20200505Suez Water Comments.pdf

SUEZ WATER IDAHO INC.’S COMMENTS - 1
Michael C. Creamer (ISB No. 4030)
Preston N. Carter (ISB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
15109606_5.docx [30.171]

Attorneys for SUEZ Water Idaho Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF DEFERRED
ACCOUNTING OF INCREMENTAL
COSTS ASSOCIATED WITH THE
COVID-19 PUBLIC HEALTH
EMERGENCY

Case No. GNR-U-20-03 (including
Consolidated Case Nos. AVU-E-20-03;
AVU-G-20-03; FLS-W-20-02; GSW-
W-20-01; IPC-E-20-19; and PAC-E-
20-04)

SUEZ WATER IDAHO INC.’S COMMENTS

Pursuant to Order No. 34643, SUEZ Water Idaho Inc. (“SUEZ”) submits the following
comments regarding Case No. GNR-U-20-03:
1. SUEZ is a regulated water utility in Idaho subject to the jurisdiction of the Idaho
Public Utilities Commission.
2. Like the other utilities already participating in Case No. GNR-U-20-30, SUEZ
anticipates increased expenses resulting from the COVID-19 emergency, which may include bad
debt expenses, waived fees, and other costs and expenses that cannot be predicted with accuracy
at this time.
3. The applications consolidated by Order No. 34643 request authorization to
account for unanticipated, COVID-19-related expenses by booking them as regulatory assets for
possible recovery through rates that would be set in future proceedings. The requested deferrals
RECEIVED
2020 May 5,PM2:14
IDAHO PUBLIC
UTILITIES COMMISSION
SUEZ WATER IDAHO INC.’S COMMENTS - 2
do not seek to increase rates at this time. Order No. 34643 further provides that any utility that
“submit[s] timely comments in the case requesting deferred accounting treatment [will] be
eligible for any deferred accounting treatment authorized by the final order in this case.” Order
No. 34643 at 2. The Order also specifies that such comments must be submitted within 21 days
of its service date, which is April 23, 2020. Id. at 3.
4. SUEZ hereby respectfully requests that Emergency-related deferred accounting
authority for SUEZ be decided in the generic case and it be allowed to defer accounting
treatment of COVID-19 related expenses consistent with any final order in this case.
5. SUEZ understands that the case will proceed by modified procedure unless the
Commission orders otherwise, and stands ready for the case to proceed as ordered.
6. Please direct all communications and service of pleadings in this matter to:
Michael C. Creamer
Preston N. Carter
Givens Pursley, LLP
601 W. Bannock
Boise, ID 83702
[e-mail]
[e-mail]
[e-mail]

and

Mr. Marshall Thompson
SUEZ Water Idaho Inc.
8284 West Victory Rd.
Boise, ID 83709
[e-mail]

SUEZ WATER IDAHO INC.’S COMMENTS - 3
DATED: May 5, 2020.
GIVENS PURSLEY LLP

Michael C. Creamer
Preston N. Carter
Givens Pursley LLP
Attorneys for SUEZ Water Idaho Inc.

SUEZ WATER IDAHO INC.’S COMMENTS - 4
CERTIFICATE OF SERVICE

I certify that on May 5, 2020, a true and correct copy of SUEZ WATER IDAHO INC.’S
COMMENTS was served upon all parties of record in this proceeding via the manner indicated
below:

Commission Staff Electronic Mail
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, ID 83714
[e-mail]
[e-mail]

Parties Electronic Mail
Avista Utilities
David J. Meyer
P.O. Box 3727
1411 E. Mission Ave., MSC 13
Spokane, WA 99220-3727
[e-mail]
Avista Utilities
Patrick Ehrbar
P.O. Box 3727
1411 E. Mission Ave., MSC 13
Spokane, WA 99220-3727
[e-mail]

Falls Water Company
Preston N. Carter
601 W. Bannock St.
Boise, ID 83702
[e-mail]
[e-mail]
Gem State Water Company
Preston N. Carter
601 W. Bannock St.
Boise, ID 83702
[e-mail]
[e-mail]

Eric W. Nelsen
NW Natural
220 NW 2nd Ave.
Portland, OR 97209
[e-mail]
Eric W. Nelsen
NW Natural
220 NW 2nd Ave.
Portland, OR 97209
[e-mail]

Idaho Power Company
Lisa D. Nordstrom
Matt Larkin
1221 W. Idaho Street
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
Rocky Mountain Power
Ted Weston
1407 W. North Temple, Suite 330
Salt Lake City, UT 84116
[e-mail]
[e-mail]
[e-mail]
[e-mail]

SUEZ WATER IDAHO INC.’S COMMENTS - 5
Rocky Mountain Power
Data Request Response Center
825 NE Multnomah St., Suite 2000
Portland, OR 97232
[e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, ID 83702
[e-mail]

Industrial Customers of Idaho Power
Dr. Don Rading
6070 Hill Road
Boise, ID 83703
[e-mail]
Monsanto Company
Randall C. Budge
Thomas J. Budge
Racine Olson, PLLP
P.O. Box 1391
Pocatello, ID 83204-1391
[e-mail]
[e-mail]

Monsanto Company
Brian C. Collins
Maurice Brubaker
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
[e-mail]
[e-mail]

Idaho Conservation League
Benjamin J. Otto
710 N. 6th Street
Boise, ID 8702
[e-mail]

Preston N. Carter