20210113Suez to Staff 111-122.pdf

Michael C. Creamer (lSB No. 4030)
Preston N. Carter (lSB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise, lD 83702
Telephone: [phone]
Facsimile: (208) 388-1 300
mcc@qivenspu rslev.com
p resto n ca rter@q iven spu rslev. co m
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Aftorneys for SUEZ Water ldaho lnc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN 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
Case No. SUZ-W-20-02
SUEZ WATER IDAHO INC.'SRESPONSE TO SIXTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF
suEz water Idaho lnc., ('sUEZWatet''or "company") submits the following
responses to the Sixth Production Request of the Commission Staff to SUEZ Water,
dated December 23,2020. Please note that the responses to Requests Nos. 113 and
121 are confidential and will be submitted under separate cover per the Commission's
rules
DATED: January 13,2021
SUEZ WATER IDAHO INC.
'/
--':-
N 4-*{ .-
By:
Michael C. Creamer
Preston N. Carter
Attorneys for Applicant
SUEZWATER'S RESPONSE TO SIXTH PRODUCTION REQUEST
OF THE COMMISSION STAFF.l
1 548251' _1 .DOCX [30-209]
CERTIFICATE OF SERVICE
I certify that on January 13,2021, a true and correct copy of the foregoing was
served upon lll parties of record in this proceeding via electronic mail as indicated
below:
Commission Staff
Jan Noriyuki, Commission Secretary Electronic Mail
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, lD 83714
[e-mail]
Dayn Hardie Electronic Mail
Matt Hunter
Deputy Attorney General
ldaho Public Utilities Commission
11331W. Chinden Blvd., Bldg.8, Ste.201-A
Boise, lD 83714
[e-mail]
matt. h unter@puc. idaho.qov
lntervening Parties
Ada County:
Lorna K. Jorgensen
John C. Cortabitarte
Ada County Prosecuting Attorney's Office
Civil Division
200 W. Front Street, Room 3191
Boise, lD 83702
civi I pafiles@adaweb. net
CAPAI: - Non-Confidential Responses Only
Brad M. Purdy
2019 N. 17th Street
Boise, lD 83702
[e-mail]
I ntervenors: - Non-Confidential Responses
Only
Marty Durand
Piotwrowski Durand PLLC
1020 Main Street, Suite 440
P.O. Box 2864
Boise, lD 83701
[e-mail]
SUEZWATER'S RESPONSE TO STXTH PRODUCTION REQUEST
OF THE COMMISSION STAFF.2
1 s482512 _1 .OOCX [30-2091
Electronic Mail
Bolse City: - Non-Confidential
Responses Only
Scott B. Muir
Deputy City AttorneY
Boise City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, lD 83701-0500
bo i seci tvatto rnev@cityofboi se. o rq
Suez Water Customer GrouP:
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main Street, Suite 1300
Boise, lD 83702
NSema nko@ parsonsbehle. com
Boisedocket@ pa rsonsbeh le.com
ldaho Fair House Council, lnc.
Ken Nagy
Attorney at Law
P.O. Box 164
Lewiston, lD 83501
com
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart
555 17th St., Suite 3200
d a ru esch hoff@ho I la nd hart. co m
Jim Swier
Greg Hanrood
Micron Technology, lnc.
8000 S. FederalWay
[e-mail]
gbhanrvood @m icron. com
tnelsontOhol landhart.com
aclee@holland hart.com
qlqarqanoa mari@ holland hart.com
Preston N. Carter
SUEZ WATER'S RESPONSE TO SIXTH PRODUCTION REQUEST
OF THE COMMISSION STAFF.3
1 548251 2_1 .DOCX [30-2091
SUEZ WATER IDAHO INC.
CASE SUZ.W-20.02
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness:J.Cary
REQUEST NO.111:
Please update the projected amounts in Witness Cary's Exhibit No. I l, Schedule No. 2
with actual amounts as available. Please provide in Excel format with allformulas intact.
RESPONS E NO. 111:
PIease see the attachment to this response for updated Exhibit No. 11, Schedule 2 with
actual amounts to November 2020.
suz-w-20-02
IPUC DR 111
Page 1 of 1
CASE NO. SIJZ.W.2O-VL
Response No. 111 Attachment
Excel Spreadsheet Provided Separately
in Native Format
SUEZ WATER IDAHO !NC.
