPage 10 of 13 Business Expense (automatically selects higher of two)*IRS Rate - ftElgg[ipg Fuel Rate - Fuel (Updated as needed IRS Rate - Total by Tax Dept.) V Taxable Poftion of Vehicle Allowance: Business Portion of Employee Expenses =[ =p Excess of Allowance Received over Business Portion of Employee Expenses (enter only if a positive number) =E-F I hereby certify that the above information is accurate and correct to the best of my knowledge, that it is supported by monthly usage logs or a comparable document, and that I have only included those expenses properly includable (if applicable): Signed:Date: $ 0.300 $ 0.075 t o.375 SUEZ Water ldaho lnc. Case SUZ-W-2G'02 Request No. 63 Attachment 2 Page 11 of13 Aftachment #3 (continued) United Water Company - Provided Vehicles, Allowances & Use of Personal Vehicles suz-w-20-02 IPUC DR 63 Attachment 2 Page 11 of13 Vehicle Poliry - Revised L2l3U2009Page 11 of 13 SUEZ Water ldaho lnc. Case SUZ-W-20-02 Request No. 63 Attachment 2 Page '12 of 1 3 ATTACHMENT #4 Dated luly 1, 2OlO United Water Company - Provided Vehicles, Allowances & Use of Personal Vehicles Notification of Vehicle Allowance or Company-Provided Vehicle Filino: 1. SLT member to Segment HR Head 2. Segment HR Head to Send to Segment President or Senior Vice President of Human Resources 3. Human Resources to Forward Copy to Payroll & Accounting Emolovee Name & Location Name: Employee SSN: Business Address: Home Address: Vehicle Allowance: Effective Date: Monthly Allowance: gB $ Company-Provided Vehicle: Effective Date: Year, Make and Model: Location of Vehicle: Monthly Leased Cost: $ Reason Company-Provided Sionatures: Segment President / SVP/HR: Print Name Print Name suz-w-2G.02 IPUC DR 63 Attachment 2 Page 12 ol 13 Vehicle Policy - Revised L2l3Llz00gPage 12 of 13 SUEZWater ldaho lnc. Casc SUZ-W-2S,02 Date: Request No. 63 Attachment 2 Page l3 of 13 Date: suz-\rv-2G02 IPUC DR 63 Attadrment2 Page 13 of 13 Vehlcle Pollqy - Revlsed LZl3LlzOOgPage 13 of 13 SUEZ WATER IDAHO INC. cAsE suz-w-20-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: D. Njuguna REQUEST NO. 64: Please provide a schedule showing actual rate case costs incurred to date. Please supplement this response each month as additional costs are incurred. RESPONSE NO. 64: PIease see below actual rate case expenses incurred through November 30,2020 Line No.Expense Description Amount t Outside Legal Counsel $ 6,942 2 Rate of Return Study S11,9os 3 Depreciation Study S38,059 4 Customer Notices, Public !nformation Campaign s37,106 5 Total $94,oLz suz-w-20-02 IPUC DR 64 Page 1 of 'l SUEZ WATER IDAHO INC. cAsE suz-w-20-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness J. Cary REQUEST NO. 65: PIease provide the details and narrative of how the Company calculated the power deferral as shown in Witness Cary's Exhibit No 10, Schedule l, Page 28. RESPONSE NO. 65: The Company's power deferral per Exhibit No 10, Schedule 1, Page 29 was calculated using planned kilowatt hours (kWh's) and expected water production levels by month based on a correlation of historical kWh's per million gallons of water produced. The projected kWh's for deferral are priced at a rate of $0.004862 per kWh using ldaho Power Company's June 1, 2A20 Power Cost Adjustment (PCA) Schedule 55 tariff rate. Even though three of the Company's facilities are billed under ldaho Power Company's Tariff Schedule 7 and a slightly higher Fixed Cost Adjustment (FCA) Schedule 54 rate of $0.008381, for the sake of simplicity and materiality only the lower PCA rate was utilized in the deferred power projection calculation. Deferred power also accumulates interest. Monthly 1l12th of the interest rate (2o/o for 2020 per Case No. GNR-U-19-01 Commission Order 34482) is applied to the growing deferred power balance. The June 2020 test year end accumulated deferred power and interest on deferred power balance per the Company's books was $679,825. As reflected in Workpaper No. 10 Schedule 29, the projected July 2020 through March 2021 additional power deferra! is $116,306 (=23,921,382 kwh . $0.004862PCA rate) plus interest of $11,387 producing a projected March 2021 total deferred power balance of $807,518 (=$679,825 + $116,306 + $11,387). suz-20-02 IPUC DR 65 Page 1 of 1