Aqua Pennsylvania, Inc. Index to Direct Testimony Ap
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AQUA PENNSYLVANIA, INC. INDEX TO DIRECT TESTIMONY AP Statement No. 1 William C. Packer AP Statement No. 2 Renee T. Marquis AP Statement No. 3 Erin M. Feeney AP Statement No. 4 Paul R. Moul AP Statement No. 5 Paul R. Herbert AP Statement No. 6 John J. Spanos AP Statement No. 7 William J. Jerdon AP Statement No. 8 Mark J. Bubel AP STATEMENT NO. 1 BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION AQUA PENNSYLVANIA, INC. DOCKET NO. R-2018-3003068 DIRECT TESTIMONY OF WILLIAM C. PACKER With Regard To The Company’s Need for Rate Relief, Overview of the Principal Accounting Exhibits Certain Expense Claims, Rate Base Claims, Rate Design, Proposed Capitalization Ratios, Return on Equity Considerations, And Various Other Matters August 17, 2018 TABLE OF CONTENTS I. INTRODUCTION AND PURPOSE OF TESTIMONY .................................................... 1 II. AQUA PA’S NEED FOR RATE RELIEF ......................................................................... 3 III. AQUA PA’S EFFORTS TO CONTROL OPERATING AND MAINTENANCE (“O&M”) EXPENSES ........................................................................................................ 9 IV. PRINCIPAL ACCOUNTING EXHIBIT ......................................................................... 10 V. OPERATING EXPENSES ............................................................................................... 13 VI. DEPRECIATION, TAXES AND OTHER ITEMS.......................................................... 23 VII. RATE BASE ..................................................................................................................... 26 VIII. RATE DESIGN ................................................................................................................ 27 IX. SUPERIOR WATER COMPANY, INC. MERGER ....................................................... 28 X. PURCHASED WATER ADJUSTMENT CLAUSE ........................................................ 30 XI. ENERGY COST ADJUSTMENT MECHANISM .......................................................... 32 XII. CAPITAL STRUCTURE RATIOS .................................................................................. 33 XIII. RETURN ON EQUITY CONSIDERATIONS ................................................................ 34 XIV. SATISFACTION OF COMMITMENTS FROM THE COMPANY’S 2011 RATE CASE SETTLEMENT ................................................................................................................. 45 XV. CONCLUSION ................................................................................................................. 45 1 I. INTRODUCTION AND PURPOSE OF TESTIMONY 2 Q. What is your name and business address? 3 A. William C. Packer. My business address is 762 W. Lancaster Avenue, Bryn Mawr, 4 Pennsylvania 19010. 5 Q. By whom are you employed and in what capacity? 6 A. I am employed by Aqua Pennsylvania, Inc. (“Aqua PA” or the “Company”) as Vice 7 President – Controller. In addition, I oversee certain financial operations for Aqua PA, 8 and Aqua New Jersey, Inc. (“Aqua NJ”). 9 Q. Please describe your education and business experience. 10 A. I graduated from the Richard Stockton College of New Jersey in 1998 with a Bachelor of 11 Science degree in Business Studies with a concentration in Accounting. In 1998, I joined 12 GE Capital Mortgage Services Inc. as a Staff Accountant. In September 1999, I joined 13 New Jersey American Water Company as a General Staff Accountant responsible for 14 financial statement preparation, account reconciliation, financial support for rate cases, 15 and account analysis. In September 2001, I was transferred to American Water Works 16 Service Company’s (“American”) Shared Services operation located in Mt. Laurel, New 17 Jersey. I was employed there for four years in a variety of positions, including Senior 18 Fixed Assets/Job Cost Accountant, Financial Support Analyst, and Accounting 19 Supervisor Fixed Assets. At American, I had the opportunity to support the rate-making 20 process by working closely with operating subsidiaries in 23 states preparing schedules 21 and exhibits and answering interrogatories. 22 In March 2005, I joined Aqua NJ where I served as Assistant Controller until 23 December 2006 when I transferred to Aqua America. In July 2008, I was promoted to 1 AQUA PENNSYLVANIA, INC. DIRECT TESTIMONY OF WILLIAM C. PACKER 1 the position of Mid-Atlantic Manager of Rates. I was promoted to Regional Controller 2 for Aqua PA and Aqua NJ in October 2012. In April 2017, I was promoted to my current 3 position of Vice President – Controller of Aqua PA. 4 In addition to my corporate experience, I am currently serving in my third term as 5 a Councilman in the Borough of Woodbury Heights, New Jersey. In this role, I currently 6 serve as the Chairman of the Finance, Administration, and Personnel committee and as a 7 member of the Public Safety and Street/Roads committees. The Borough of Woodbury 8 Heights is one of 565 municipalities in the state and has a population of approximately 9 3,000. 10 Q. What are your duties as Vice President - Controller? 11 A. As Controller, I oversee all financial accounting and reporting activities of Aqua PA. My 12 responsibilities also include oversight of all regulatory filings including base rate cases, 13 surcharges, and other compliance filings. I report directly to the Chief Accounting 14 Officer of Aqua America, who reports directly to the Chief Financial Officer. 15 Q. What is the purpose of your testimony? 16 A. The purpose of my testimony is as follows: (1) to explain the Company’s need for rate 17 relief; (2) to identify and describe the principal accounting exhibits (AP Exhibits 1-A and 18 1-B) submitted in support of Aqua PA’s proposed rate increase for water and wastewater 19 operations, respectively; (3) to explain and support the derivation of certain Company 20 expense and rate base claims; (4) to describe any major changes or other matters related 21 to rate structure and rate design; (5) to describe the Company’s proposed capital 22 structure; (6) to recommend the appropriate return on equity to be utilized in this 23 proceeding in light of the analysis of Mr. Paul R. Moul (AP Statement No. 4); (7) to 2 AQUA PENNSYLVANIA, INC. DIRECT TESTIMONY OF WILLIAM C. PACKER 1 provide an overview proposed Purchased Water and Energy Adjustment mechanisms; (8) 2 to address return on equity considerations (9) to discuss the Company’s satisfaction of the 3 commitments it made in the settlement of certain issues in its last water base rate case. 4 Q. For which of the Company’s exhibits are you responsible? 5 A. I am responsible for the primary accounting exhibits for water and wastewater operations, 6 respectively, AP Exhibits 1-A and 1-B, and Exhibit 2, which supports the Company’s 7 labor expense claims. In addition, I oversaw and assisted in the preparation of the backup 8 volumes that contain responses to the Pennsylvania Public Utility Commission’s (“PUC” 9 or the “Commission”) standard rate case filing requirements with respect to: A. Statement 10 of Income, B. Operating Revenues, C. Operating Expenses, D. Taxes, E. Rate Base, G. 11 Rate of Return, H. Rate Structure, J. Balance Sheet, and K. Other Data. 12 II. AQUA PA’S NEED FOR RATE RELIEF 13 Q. