PENNSYLVANIA · Web viewGovernor Thomas Wingett Corbett signed into law Act 11 of 2012 (Act 11),...

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PENNSYLVANIA PUBLIC UTILITY COMMISSION Harrisburg, PA 17105-3265 Public Meeting held June 14, 2017 Commissioners Present: Gladys M. Brown, Chairman Andrew G. Place, Vice Chairman John F. Coleman, Jr. Robert F. Powelson David W. Sweet Petition of Suez Water Pennsylvania Inc. for Approval of its Long-Term Infrastructure Improvement Plan P-2017-2589724 OPINION AND ORDER BY THE COMMISSION: Before the Commission for consideration is the Petition of Suez Water Pennsylvania Inc. (Suez) for approval of its Long-Term Infrastructure Improvement Plan (LTIIP). The Commission required all water utilities that have implemented a Distribution System Improvement Charge (DSIC)

Transcript of PENNSYLVANIA · Web viewGovernor Thomas Wingett Corbett signed into law Act 11 of 2012 (Act 11),...

Page 1: PENNSYLVANIA · Web viewGovernor Thomas Wingett Corbett signed into law Act 11 of 2012 (Act 11), which amends Chapters 3, 13 and 33 of Title 66. Act 11, inter alia, provides utilities

PENNSYLVANIAPUBLIC UTILITY COMMISSION

Harrisburg, PA 17105-3265

Public Meeting held June 14, 2017

Commissioners Present:

Gladys M. Brown, ChairmanAndrew G. Place, Vice ChairmanJohn F. Coleman, Jr.Robert F. PowelsonDavid W. Sweet

Petition of Suez Water Pennsylvania Inc.for Approval of its Long-Term Infrastructure Improvement Plan

P-2017-2589724

OPINION AND ORDER

BY THE COMMISSION:

Before the Commission for consideration is the Petition of Suez Water

Pennsylvania Inc. (Suez) for approval of its Long-Term Infrastructure Improvement Plan

(LTIIP). The Commission required all water utilities that have implemented a

Distribution System Improvement Charge (DSIC) pursuant to the repealed 66 Pa.

C.S. § 1307(g) to file a LTIIP by March 20, 2017.1 The Commission established a filing

schedule for the required LTIIPs via a Secretarial Letter dated October 31, 2016, and

directed Suez to file a its LTIIP on February 20, 2017.2

1 See Supplemental Implementation Order of Act 11 of 2012, entered September 21, 2016, at Docket No. M-2012-2293611.2 Docket No. M-2012-2293611.

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Suez filed its LTIIP on February 17, 2017. Copies of the LTIIP were

served on the statutory advocates and parties of record from Suez’s last base rate

proceeding. Suez filed a letter on March 20, 2017, noting a typographical error regarding

the number of services to be replaced per year.

On March 20, 2017, the Office of Consumer Advocate (OCA) filed

comments on Suez’s LTIIP. The OCA did not request hearings, but suggested Suez

provide additional information to the Commission to ensure Suez’s LTIIP accelerated

infrastructure repair and replacement in a cost effective manner as required by Act 11.

The OCA also requested the Commission reaffirm in this Order that inclusion of property

in the LTIIP is not dispositive of whether the costs of that project will be afforded DSIC

recovery. The Commission, as noted below, requested additional information from Suez

that addressed most of the concerns raised by the OCA. As to the request for

reaffirmation, this is unnecessary as the Commission has made itself clear on the matter.3

On April 12, 2017, via a Secretarial Letter, the Commission issued a

request to Suez for more details regarding Suez’s historical baseline infrastructure

replacement and capital spending for the categories of eligible property in the LTIIP. In

addition, the Commission noted more information was needed to determine the cost-

effectiveness of the LTIIP as required per 52 Pa. Code § 121.4(e).

On April 24, 2017, Suez filed a response to the data request.

BACKGROUND

On February 14, 2012, Governor Thomas Wingett Corbett signed into law

Act 11 of 2012 (Act 11),4 which amends Chapters 3, 13 and 33 of Title 66. Act 11, inter

3 See Petition of Duquesne Light Company for Approval of a Distribution System Improvement Charge, pg. 23, Order entered September 15, 2016, at Docket No. P-2016-2540046. 4 http://www.legis.state.pa.us/WU01/LI/LI/US/HTM/2012/0/0011..HTM

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alia, provides utilities with the ability to implement a Distribution System Improvement

Charge (DSIC) to recover reasonable and prudent costs incurred to repair improve or

replace certain eligible distribution property that is part of the utility’s distribution

system. The eligible property for the utilities is defined in 66 Pa. C.S. §1351. Act 11

states that as a precondition to the implementation of a DSIC, a utility must file an LTIIP

with the Commission that is consistent with 66 Pa. C.S. §1352. The Commission’s LTIIP

Regulations are codified at 52 Pa. Code Chapter 121.

On April 5, 2012, the Commission held a working group meeting for

discussion and feedback from stakeholders regarding its implementation of Act 11. On

May 10, 2012, the Commission issued a Tentative Implementation Order addressing and

incorporating input from the stakeholder meeting. Stakeholders filed comments to the

Tentative Implementation Order on June 6, 2012. On August 2, 2012, the Commission

issued the Final Implementation Order via Docket No. M-2012-2293611 which

established Act 11 implementation procedures and guidelines.

The Final Implementation Order adopts the requirements established in 66

Pa. C.S. § 1352, provides additional standards that each LTIIP must meet, and gives

guidance to utilities for meeting the Commission’s standards. The Final Implementation

Order of Act 11 requires the inclusion of eight elements in the LTIIP.

SUEZ’s LTIIP PETITION

Suez is a corporation organized and existing under the laws of the

Commonwealth of Pennsylvania and is a wholly-owned subsidiary of Suez Water North

America Inc. Suez is a public utility as defined by the Pennsylvania Public Utility Code,

66 Pa. C.S. § 102, and is subject to the regulatory jurisdiction of the Commission.

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Suez owns and operates water treatment plants, wells, storage facilities, and

water distribution and transmission systems throughout Pennsylvania. Suez serves

approximately 60,000 customers in eight counties. Suez’s distribution system is made up

of approximately 881 miles of main, 12,200 main line valves, 3,352 fire hydrants,

60,325 service lines, and 60,109 meters. Suez has four operating areas, the largest of

which is Harrisburg/Newberry, which serves 64% of the Company's customer base.

Suez’s Mechanicsburg system provides service to 22% of customers, and the Bloomsburg

and Dallas systems in northeast Pennsylvania serve the remaining 14%.

Suez’s LTIIP is a five year plan, spanning the years 2017 through 2021 and

its Petition addressed the eight LTIIP elements required in the Final Implementation

order of Act 11 as discussed below:

(1) TYPES AND AGE OF ELIGIBLE PROPERTY

Suez Position

Suez’s LTIIP includes only distribution plant that is DSIC-eligible. Suez

has been replacing and repairing DSIC-eligible property since it received approval to

charge a DSIC in an Order entered March 2, 1998, at Docket No. R-00984265. The

DSIC-eligible property includes mains and appurtenances, services, fire hydrants, and

meters.

Suez's distribution system is made up of approximately 881.74 miles of

main ranging in size from less than 2 inches up to 24 inches in diameter. Pipe material

varies from cast iron, asbestos cement (AC), ductile iron, and polyvinyl chloride (PVC).

Galvanized pipe, glued plastic, polyethylene (PE), steel, and wrought iron are other

materials included in Suez’s distribution system. The age of the mains in Suez’s system

range from new to 100 years old with the average age of the mains being 33 years old.

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Suez provided a detailed breakdown of its main materials, ages, and diameters in the

LTIIP.

Suez states that since the 1980's, they have been installing both ductile iron

and PVC pipe that represent 49.2% of the total mains. Recently Suez has shifted to

ductile iron as its primary choice, particularly when: high pressure is encountered; mains

are installed in state highways; or any stream crossings or critical intersections are

involved.

Suez avers that the valves in its system consist of main line valves, hydrant

valves, fire line valves, and pressure-reducing valves. Suez’s LTIIP provided detail on

the number and types of its valves. Suez states it replaces valves under one of the

following conditions: as a part of Suez's main replacement program; or, a valve identified

as needing replaced as a part of Suez's valve maintenance program. Suez avers that the

12,200 main line valves are exercised and inspected via Suez's valve maintenance

program. Currently, Suez is in the process of utilizing its hydraulic models to perform a

valve analysis that will identify which valves are critical and should be inspected on a

more frequent basis and potentially replaced. Suez states it has 25 pressure reducing

valves that ensure proper pressures are maintained in areas that experience high pressure.

Suez’s service lines extend from the main to the curb stop located at the

customer's property line. The customer-owned service line extends from the curb stop to

the meter. Suez’s services consist of copper, plastic, and galvanized material. Suez

states they do not have any inventoried lead services but it plans to file a petition with the

Commission in 2017 to seek recovery of the cost to replace a customer's lead service line

when encountered. Suez’s policy is to replace and not repair Company-owned service

lines as a part of its main replacement program or as a part of its non-revenue water

(NRW) reduction program. In supplemental information filed with the Commission,

Suez avers that it currently does not have any costs included in the LTIIP for replacement

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of customer-owned lead service lines.

Suez states that although 28,068 services are constructed with unknown

material, it has interviewed long-term field employees to determine their experience in

encountering lead services. Suez avers its field employees have indicated that, while they

on occasion encounter lead goose necks, they have not come across any lead services.

Goose necks are a type of connector between the main and the company-owned service

section. Suez states its policy is to replace any lead goose necks when encountered.

Suez states it has 3,352 fire hydrants in its system and they are replaced

under one of the following conditions: as a part of the Suez's main replacement program;

when a fire hydrant is made inoperable due to being struck by a vehicle; relocation of a

hydrant from a smaller diameter main to a larger diameter main so as to improve fire

flow; or, a hydrant identified as needing replaced as a part of the Suez's hydrant

maintenance. Suez states hydrants located throughout the system are inspected and

exercised at least once per year during the Suez's flushing program. Suez utilizes

hydraulic models to identify hydrants that could be relocated to an adjacent larger main

which would improve fire flows.

Suez states it has initiated an aggressive meter replacement program.

Suez’s program is designed to ensure that the meters are in compliance with Commission

regulations on testing as well as replacing meters due to age. Radio frequency end points

are also installed on all meters as part of the program. Suez states that in addition to

reducing meter reading time from the equivalent of eight full-time employees to the

equivalent of one-full time employee, the replacement program allows Suez to focus

more on preventative maintenance, customer service, and NRW efforts. Suez notes it has

installed smart meters on its top 50 customers as well as another 100 strategic accounts.

This enables Suez to track their water usage daily utilizing a program called Water

Scope.

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Comments

The OCA recommended that Suez clarify that no dollars are included for

customer-owned lead service line replacement in the LTIIP period or quantify the amount

by year and by operating area.

Resolution

Upon review of Suez’s LTIIP and all supplemental information filed, the

Commission finds the types and ages of eligible property requirements of element one of

the Final Implementation Order have been fulfilled.

(2) SCHEDULE FOR PLANNED REPAIR AND REPLACEMENT OF ELIGIBLE PROPERTY

Suez Position

Suez states it prepares a five-year strategic capital plan which includes all

DSIC-eligible properties. The budgets are based on “blanket” approvals but include

specific project categories and include the following DSIC-eligible property projects:

Replacement Fire Hydrants – Suez States that replacement of fire hydrants are

not included as part of the main replacement projects. Suez budgets hydrant

replacements utilizing historical trends and any known new initiatives, based

on their performance characteristics, main break frequency rates, and expected

service level unless there are other overriding factors such as structural, water

quality or capacity concerns.

Replacement Short Main and Valves – Suez states this project category is for

the replacement of valves and capitalized main breaks. While historical trends

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are used, there has been an increase from the past in this category due to Suez’s

increased NRW efforts in locating leaks as well as the cost of repairs due to

increased restoration costs required by the local municipalities.

Replacement Services – Suez states this project category is for the replacement

of services not included as a part of the main replacement projects. Suez's

policy is to replace the company-owned service in its entirety as opposed to

repairing a service leak. Suez states that because of a more-aggressive NRW

initiative, there has been an increase in this project category as compared to the

past years.

Replacement Fire Services – Suez states this project category is for the

replacement of fire services not included as a part of the main replacement

projects. The Suez avers it has initiated an aggressive fire line survey of its

unmetered fire services and, if unauthorized use is occurring, Suez is requiring

the customer to retrofit the fire line with a meter.