GASE SUZ-W-20-02
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
P reparer/Sponsoring Witness J. Cary
REQUEST NO. 112:
please provide the monthly plant-in-service balances from 2018 to present in the same
format as Witness Cary's fifriUit No. I l, Schedule No. 3, Page No 2. Please provide in
Excel format with all formulas intact.
RESPONSE NO.112:
please see the attachment for the monthly plant in service balances from January 2018
to November 2020.
suz-w-20-02
IPUC DR 112
Page 1 of 1
CASE NO. SUZ.W-20-02
Response No. 1 12 Attachment
Excel Spreadsheet Provided Separ ately
in Native Format
SUEZ WATER IDAHO INC.
CASE SUZ.W.2O.O2
SIXTH PRODUCTION REQU EST OF THE COMMISSION STAFF
Preparer/Sponsori ng Witness J. Cary
REOUEST NO. 1 14:
please provide supporting documentation of the Deferred Customer Payment Fees
stated in Witness iary's einiUt No. 10, Schedule No. 1, Page No. 31.
RESPONSE NO. 114:
please see response to Production Request No. 98 for the schedule of deferred
customer payment fees through November 2020.
suz-w-20-02
IPUC DR 114
Page 1 of 1
Preparer/Sponsoring Witness:J. Cary
REQUEST NO. 115:
Please provide a schedule of the maintenance deferred and overtime accrued due tostaffing levels that wil! be cured by the hiring of ten employees. Please quantify the dollar
amount of overtime attributable to understaffing that is currently included in the test year
ending June 30, 2020, and in the pro forma adjustments.
RESPONSE NO. 115:
A schedule of maintenance deferred is offered below based on new staffing positions
described in previous Company response to Request No. 47. Note that overtime
utilization is generally viewed as unavoidable and not linked to the planned or deferred
maintenance activities associated with these positions.
Average annual overtime spending since 2017 is estimated to be $3S3k per year, withspending as of June 2020 in the test year at $397k (lS% Opex, 25o/o Capex). During the
test year, overtime spending was near normalfor the prior 3-year period.
Position
Engineeilng Aomin
Customer Service
Representative
Environmenta!
Health & Safety
Manager
Engineering Design
Technician
Operator
Utility Worker
lnventory Control
Specialist
Schedule of Maintenance Deferred
No maintenance deferred or overtime due to this
backfill position
No maintenance deferred due to this position
(backfill)
Catch up and re-establishment of safety training and
inspection programs related to compliance for
OSHA, DEQ, and NFPA.
Backlog of engineering design tasks for capital
program delivery and developer project review
Pressure reducing valve station inspection and
maintenance, maintenance of chemical pumping
systems, field maintenance of facilities.
System valve inspection and operation,
unidirectional flushing activities, maintenance of
hydrants, maintenance of system air and blow-off
valves, large meler field testing
Administration of company material stores.
suz-w-20-02
IPUC DR 115
Page 1 of2
SUEZ WATER IDAHO INC.
CASE SUZ-W-20-02
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Position
Operations
Supervisor
Schedule of Maintenance Deferred
Direct oversight of maintenance and repair activities
related to transmission and distribution
infrastructure.
Area oversight of al! activities related to water
treatment and production, transmission and
distribution, and meter reading.
Activity planning and purchasing support for all
activities related to water treatment and production,
transmission and distribution, and meter reading
Operations
Manager
Operations
Planner/Buyer
suz-w-20-02
IPUC DR 115
Page 2 of 2
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: M. Thompson
REQUEST NO. 116:
ln 2015, the Company was able to function in a safe, reliable manner with 882 customersper employee. Please explain why the Company now proposes to operate at 816
customers per employee.
RESPONSE NO. 116:
As provided in the Company's response to production requests No. 44 and 45, actual
reported customers per employee were 957.70 in 2015, peaking to a high of gg7.09 in
2016, and then decreasing to a current total of 820.11 in 2020.
Year Customer Count
90,032
9L,732
93,001
95,449
97,O29
gg,4L3*
Employee Count Customer per Employee
957.79
997.09
9L1..77
945.04
924.O9
820.17
20LS
2016
20t7
2018
20L9
2020
94
92
102
101
105
720*
*projected 2020 year end totals
It is the Company's position that its current ratio of 820 customers per employee is
appropriate to sustain safe and reliable operations for growing needs of the community
we serve.
suz-w-20-02
IPUC DR 116
Page 1 of 1
SUEZ WATER IDAHO INC.
