20210106Staff 123-133 to Suez.pdf

DAYN HARDIE (ISB No. 9917)
MATT HUNTER (ISB No. 10665)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-O3t2
[phone]
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Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF SUEZ WATER IDAHO
INC.'S APPLICATION FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
cAsE NO. SUZ-W-20-02
SEVENTH PRODUCTION
REQUEST OF THE
COMIVIISSION STAFF TO
suEz WATER IDAHO,INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie and Matt Hunter, Deputy Attorneys General, request that Suez Water Idaho,
Inc. provide the following documents and information as soon as possible, but no later than
WEDNESDAY, JANUARY 27, 202I.
This Production Request is to be considered as continuing, and Suez Water Idaho, Inc. is
requested to provide, by way of supplementary responses, additional documents that it, or any
person acting on its behalf, may later obtain that will augment the documents or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
SEVENTH PRODUCTION REQI]EST
TO SUEZ WATER
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1 JANUARY 6,2021
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. 123: Following up on Witness Kahn's direct testimony page 5, please
provide the company's ARAM calculation for years 2018 through2o2o.
REQUEST NO. 124: Please explain how the M&S Expenses are assigned or allocated
to Suez Water Idaho, Inc. Does the Company get invoiced for M&S expenses? If so, please
provide the invoices for M&s Expenses for January 2019 through July 2020.
REQUEST NO. 125: In Order No. 33965 (Case No. GNR-U-18-01), the Commission
ordered each rate-regulated utility to immediately account for the financial benefits from the
January 1, 2018 tax rate reduction to 2lVo as a deferred regulatory liability. Please provide the
amount the Company recorded to the deferred regulatory liability as required by that Order.
REQUEST NO. 126: Following up on Production Request No. 3, please provide the
amount of outside legal expense included in the Company's test year and proposed for recovery
in this case. Please reconcile the outside legal expenses provided in the Company's response to
Production Request No. 3 to the actual test year amount for outside legal expense.
REQUEST NO. 127: In the previous four general rate cases, the Company used the
Balance Sheet method for determining Working Capital. In this application the Company is
using the 1/8th Operation and Maintenance or 45-day method. Please explain why the Company
is now using the 45-day method instead of the Balance Sheet method.
REQUEST NO. 128: Please provide Exhibit 7,the Balance Sheet Per Books as of
June 30, 2020 in Excel format. Please provide the Regulatory Balance Sheet for the period
ending December 31,2019. In addition, please provide the Rolling Balance Sheet beginning
with January 2020 and ending with December 2020 in Excel format.
SEVENTH PRODUCTION REQUEST
TO SUEZ WATER 2 JANUARY 6,2021
REQUEST NO. 129: For the Company's residential customers, please provide monthly
billed consumption for the January 1, 1990 through December 3I,2020 billing cycles. Please
include the following information for each billing month:
a. Billing period;
b. Total billed residential consumption; and
c. Total number of residential bills.
REQUEST NO. 130: For the Company's commercial and industrial customers, please
provide monthly billed consumption for the January 1, 1990 through December 31,2020 billing
cycles. Please include the following information for each billing month:
a. Billing period;
b. Total billed commercial and industrial consumption; and
c. Total number of commercial and industrial bills.
REQUEST NO. 131: In reference to the AMI meters the Company is using for
residential, commercial, and industrial customers, please answer the following questions:
a. Please describe the functions of the Company's AMI meters.
b. How often do the meters save consumption data?
c. How many data points can the meters save and transmit?
d. Which functionalities are the Company currently using?
e. Which functionalities do the Company plan to use in the future?
f. What duration of time is water consumption currently being recorded for customer?
(e.g. hourly, daily, monthly, bi-monthly) Does the Company plan to continue using
the same consumption measurement in the future?
g. What percentage of residential, commercial, and industrial customers currently have
AMI meters installed?
h. What is the estimated date AMI meters will be installed for all residential,
commercial, and industrial customers?