Replacement Meters – Suez states this project category is for the replacement

of aged, damaged and stopped meters as well as meter pits (moving the meter

from inside the house into a meter pit) installed as a part of the main

replacement projects.

Main Replacements – Suez states this project category is for the replacement of

DSIC-eligible mains. Suez evaluates current assets to arrive at a detailed list of

projects which in turn are rolled into a single-number budgetary number. Suez

avers that in the past, a scoring system was used to determine what mains

should be replaced. Suez states it will be transitioning to a computer software

program called "Infomaster," as well as its hydraulic model, to determine

which mains are high priority mains for replacement. In supplemental

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information filed with the Commission, Suez averred that they are still in the

process of implementing Infomaster and expects it to be completed and in use

by the third quarter of this year. Suez is currently compiling the necessary GIS

and hydraulic model data which is required input for Infomaster.

Highway Projects - Suez states that this project category is difficult to budget

as it depends heavily on PennDOT and local municipality projects. Suez meets

with representatives of these agencies to formulate a more-accurate plan. Suez

states by the end of the first or second quarter of each year, it knows what

highway projects are going forward for that given year.

New Mains – Suez states this project category is for the installation of mains to

eliminate dead-ends.

Comments

No comments were received regarding the schedule for planned repair and

replacement of eligible property.

Resolution

Upon review of Suez’s LTIIP and all supplemental information filed, the

Commission finds the schedule for planned repair and replacement of eligible property

requirements of the Final Implementation Order has been fulfilled.

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(3) LOCATION OF THE ELIGIBLE PROPERTY

Suez Position

Suez states that the DSIC-eligible property is located throughout its four

operational areas: Harrisburg; Mechanicsburg; Bloomsburg; and Dallas. Suez avers

assets are tracked via its GIS system, which is constantly being updated with better data

and the location of facilities. Suez states field employees are equipped with a GPS unit

linked to a smart tablet which allows them to locate facilities on a continuous basis and

upload data to the GIS system.

Comments

No comments were received regarding the locations of the eligible property.

Resolution

Upon review of the Suez LTIIP and all supplemental information filed, the

Commission finds the location of eligible property requirements of the Final

Implementation Order has been fulfilled.

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(4) REASONABLE ESTIMATES OF THE QUANTITY OF PROPERTY TO BE IMPROVEDAnd,

(5) PROJECTED ANNUAL EXPENDITURES AND MEASURES TO ENSURE

THE PLAN IS COST EFFECTIVE

Suez Position

Tables 1 and 2, below, detail the projected quantities of DSIC-eligible

property to be improved and/or replaced during the LTIIP period. Suez notes that for

valves, services and hydrants, the number of units retired depend largely on the main

replacement program.

Table 1: Projected LTIIP Services, Valves, Hydrants and Meters

Year Services Valves Hydrants Meters

2017 1,250 250 100 3,2502018 1,250 250 100 3,2502019 1,250 250 100 3,2502020 1,250 250 100 3,2502021 1,250 250 100 3,250Total 6,250 1,250 500 16,250

Table 2: Estimated Miles of LTIIP Main Replacement 2017 Through 2021

Year New Mains

Main Replacements

Highway Projects

Total

Miles

2017 0.9 11.9 1.8 14.62018 1 12 2 152019 1 12 2 152020 1 12 2 152021 1 12 2 15Total 4.9 59.9 9.8 74.6

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Table 3, below details the proposed expenditures by project title for each

year of the LTIIP.

Table 3 – LTIIP Expenditures for 2017 Through 2021 (in $1,000s)