CASE SUZ-W-20-02
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness:J. Cary
REQUEST NO. I17:
Please provide a copy of the company credit card and purchase card policy, if applicable.
RESPONSE NO.117:
Please see the attachment to this response for the Company purchasing card policy.
suz-w-20-02
IPUC DR 117
Page 1 of 1
Purchasing Gard
Policies and Procedures
March 11,2019
SUEE
SUZ-W.2GO2
IPUC DR 117
Attachment
Page 1 of11
TABLE OF CONTENTS
Purpose
Scope of the Policy
Obtaining a Purchase Card (Eligibility)
Card lssuance Criteria
Card Activation
Card Renewal
Purchase Card Use
Resolving Returns, Credits, Disputes & Billing Problems
Declined Transactions
American Express Card AccePtance
Limit Changes and ExcePtions
lnactive Purchasing Cards
Transfer and Terminations
Safeguarding your Card Account
Fraud
Misuse and Policy Violations
Audit of the Card
Reconciliation Process
Purchase Card Payments
Business Ethics and Employee Obligations
Failure to Comply with Procedures and Guidelines
General Roles and Responsibilities
Amendments to Purchase Card Policy
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PURPOSE
Ttis policy sets forth the terms and conditions that employees of SUEZ North America ('SUEZ,'"SUEZ NA" or the'Company') must comply with when using SUEZ bank-issued purchasing cards (p-
Card) to purchase high volume and low cost materials and iervices. 'Low cost'tiansactions aredefined throughout this policy as those individual purchases under $2,500 per individual transaction.
Use of the P-card to purchase services is permitted for services deemed to be of low risk based onthe business unit assessment a.nd relative spend level (under $2,500 per individualtransaction).
While the P-Card program is primarily suited to OPEX purchases, theie are limited situations wnereUy
the card can be used to purchase low-risk, CAPEX equipment and services. please consult your
supervisor or Supply Chain Management ("SCM") if you require further clarification to assess whether
a contracUMSA is a more suitable approach.
Scope of the Policy
The P-card is a charge card issued by American Express which is used to make purchases forapproved business related goods and services. This is a payment method that enables SUEZ to
reduce and eliminate the administration for sanctioned goods and services, reduce overafl purchase-
to-pay process costs, increase productivity, improve relationships with suppliers and streamline theaudit process. These benefits can be achieved while maintaining management controls andpromoting spend visibility which increases our purchasing power and ensures appropriate use of
company funds.
This policy applies to all authorized SUEZ NA employees. Purchasing Cards are individually
requested and must be approved by the employee's immediate supervisor (except in rare situationswhere the requested credit limit exceeds the approveds Delegation of Authority in which case EMTapprovalwillbe required). Allpurchases willbe paid centrally by SUEZ. The SCM Department isresponsible for administering and enforcing the policies and procedures of the P+ard program asapproved by the EMT.
The P-card shall not be used as a substitute for:
. Personal business expenses. Fleet fuel cards
. Other corporate cards
Persona! use of the P-card is strictly prohibited and may result in disciplinary action up to andincluding termination of employment.
Obtaining a Purchase Card (Eligibitity)
. SUEZ employees who have a relevant business need to procure certain types of tow costgoods and services. Cards will not be issued to contingent workforce or contractors/consultantso Eligibility is subject to approvals by immediate supervisor or EMT (per the Delegation of
Authority)
Card Issuance Criteria
All cardholders must meet the following conditions, prior to card issuance:o Cardholder and approver review and accept P-Card Policy and Cardholder Agreement during
the BTS Portal application process. The Cardholder Agreement signifies that th9 applicant
and approver aci<nowledges that they have had adequate training, u.nderstld theP-card
policiii and Procedures, and accept responsibility for compliance with the P+ard Policies
and procedures. Cardholders and Approvers will need to positively attest to
reading/acknowledging the Purchasing Card Policies & Procedures prior to card issuance.
. ComplEte cardholder inkoductory training prior to card issuance. Annua!, refresher training
mustalso be completed to maintain P-Card program eligibility.