SEVENTH PRODUCTION REQUEST
TO SUEZ WATER 3 JANUARY 6,2027
REQUEST NO. 132: For the accounts listed below, please provide a list of all assets
incorporated in each account:
a. Account No. 340.5 Software - Lighthouse
b. Account No. 340.5 Computer Hardware
c. Account No. 340.5 Computer Software
d. Account No. 340.5 Office Furniture and Fixtures
e. Account No. 342.5 Stores Equipment
f. Account No. 343.5 Tools, Shop, and garage Equipment
g. Account No. 344.5 Laboratory Equipment
h. Account No. 346.5 Communication Equipment
i. Account No. 347.5 Miscellaneous Equipment
j. Account No. 348.5 Master Pan
k. Account No. 348.5 Other Tangible plant
REQUEST NO. 133: For the accounts listed below, please provide all supporting
documentation used to determine the useful life, removal costs, and net salvage values:
a. Account No. 307.2 Wells and Springs
b. Account No. 309.2 Supply Mains
c. Account No. 320.3 Water Treatment Equipment
d. Account No. 320.3 Treatment Membranes
e. Account No. 330.4 Distribution Reservoirs and Standpipes
f. Account No. 331.4 Transmission and Distribution Mains
g. Account No. 333.4 Services
h. Account No. 334.4 Meters and Meters Installations
i. Account No. 335.4 Hydrants
j. Account No. 341.5 Transportation Equipment
k. Account No. 345.5 Power Operated Equipment
SEVENTH PRODUCTION REQUEST
TO SUEZ WATER JANUARY 6,20274
DATED at Boise, Idaho, this L+b day ofJanuary 2021
Hardie
Deputy Attorney General
i:umisc:prodreq/suzw2O.2dhmhtnc prod req 7
SEVENTH PRODUCTION REQI.]EST
TO SUEZ WATER 5 JANUARY 6,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF JANUARY 2021,SERVED THE FOREGOING SEVENTH PRODUCTION REQUEST OF THECOMMISSION STAFF TO SUEZ WATER IDAHO, INC., nq cesE No. SUZ-W-20-02,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GTVENS PURSLEY LLP
POBOX2720
BOrSE rD 8370t-2720
E-MAIL: mcc@givenspursle)r.com
prestoncarter @ givenspursley.com
LORNA K. JORGENSEN
JOHN C. CORTABITARTE
ADA COUNTY PROSECUTING
ATTORNEY'S OFFICE
CNIL DTVISION
2OO W. FRONT STREET, ROOM 319I
BOISE, TD 83702
E-MAIL: civilpafiles @ adaweb.net
SCOTT B. MUIR
DEPUTY CITY ATTORNEY
BOISE CMY ATTORNEY'S OFFICE
I5O N. CAPMOL BLVD.
P.O. BOX 500
BOISE,ID 83701-0500
E-MAIL : boisecitlzattorney @ cityofboise.org
BRAD M. PURDY
2019 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.niu @suez.com
NORMAN M. SEMANKO
PARSONS BEHLE & LATIMER
8OO W. MAIN ST., STE.l3OO
BOISE, TD 83702
E-MAIL: NSemanko @parsonsbehle.com
Boi sedocket @ parsonsbehle.com
MARTY DURAND
PIOTROWSKI DURAND PLLC
1O2O MAIN ST., STE. 440
P.O. BOX 2864
BOISE,ID 8370I
E-MAIL: maftv@ w.com
KEN NAGY
ATTORNEY AT LAW
P.O. BOX 164
LEWISTON, ID 8350I
E-MAIL: knagy @lewiston.com
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF
THORVALD A. NELSON
555 tTrH ST., STE. 3200
DENVER, CO 80202
E-MAIL: [e-mail]
tnelson @ hollandhart.com
aclee @ hollandhart.com
JIM SWIER
GREG HARWOOD
MICRON TECHNOLOGY, INC.
SOOO S. FEDERAL WAY
BOISE, TD 83707
E-MAIL: [e-mail]
[e-mail]
gl garganomari @ hollandhart.com
S Y
CERTIFICATE OF SERVICE