PROJECT ID PROJECT TITLE 2017 2018 2019 2020 2021

CYYD502_002Replacement

Short Mains & Valves — DSIC

$750 $750 $750 $750 $750

CYYD501_002Replacement

Fire Hydrants - DSIC

$45 $45 $45 $45 $45

CYYD700_002 Highway Main Projects DSIC $1,500 $1,500 $1,500 $1,500 $1,500

CYYD100_002 New Mains — DSIC $1,000 $1,000 $1,000 $1,000 $1,000

CYYD600_002Replacement

Main Projects - DSIC

$11,000 $11,000 $11,000 $11,000 $11,000

CYYF501_002

Replacement Domestic

Services — DSIC

$470 $470 $470 $470 $470

CYYD902_002

Pressure Management Facilities —

DSIC

$375 $375

CYYF503_002Replacement

Fire Services - DSIC

$35 $35 $35 $35 $35

CYYG501_002Replacement

Customer Meters -DSIC

$800 $800 $800 $800 $800

TOTAL NET DSIC $15,975 $15,975 $15,600 $15,600 $15,600

TOTAL NET BUDGET $22,923 $26,740 $31,474 $25,563 S 21,154

PERCENT DSIC 70% 60% 50% 61% 74%

Suez states it continues to implement a continuous improvement process to

ensure that capital expenditures are being deployed in a prudent and cost-effective

manner consistent with the requirements of the Public Utility Code. Suez provided

several examples of how it is improving its processes.

Suez states it has over 200 miles of AC and transite (TR) main and is in the

process of hiring a firm to analyze the condition and to determine the remaining life of

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the pipe. This will help Suez in the prioritization of AC main replacement which is

critical since AC main has a shorter life cycle than other main material such as ductile

iron, cast iron, etc.

Suez states it has access to its parent Company's research and technical

resources and that it is continually evaluating which services are best to be performed

internally and which are best to be outsourced. Suez states flagging and traffic control is

mostly outsourced to Flagger Force, a company that specializes in traffic control. In

addition, Suez outsources the inspection of water mains to engineering firms and its

hydraulic modeling which is utilized for design as well as prioritizing infrastructure

replacement.

Suez notes it prioritizes succession planning and hiring practices and that

hiring employees with the right skills is critical in ensuring efficient deployment of

capital dollars. Suez also notes its bidding process utilizes a list of pre-qualified

contractors that is evaluated and updated annually. Suez states it evaluates those

infrastructure projects could be done internally and those projects that could be bid on an

individual basis. Suez may also bundle projects for bidding if it creates efficiencies.

Suez avers that materials such as pipes, meters, hydrants, valves, etc. are

bid annually by Suez's Corporate Procurement Department. This provides better pricing

than could obtained locally, or as a stand-alone company. Suez has a Commission-

approved master services affiliated interest agreement in place for such services.

Comments

No comments were received regarding the reasonable estimates of the

quantity of property to be improved and the projected annual expenditures and measures

to ensure that the plan is cost effective.

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Resolution

Upon review of the Suez LTIIP and supplemental information filed, the

Commission finds the reasonable estimates of the quantity of property to be improved

and the projected annual expenditures and measures to ensure that the plan is cost

effective, requirements of elements of the Final Implementation Order of Act 11 have

been fulfilled.

(6) ACCELERATED REPLACEMENT AND MAINTAINING SAFE AND RELIABLE SERVICE

Suez Position

Suez notes in the past ten years it has replaced a total of 46 miles of main.

This represents 5.6 % of its mains and is equivalent to a 180-year replacement cycle.

Including the LTIIP, Suez has accelerated its ten-year average replacement slightly to a

6.6 % rate, which is equivalent to a 160-year replacement cycle. Table 5, below, details

Suez's historic main replacement rate.

Table 4 – History Miles of Main Replaced

Period Years Total Average

10 Year 2007 -2016 46.28 4.63

5 Year 2012 -2016 23.17 4.63

3 year 2014-2016 14.60 4.87

2 Year 2015-2016 10.84 5.42

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Suez states that the average age of its mains is only 37 years.

Approximately 30% of Suez’s 881 miles of main is greater than 50 years old and 40% is

less than 30 years old. Over 50% of Suez’s main is ductile iron or PVC Pipe.

Suez's focus for the next five years in regards to its accelerated main

replacement program concerns galvanized pipe, glued plastic pipe in its Newberry

operation, and AC pipe. Suez avers that its five-year plan proposes to replace both the

entire 19 miles of Galvanized main and the 10 miles of glued plastic pipe. This

represents an average replacement rate of six miles per year for those mains. Suez states

that remaining replacements will focus on AC pipe and unlined cast iron, as well as

mains required to be replaced due to highway projects.