Card Application and APProval
purchasing Card applications must be submitted by the requestor using the SUEZ BTS Portal on The
Resource.-All appiiiations will be automatically routed for apprwal by immediate suPervisor or
respective EMT'member. When the steps above are successfully completed, American.Express will
issue the card within 7-10 business days. The card will be delivered directly to the Cardholder at the
business address specified on the application.
Card Credit Limits and Restrictions
To ensure adequate control, all Purchasing Cards are assigned with a standard credit limit of $2,500
per individualtransaction and $10,000 per month. Credit limit variations will be reviewed/approved on
ln exception basis only and must be accompanied by an EMT approval and business justification. ln
addition, certain spend categories have been restricted to ensure compliance with this policy. See
Appendix A for a list of restricted Merchant Category Codes (MCC).
Gard Activation
Upon receipt, employees must sign the back of the card and immediately activate the card using one
of the following processes:
Call: 1-800-3626033
Link: www.americanexpress.com/confirmcard
please note you will be asked to verify your identity using the telephone number provided on your
application. ihis ensures you are the only one authorized to activate the P-card.
Gard Renewal
The purchasing Card expires every four years, as indicated on your card. Prior to card expiration,
SCM will reviei each Cardholder's statui and if eligible, the Cardholder will be issued a new card to
ensure uninterrupted service. Cardholders are responsible for secure destruction of any expired
cards. Expired cirds will no longer remain active after 30 days of receiving the new card.
Page4ofll
Purchase Card Use
The Purchasing Card is the preferred method of payment for high votume, low cost products andg9ryi9esr For the purposes of this policy, 'high volume' is defined as those low-risk iransactions under$2,500 that generate a significant amount of administrative burden associated with the purchase topayment process (PO's, invoices, etc.).
Acceptable Purchasing Card use guidelines are provided below:
o Use for relevant, business purchase of unrestricted categories (as previously defined in thispolicy).o Certain categories of spend have been blocked to ensure proper utilization of the cardprogram per this policy. Purchase of products and low-risk services under $2,500 per individual transaction. Splittingcharges to adhere to the individualtransaction limit is strictly prohibited.o Monthly transactions limits under $10,000 (limited exceptions only with EMT approval)o Repetitive transactions such as E-Zpass@, uniforms, office supplies, etc.
Supply Chain Management acknowledges that exceptions will have to be made for certainCardholders when it makes business sense and these exceptions must be approved at the discretionof the respective EMT member.
Resolving Returns, Gredits, Disputes & Billing
Problems
The Cardholder is responsible for resolving any issues related to returns, credits, disputes and/orinconect charges.
o The cardholder willwork direcfly wlth the vendor to reach a resolution.. Disputes may result from failure to receive materials or services ordered, fraud or misuse,
altered charges, duplicate charges, defective merchandise, incorrect amounts, credits notprocessed, etc.r Cardholders may request a credit from the vendor for any disputed items as well as a creditslip to attach with your monthly statement. Disputed items should be documented in thereconciliation process.. lf an acceptable resolution cannot be reached with the vendor, contact American ExpressCustomer Service at 1-800-4924920 or dispute the transaction using American ExpressMYCA.
Declined Transactions
A transaction may be declined for various reasons, including:
o The Merchant Category Code (MCC) is not approved by SUEZ for P-card use (See AppendixA);o The amount exceeds the authorized dollar amount for a single transaction;o The maximum spending limit per month/cycle has been exceeded; ando Charging privileges may be suspended due to administrative violations per policy.
Page
lf a transaction is denied, the Cardholder should login to the American Express MYCA toolto identify
the reason for the decline and resolve the probbmlI further assistance is required please contact the
Purchasing Card Administrator.
American Express Card AccePtance
!f a supplier does not accept the American Express P-card, employees should contact the P-card
ndminiitrator. The P-card'Administrator will review the supplier with Procurement to ensure that a
competitive and preferr-J supplier does not alrealV exist. if the supptier is deemed to be essential to
the business, procurement will advise American Eipress to contact the supplier and encourage them
to enroll as a participating merchant.
