20210113Staff 134-151 to Suez.pdf

DAYN HARDIE (ISB No. 99lt)
MATT HUNTER (ISB No. 10665)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.007 4
[phone]
[phone]
;i::'i; i" i .'i'*P'*
:,..1":,ii:i i3 FH 3r 3l
Street Address for Express Mail:
II33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, D 83114
Attorneys for the Commission Staff
BBFORE 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
EIGHTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
suEz WATER IDAHO,INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie and Matt Hunter, Deputy Attorneys General, request that Suez Water Idaho,
Inc. provide the following documents and information as soon as possible, but no later than
WEDNESDAY, JANUARY 27, 2021.r
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.
I Staffis requesting an expedited response. Ifresponding by this date will be problematic, please call Staffs attorney
at [phone].
EIGHTH PRODUCTION REQUEST
TO SUEZ WATER JANUARY I3,2O2I
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Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
ln 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. 134: Please explain why the Company used the period 1990 - 2019 to
create its residential weather normalization model but used the period 1995 -2019 to create its
commercial weather normalization model (ref. Company Workpapers 15334198_|_SUZ-W-20-
02 Revenues.XLSX).
REQUEST NO. 135: With reference to Company Adjustment 28, shown on Exhibit
No. 10, Schedule 1, page 28, please provide the source documentation indicating that the level of
cash contributions to the pension plan were the minimum required contributions. Please provide
the ERISA required minimum contributions for the years 2016-2020, along with all supporting
documentation.
REQUEST NO. 136: Please update the June 30,2020 test year amounts in the
workpapers and the exhibits for the Opex Adjustments Summary Exhibit No. 10 and the Rate
Base 2020 Exhibit No. 11 with December 31, 2020 year-end amounts.
REQUEST NO. 137: Please quantify the amount of pay increases granted and incentive
payments paid in 2O2O and included in the test year ending June 30, 202O in Adjustment No. 1,
Adjustment of Payroll Expense from Exhibit No. 10, Schedule 1. Please identify the accounts
that the pay increases have been booked to and separate the pay increases by bargaining unit, and
by salaried, and non-exempt employees.
EIGHTH PRODUCTION REQUEST
TO SUEZ WATER 2 JANUARY I3,2O2I
REQUEST NO. 138: Please identify the amount of pay increases granted and incentive
payments paid in 2020 fromJuly through December 31,2020. Please identify the accounts that
the pay increases have been booked to and separate the pay increases by bargaining unit, and by
salaried, and non-exempt employees.
REQUEST NO. 139: Please provide business case documentation or project selection
analysis documents for all IT projects listed below in M&S lnformation Technology
depreciation.
a. Ring Central to Paramus
b. Engineering - Project & Portfolio Financial Management
c. Data Reservoir
d. SCADA - Endpoint Security
e. Stratus Cloud
f. Mysuezwater.com Customer Payments (WO#: C18J908_305_001)
g. Engineering - Project & Portfolio Financial Management
h. eBill to Web migration
i. Headquarters Relocation (WO#: C14K201_305)
j. IT Storage Refresh (WO#: Cl8J911_305_001)
k. IVR Call Center Upgrade (WO#: Cl8J904_305_001)
1. PeopleSoft Implementation (WO#: Cl4J106_305_001)
m. MySUETl,l ater (WO#: C 1 5J 109_305_001)
n. mysuezwater.com Phase 2 (WO#: Cl6J902_305_001)
o. CCB Phase II (WO#: C15J107_305_001)
p. Hyperion Implementation (WO#: Cl4J 113_305_001)
q. Hyperion Consolidation Reporting (WO#: CITJOOT _305_001)
r. Power Plan Implementation (WO#: Cl4Jl07 _305_001)
EIGHTH PRODUCTION REQUEST
TO SUEZ WATER JANUARY I3,2O2IaJ
REQUEST NO. 140: Regarding the File, "Appendix D Net Salvage history," submitted
by the Company as an attachment to the depreciation study, please provide invoices and itemized
supporting documentation for the costs of removal that were incurred by the company for the
following accounts:
a. 331. Transmission and Distribution
b. 333. Services
c. 334. Meters
REQUEST NO. 141: Please update the workpaper provided with the Application
labeled "M&S Shared Assets" with actual amounts through December 31,2020.
REQUEST NO. 142: Please provide all legal expenses booked to account 504-009-23
Out Serv-A&G Ops assigned to regulatory matters filed with IPUC by year for the last five
years. Please provide in Excel format and reference case numbers with the associated costs.
REQUEST NO. 143: Regarding Production Request Response No. 87, please respond
to the following:
a. Why does the Company anticipate the comprehensive tank inspections cost to be
$45,123 going forward instead of the $16,538 cost from 2Ol7 to2OI9?
b. How many backup generators has the Company added since 2017?
c. Please provide the 2019 Northwest Power Systems generator maintenance costs
and the number of backup generators included in the maintenance costs.
d. Was Account 50655 adjusted for the coding change that is now captured in
Account 50400? If so, please explain why and provide the adjustment amount. If
not, why not?