Suez states in 2016, its main breaks per mile of main was only 0.192 (169

main breaks). This is down from the 2015 rate of 0.237 (209 main breaks) and the 2014

rate of 0.243 (214 main breaks). In addition, Suez avers that because of its NRW

program, it has reduced its NRW consistently over the past five years. Suez notes that in

the past five years it has been able to reduce its NRW by 16.9%, which is equivalent to

580 million gallons per year, or 1.59 million gallons per day.

Tables 5 and 6, below, detail the actual expenditures and materials replaced

or improved over the previous 10 years under Suez’s DSIC program. As can be seen

when compared to Tables 1 through 3, above, Suez’s LTIIP continues its increased level

of infrastructure replacement and expenditures.

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Table 5 – Main Replacement Projects by Year and by Operating Area from 2012 through 2016

Year

Bloomsburg Dallas Harrisburg Mechanicsburg Total

Cost Installed Cost Installed Cost Installed Cost Installed Cost Installed

$ x 1,000 Feet $ x

1,000 Feet $ x 1,000 Feet $ x

1,000 Feet $ x 1,000 Feet

2012 $370 2,195 $1,144 6,399 $2,183.1 13,598 $811.3 3,370 $4,508.1 25,5622013 $423 2,859 $626 4,550 $1,688.7 9,995 $313.4 2,305 $3,050.5 19,7092014 $434 5,704 $915 4,980 $1,607.0 6,212 $524.5 3,445 $3,480.1 20,3412015 $711 2,626 $1,404 9,090 $3,140.0 16,038 $465.2 1,830 $5,719.5 29,5842016 $ $1,390 6,063 $4,143.4 17,380 $929.3 6,891 $6,120.3 28,182Total $1,936 13,384 $5,479 31,082 $12,762 63,223 $3,044 17,841 $22,879 123,378

Table 6 – A Breakdown of Historic Utility Plant In-Service Additions by Year from 2007 through 2011

Account Year 2007 2008 2009 2010 2011

331.40Transmission and

Distribution Mains

$74,521,548 $80,516,469 $84,758,631 $90,555,977 $96,423,386

333.40 Services $20,520,158 $22,351,546 $23,623,517 $25,119,461 $26,647,527

334.40 Meters and Meter Installations $7,499,057 $7,985,998 $8,217,260 $8,920,613 $9,891,430

335.40 Hydrants $4,985,025 $5,253,191 $5,538,722 $5,764,035 $6,012,990

Total $107,525,788 $116,107,204 $122,138,130 $130,360,086 $138,975,333

Comments

The OCA suggested generally that Suez should provide additional

information regarding its historic rates of replacement and its proposed rate of

replacement for the LTIIP period.

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Resolution

Suez has demonstrated that the LTIIP expenditures are an acceleration of

historical spending in the eligible property categories outlined in the LTIIP projects areas.

Upon review of the Suez’s LTIIP and supplemental information filed, the Commission

finds the manner in which replacement of aging infrastructure will be accelerated and

how repair, improvement or replacement will maintain safe and reliable service

requirements of the Final Implementation Order have been fulfilled.

(7) WORKFORCE MANAGEMENT AND TRAINING PROGRAM

Suez Position

Suez states that it continually evaluates both its internal workforce and its

utilization of external contractors to ensure that it has in place a safe and efficient

workforce to complete its infrastructure replacement program. Suez avers that in 2016 it

utilized eight different contractors to replace mains in its four operational areas. Each

contactor must be prequalified, which requires evaluation of past performance, adherence

to company specifications, attendance at Suez's annual training and review of the

contractor's safety record.

Suez states it contracts out the inspection of its main replacements to

engineering firms that specialize in watermain installation. Suez has also outsourced

paving restoration and the majority of traffic control. Suez avers that outsourcing allows

Suez employees to focus more on Suez's core business of providing high quality water

service. Suez states its workforce primarily focuses on capitalized main breaks,

replacement of valves, services and hydrants under its annual programs, and the majority

of meter replacements.

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Suez states it has an Environmental, Health and Safety Manager. Suez

tracks both lagging and leading indicators to monitor the effectiveness of the safety

program. Suez avers that recordable accidents, lost time accidents and vehicle accidents

are measured and monitored daily via Suez’s Intelex software. Suez avers that all

accidents must be reported within one day and a review call depending on severity is

required anywhere within one day to twenty one days. Near misses or unsafe work

conditions are tracked and remedial measures are implemented as appropriate. Suez

states in 2015, 30 near misses and, in 2016, 43 near misses were reported.