Limit Changes and ExcePtions
All permanent p-card limit or restriction changes to existing cards must be requested via the BTS
portal on The Resource. Any permanent PJard limit increases over $10,000 must be approved by
an EMT member. Temporary individual credit limit increases and MCC/category restrictions will be
considered on an "*c"ition basis with appropriate business justffication at the discretion of the P-
card administrator.
lnactive Purchasing Gards
purchasing Cards are periodicatly audited for inactivity. Any P-card that has had no charge activity for
a period longerthan 12 months willbe automatically cancelled'
Transfer and Terminations
The card may not be transfened to, assigned, or used by anyone other than the designated
CaiOnoUer. hny cardholder turnover reJufiing from termination or project reassignment shou]d be
communicated to SCM immediatelY.
iftJ t4"n"g"r should also resolve iny disputes and reconcile outstanding expenses.on behalf of the
terminatedemployee. The Manager witl irirmeOiately submit a notification to cancel the account.
If any employee is taking a leave of absence, then the P+ard can be placed on an 'inactive" status
Ourdg tnd nive period ind can be reactivated upon the employee's return in writing from their
department's manager.
Safeguarding your Gard Account
It is the cardholder's responsibility to safeguard the P-card and account number at alltimes- P'cards
must be kept in " s""rre location and stro-utO only be used to process transactions by the respective
cardholder. ln order to prevent exposure to fraud, the full P-card account number should not be
recorded electronically or on paper.
Employees must report a stolen, lost or misplaced P-card immediately by telephone to American
Express (1-8004924920).
Page 6
Fraud
Fraud is the intentional, unauthorized use of a card or account, which results in damage to the
company, usually through purchases which do not benefit the company. This can occur from stolen
cards, account numbers, or counterfeit cards, used by a third-party which did not have actual, implied,
or apparent authority to use the card or account. Use of a card or account by the cardholder or other
authorized user, in collusion with a supplier for personal gain also constitutes fraud.
Employees should set-up account alerts with American Express and monitor their monthly billing
statement for unauthorized charges. Report suspected fraud immediately to the P-card Administrator
and American Express.
Misuse and Policy Violations
Policy violations may be subject to sanctions including suspension of card privileges, card
cancellation, and other disciplinary action as deemed appropriate by SUEZ. Examples of misuse and
policy violation include, but are not limited to:
Misuse: Purchase of items for personal use; purchase of restricted commodities; splitting one
charge over multiple transactions to circumvent the transaction limit; use of the card by anyone other
than the authorized Cardholder; Purchases from a Merchant set up as PO type and PO (purchase
order) is rejected.
Administrative Violations: Failure to obtain and maintain supporting documentation for card
transactions; failure of Cardholder and Approver to sign off on transactions by deadline; Lack of
timely and proper reconciliation of posted transactions; Approval of transactions that violate other
policies.
Personal use of the P-card is strictly prohibited and may result in disciplinary action up to and
including termination of employment.
Audit of the Card
As with all other forms of purchases, the use of the P-card is subject to the same levels and types of
supervisory approvals and accounting controls as would othenrvise apply. Purchases and records are
also subject to the Company's internal and externa! audit review and review by the P+ard
Administrator.
Following is an overview of the audit types and procedures. Full detail on the audit process is
available only to the P-card Administrator. Audits include but are not limited to:
. Termination Audits: Based on termination notice from Human Resources or approving
manager.o Monthly Audits: Active cards will be randomly audited to review transactions for policy
compliance.. Timely Submission: ltemized receipts, approvaland validity, appropriate use and high risk
Failed audits may result in disciplinary action of the Cardholder up to and including termination of
employment, depending on the severity of the offense. At a minimum, the following actions will be
taken:
Page7of11
1st Offense:
2nd Offense:
Warning, written communication to the Cardholder and Manager
Card is cancelled; EMT approval required for card re-activation
Reconciliation Process
Concur is a web-based toolthat allows Cardholders to review, reallocate accounting information, and
reconcile their monthly transactions. The tool is also used to interface information to SUEZ's financial
systems, generate reports, and facilitate payment to American Express. Supplier transaction
information is available via Concur wilhin 48-72 hours after the supplier processes the transaction.
The following process will be conducted for each transaction by the Cardholder:
o Verify the transaction data from American Express agrees with your own personal record of
the transactiono Review data provided by the supplier for each transaction captured at the point of sale
o Add the business justification in the comments box for each transaction
o Select the correct Expense Type for P-Card transactions (denoted by card image) and code
conectlyo Allocate transactions between various Business Units & Departments and GL Accounts.