REQUEST NO. 144: Regarding Production Request Response No. 88, please respond
to the following:
a. Please provide the length of time the monitoring waivers allow for the reduction
of repeat monitoring frequency.
EIGHTH PRODUCTION REQUEST
TO SUEZ WATER JANUARY I3,2O2I4
b. When will the Company know the effect of the new protocols on every supply
source in the SUEZ system?
c. Please provide a list of each supply source the Company knows will be affected
by the new protocol and the total cost change for each supply source.
REQUEST NO. 145: Regarding Production Request Response No. 89, please respond
to the following:
a. Please provide all the alternative customer notification systems the Company
considered prior to choosing the Notify system.
b. Please provide all quotes the Company received when looking for a customer
notification system.
REQUEST NO. L46: Regarding Production Request Response No. 90, please respond
to the following:
a. What is the amount of the maximum annual fee for the Cityworks license? Is
SUEZ-Company-wide---close to exceeding the maximum annual fee or
1,000,000 service connections? Please explain.
b. Please explain why the Cityworks license number of employees increased by 20
employees when comparing the test year and proforma year numbers, but the
number of employees in the Payroll Expense adjustment only increase by ten
employees.
REQUEST NO. 147: Regarding Production Request Response No. 91, please respond
to the following:
a. Were any non-compliance events identified in the Idaho Business Unit in the
2018 Environmental Compliance audit?
b. Please provide all the alternative water quality management systems the Company
considered prior to choosing the SAM system.
c. Please provide all quotes the Company received when looking for a water quality
management system.
EIGHTH PRODUCTION REQUEST
TO SUEZ WATER JANUARY I3,2O2I5
REQUEST NO. 148: Regarding Production Request Response No. 92, how often will
confined space training be performed?
REQUEST NO. 149: Regarding Production Request Response No. 94, please provide a
list of all chemical assessments the Company has performed in the last five years. Include the
individual cost for each chemical assessment.
REQUEST NO. 150: Regarding Production Request Response No. 95, is every
Company employee required to have every item of PPE on the list and does every employee
receive each item of PPE? Please explain.
REQUEST NO. 151: In the 2019 Suez Water Annual Report (page 3), the Company
shows Operating Expenses of $407,098 for chemicals (ACCT # 618 - Chemicals). Please
explain why this amount is 2I7o higher than the prior year of $335,785, while during this same
period the amount of water sold declinedby 67o.
DATED at Boise,Idaho, tti. 13$ day of January 2021
Dayn
Deputy Attorney General
i:umisc:prodreq/suzw20.2dhmhtnc prod req 8
EIGHTH PRODUCTION REQUEST
TO SUEZ WATER 6 JANUARY I3,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13th DAY OF JANUARY 2021,
SERVED THE FOREGOING EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO SUEZ WATER IDAHO, INC., IN CASE NO. SUZ-W-20-02,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GTVENS PURSLEY LLP
POBO)(2720
BOISE D 8370r-2720
E-MAIL: mcc @ givenspursley.com
prestoncarter @ givenspursley.com
LORNA K. JORGENSEN
JOHN C. CORTABITARTE
ADA COUNTY PROSECUTING
ATTORNEY'S OFFICE
CryL DryISION
2OO W. FRONT STREET, ROOM 3191
BOISE, D 83]02
E-MAIL: civilpafiles @ adaweb.net
MARY R. GRANT
SCOTT B. MUIR
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
150 N. CAPITOL BLVD.
P.O. BOX 500
BOISE, ID 83701-0500
E-MAIL: boisecitlzattorney @cityofboise.org
BRAD M. PURDY
2019 N. lTrH ST.
BOISE, D 83702
E-MAIL: bmpurdy @hotmail.com
DAVID NJUGUNA
MGR - REGULATORY BUSINESS
SUEZ WATER MGMNT & SERVICES CO
461 FROM ROAD SUITE 4OO
PARAMUS NJ 07052
E-MAIL: [e-mail]
NORMAN M. SEMANKO
PARSONS BEHLE & LATIMER
8OO W. MAIN ST., STE.l3OO
BOISE, ID 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 83701
E-MAIL: marty @idunionlaw.com
KEN NAGY
ATTORNEY AT LAW
P.O. BOX 164
LEWISTON, ID 83501
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF
THORVALD A. NELSON
555 lTrH ST., STE. 3200
DENVER, CO 80202
E-MAIL: [e-mail]
JIM SWIER
GREG HARWOOD
MICRON TECHNOLOGY, INC.
8OOO S. FEDERAL WAY
BOISE,ID 83707
E-MAIL: [e-mail]
[e-mail]
tnelson @ hollandhart.com
aclee @ hollandhart.com
gl garganomari @ hollandhart.com
SECRET
CERTIFICATE OF SERVICE