Suez states it requires that all jobs require that a safe work plan be filled out

prior to the commencement of the work. Suez avers this is now paperless, as the report is

filled out on the employee's smart tablet, which allows for easier completion and allows

for better data retention.

Suez states that all employees are required to take the appropriate safety

training. Suez has a goal of eight hours of annual safety training per employee and bases

the hourly employee's year-end bonus on safety.

Comments

No comments were received regarding the workforce management and

training program.

Resolution

Upon review of the Suez LTIIP and supplemental information, the

Commission finds the workforce management and training program requirements of the

Final Implementation Order have been fulfilled.

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(8) A DESCRIPTION OF A UTILITY’S OUTREACH AND COORDINATION

ACTIVITIES WITH OTHER UTILITIES, PENNDOT AND LOCAL

GOVERNMENTS ON PLANNED MAINTENANCE/CONSTRUCTION

PROJECTS

Suez Position

Suez notes that it works with PennDOT, local municipalities, and other

utilities to accumulate information as to their intentions to undertake paving and other

public works within the budget year. Suez avers that, by working and communicating

with these entities, disruptions are minimized and ensure that infrastructure replacement

is efficient and cost-effective.

Suez avers that it maintains a list of PennDOT's proposed projects that is

used in gauging the magnitude of replacement work that is required for each project.

Suez states that while it may be aware of a project, there are times that it needs to begin

relocating its facilities within months of when PennDOT gives notice to Suez of its intent

to proceed.

Suez deals closely with municipal public works directors to understand

what work is being planned within a municipality's jurisdictional boundaries. Suez

evaluates paving projects to determine if replacement of Suez's facilities is warranted

based on their age and maintenance history. More-extensive projects require a different

evaluation and often require Suez to relocate its facilities as a result of the project. Suez

states the timing and notification of this work often does not always coincide with its

budget and work schedule and can prevent Suez from finalizing designs and scheduling

the work with contractors.

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Page 20: PENNSYLVANIA · Web viewGovernor Thomas Wingett Corbett signed into law Act 11 of 2012 (Act 11), which amends Chapters 3, 13 and 33 of Title 66. Act 11, inter alia, provides utilities

Suez utilizes Pennsylvania's One Call system during the initial phase of

project design and before the first dig. Suez states it recently purchased a Hydro

Excavator which allows Suez to locate other facilities utilizing a safer and more efficient

process.

Suez informs its customers about water disturbances by utilizing door-to-

door notifications, issuing press releases, posting SUEZ website banners, making social

media posts, and mailing informational letters notifying customers and communities

affected by the work.

Comments

No comments were received regarding the coordination activities.

Resolution

Upon review of the Suez’s LTIIP, the Commission finds the coordination

activities requirements of the Final Implementation Order have been fulfilled.

LTIIP SUMMARY

The Commission reviewed the eight required elements for Suez’s Petition

for Approval of its LTIIP and any resulting Petition comments. Suez’s proposed LTIIP

appears to demonstrate its associated expenditures are reasonable, cost effective, and

designed to ensure and maintain efficient, safe, adequate, reliable, and reasonable service

to its customers.

The Commission finds Suez’s Long-Term Infrastructure Improvement Plan

and manner in which it was filed conforms to the requirements of Act 11 and our Final

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Page 21: PENNSYLVANIA · Web viewGovernor Thomas Wingett Corbett signed into law Act 11 of 2012 (Act 11), which amends Chapters 3, 13 and 33 of Title 66. Act 11, inter alia, provides utilities

Implementation Order. The plan, as approved herein, is designed to maintain safe,

adequate and reliable service and, as such, Suez shall be required to comply with the

infrastructure replacement schedule and elements of that plan; THEREFORE,

IT IS ORDERED:

1. The Petition for Approval of Long-Term Infrastructure Improvement

Plan (LTIIP) filed by Suez Water Pennsylvania Inc. is approved, consistent with this

Order.

2. That the proceeding at Docket No. P-2017-2589724 be closed.

BY THE COMMISSION,

Rosemary ChiavettaSecretary

(SEAL)

ORDER ADOPTED: June 14, 2017

ORDER ENTERED: June 14, 2017

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