. Add comments and other details for each transaction (ex note if a charge is disputed). ln
addition, notify your business unit accounting department of the omission for accrual.
Failure to review and/or reallocate transactions by the close of the billing cycle, may result in the
suspension/cancellation of charge privileges until such time all reconciliation requirements have been
completed.
Monthly Billing Statement
Each Cardholder will have access to their monthly billing statement via Manage Your Card Account at
www.americanexpress.com/checkvourbill, 48 hours afier the billing cycle ends.
. Attach all appropriate receipts, credit slips and/or invoices to your monthly billing statemento Note: Concur provides the capability of uploaded receipt images as an alternative to
maintaining hard copies. Document any missing receipts with the Missrng Receipt Affidavit Form on Concur
Statements with all attachments should be retained for seven (7) years along with associated
receipts. Alternatively, Concur can be used as a repository for P-Card receipt images in place of
maintaining hard copy receipts.
Approver Reconciliation Responsi bilities
It is the responsibility of the designated Approver (usually the supervisor/manager of the Cardholder)
to ensure that all purchases on the individual's statement are for appropriate and business purposes
only. Managers will be held accountable for any misuse that was not identified and reported to the P-
card Administrator.
Following are the steps for the monthly review and approval process:
Review all supporting transactions and receipts in Concur to ensure the charges and
documentation are valid
a
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. Approve transactions electronically via concur before monthly cycte cuto Ensure a brief description is included for each transaction in the "Comments' box or
description if the Cardholder has not done soo Managers should have access to cardholder receipts (hard copy or electronically in Concur)
when signing off on transactions in concur, comparing to monin[ statement. Disgrepancies must be investigated immediately and resolved in a timely manner to ensureSUEZ is not assessed a late fee for non-payment of a charge.
P-Card Payments
S.UEZ will submit paym_ent directly to American Express for alt P+ard charges. Under nocircumstances willthe Cardholder be permifted to make a direct payment to American Express.
Business Ethics and Employee Obligations
purlng any involveme{ (f1ecJ9r indirect) with vendors, the Cardholde/s only legitimate interest mustbe the best interest of SUEZ. You m.ust not give or even appear to give a preiere-nce to anyone at theexpense of the Company. The vendors are, in a sense, your business partners. !n line witir theseprinciples, employees must also comply with SUEZ North Ameica's Efhics poticy, Conflict of tnterestPolicy and Gift Policy.
!f any employee suspects P-card fraud or abuse, the emptoyee should report the fraud or p-card
abuse to their supervisor, who in turn, should contact the P-card Adminisirator and the EthicsCommittee (via the SUEZ NA Ethics Hotline a|877-3844277 or [e-mail]).
Failure to Gomply with Procedures and Guidelines
Any clear infraction of prevailing business ethics, misuse or nonrompliance with the procedures
contained in the SUEZ P-card Procedure Manual, Ethics Policy, Conflict of lnterest policy and GiftPolicy, or failure to comply with any of the responsibitities set forth in this Policy, may result inpermanent revocation of the P-card. ln addition, the Cardholder may be subjeit to disciplinary action,which may Inglude, depending on the seriousness of the offense, reprimand, probation, susplnsion,or dismissal. The Company also reseryes the right to seek recovery from the bardholder for anyunauthorized or personal use of the P-card.
General Roles and Responsibilities
The Cardholder, as an authorized purchaser for SUEZ, must adhere to the Company's principles ofethics, integrity and tran-sparenc_y !1!he purchasing process. Al! Cardholders are reiuirea to complywith the obligations set forth in SUEZ Group's Ethics Charterand Practical Guide 20'15: ethics in' '
commercial rclations.
Employeeo Read and understand the P-card Policy, Terms & Conditions.o Submit legal or employee conforming name changes to the P-card Administratoro Adhere to policies & procedures when making purchases.o Utilize preferred suppliers whenever possible.o Be accountable for all purchases and appropriate use of company funds.o Ensure orders are complete when receiving goods & services.
Page
o Retain/upload itemized receipts for ALL transactions.o Work with tfre supplier to resolve any issues and/or discrepancies concerning an order.
o Be responsible for the safeguarding and safekeeping of the P+ard number at all times.
o Contact the P+ard Administrator to cancel a P-card that is no longer required.
o Complete introductory and annual recurring P-Card training
Manager. Aplrove new Cardholder applications for employees that meet the requirements outlined in
this policy.o Accept ownership and responsibility for card use by all his/her employees'
. Ensuie that all Cardholders in their department use the P-card according to the guidelines
described in this PolicY.. Notify the P-card Admlnistrator of active Cardholder(s) changing roles or leaving the
Comiany so that the employee's card(s) in the programwill be reviewed or cancelled
immeOiaiety. For employeei baving the company, the Manager should then destroy the P-
card immediatelY.o Timely review and approval of P-Card transaction accuracy. Completeannualtraining
P-card Administrator. Ensure Cardholders have met the eligibility requirements and completed program pre-
requisites.o Manage Cardholder communications and support training requirements'o Ensure all card transactions are reconciled by the due date.o Review and audit P-card transactions for reasonableness, misuse, and/or abuse.
o Manage controls and restrictions including monitoring spending limits and updating category
restrictions.. Coordinate Cardholder enrollment, termination, and changes.o Manage all P+ard suspensions and terminations.. Collaborate with lnternal Control and Finance to develop, implement, enforce, and measure
effectiveness of program controls.. Collaborate with Sourcing to evaluate spend categories and suppliers approved for the P-
card program.o Conduct an annual review and, if necessary, update the P-card policy and distribution to
Cardholders, Managers and Finance'
Accounts Payableo lssue payment to the P+ard provider
Procurement. Review requests to modify category restrictions to the P+ard program.
. Responsible for working with P-card Administrator on the strategic development of the P-card
program.
Amendments to P-Card PolicY
This policy may be modified or updated from time to time. A new version of the policy will.be
prUliItr"A'in.oiporating such modifications or updates, as approved by Procurement and Legal, or as
recommended by SUEZ GrouP.
Appendix A - Blocked/Restricted Merchant
Gategory Codes (MCG) for P-Card program
Blocked Categories
Furriers and Fur Shops
Securities Brokers and Dealers
Beauty and Barber Shops
Funeral Services and Crematories
Counseling Services, Mariage and Personal
Pawn Shops
Dating and Escort Services
Massage Parlors
Betting, Lottery, Casino, Gambling
Bail and Bail Bond Payments
Jewelry, Precious Stones, Metals and Watches
Political Organizations
Religious Organizations
Restricted Categories
Court Costs, Fines, Fees, Child Support
Electronic Stores
11 ol 11
SUEZ WATER IDAHO INC.
CASE SUZ.W.2O.O2
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness:J. Cary
REQUEST NO. 118:
please provide justification, including why no adjustments are needed forthe Unadjusted
Operating and Maintenance Expenses not included in test year adjustment amounts,
such as adjustments 14, 15, 16, and 18.
RESPONSE NO.118:
All major cost categories which had material & known changes from test year amounts
had adjustments. The unadjusted operating & maintenance expenses for the June 2020
test year totaled $1.4M. The costs that were unadjusted include relatively minor and
stable expenses. They include other subcontractor expenses such as legal costs,
temporary help, support and license fees, office expenses include predominantly
telephone and communications costs, office supply costs such as copier rental,
miscellaneous expenses which predominantly cover a set-fee landscaping contract and
snow removal costs, insurance reserves and bad debt reserves, other employee
benefits, expired amortization accounts with zero activity in the test year, routine banking
fees, and janitorial and office maintenance costs'
The historical costs in recent years were similar amounts of expense levels' With no
major changes occurring or anticipated, no adjustments to these test year amounts were
requested.
suz-w-20-02
IPUC DR 118
Page 1 of 1
Preparer/Spo nsoring Witness J. Cary
REQUEST NO. 119:
Please provide the transaction detail reports for the following FERC accounts, in Excel
format with formulas intact:
a. 50650 - lnclude allsub accounts - Office Expense;
b. 506s5 - lnclude all sub accounts - Miscellaneous Expense;
c. 91860 - lnclude all sub accounts _ OtherAwards;
d. 92300930 Bank charges-A&G ops Miscellaneous General;
e. 92600920 other G&A Exp-A&G ops pension & Benefit;
f. 92600930 System Water Use-A&G; and
g. 92600932 Other G&A Exp-A&G Maintenance plant.
RESPONSE NO. 119:
Please see the attachment to this response for general ledger journal entries andpurchasing card/employee expense report details (designated as EXACC journal
entries) for the requested unadjusted operating and maintenance account amounts for
test year ending June 2020.
suz-w-20-02
IPUC DR 1 19
Page 1 of 1
SUEZ WATER IDAHO INC.
CASE SUZ-W-20-02
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
CASE NO. SIJZ-W-20.02
Response No. 119 Attachment
Excel Spreadsheet Provided Separately
in Native Format
Preparer/Sponsoring Witness: J. Cary
REQUEST NO.12O:
In reference to Production Request No. 14, please provide the cosUbenefit analysis and
identify allbenefits ldaho ratepayers receive from hiring Red Sky lnc. and Donahoe Pace
& Partners LTD.
RESPONSE NO- 120:
Donahoe Pace & Partners Ieverages their deep roots in the Treasure Valley media to
get the best placement and coverage for our public outreach dollars.
Annually, SUEZ runs several critical public information campaigns that keep customers
informed, safe, and healthy. Those campaigns include television advertising, print and
online newspaper ads, radio spots, and online banner ads. SUEZ reaches a wide range
of customers across our service area on topics such as:
. Annualflushingadvisories. The Consumer Confidence Report. Backflow preventiono Water conservationo Winterization
These are regular touchpoints for customers, reminding them about common issues,
providing helpful tip, and a way to get in touch with us. Donahoe Pace helps us reach
the most customers possible.
Red Sky provides messaging and media support, helping SUEZ provide critical
information to the public in a digestible form. They assist with press releases, information
campaigns including this rate case, and use their public relations expertise to ensure our
message is received as intended.
Red Sky is staffed by local PR and former journalists. ln a world increasingly dominated
by the Z4-hour news cycle and social media, SUEZ requires support to help ensure we
are as effective as possible in our communications with our community. Red Sky helped
SUEZ create messaging and materials for our outreach to the East First Bench regarding
intermittent discolored water events. Their support included planning a webinar, town
hallmeetings, newsletters, socialmedia outreach, and media management. While SUEZ
engineers and crews worked to provide short and Iong-term solutions, customer
communication was a critica! component. Reassuring customers their water is safe, that
suz-w-20-02
IPUC DR 120
Page 1 of2
SUEZ WATER IDAHO INC.
CASE SUZ-W-20-02
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
we have heard their concerns, and are actively addressing the issue resulted in fewer
complaint calls to our service center, and intangibly, less frustration on social media.
Our partnerships with Red Sky and Donahoe Pace provide much needed expertise
without hiring additionalful!-time staff. We could not hire an employee to capably handle
one of those skill sets for less than what we spend on Red Sky or Pace Donahue
annually. We see this as a cost savings for our customers.
ln summary:o Red Sky provides a one-stop shop with experts in social media, editing, writing,
advertising content, graphic design, public relations, and media training and
support.
a Donahoe Pace offers decades of relationships with the media outlets in the Valley
and analysis of page views, impressions, and customer reactions. Their cost
includes not only the cost of running advertisements with the media outlet, but
their expertise in negotiating with the media outlets to get SUEZ the most for our
money.
suz-w-20-02
IPUC DR 120
Page 2 of 2
Prepa rer/Sponsoring Witness:C. Cooper
REQUEST NO.122:
Please provide a detailed Iist of all assets retired, gross salvage value, and the cost to
remove for years 2004 through end of 2019, for the following accounts . Please provide
the response in excel format with formulas intact.
a. 303 Land, Land Rights & Water Rights;
b. 304 Structures and Improvements;
c. 307 Wells and Springs;
d. 311 Pumping Equipment;
e. 320 Purification Systems;
f . 331 Transmission and Distribution Mains.
g. 333 Services;
h. 334 Meters; and
i. 346 Communication Equipment.
RESPONSE NO.122:
Please see Attachment 1 to this response showing the asset retirements from 2004
through 2019 and Attachment 2 showing the gross salvage value and the cost to remove
for the same period. ln 2004, the Company had a data conversion between different
fixed assets software modules and therefore has Asset Retirements by plant account
only.
suz-w-20-02
IPUC DR 122
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
CASE NO. SIJZ.W'20.02
Response No . 122
Attachment 1
Excel Spreadsheet Provided Separately
in Native Format
CASE NO. SIJZ-W-20.02
Response No. I22
Affachment 2
Excel Spreadsheet Provided Separately
in Native Format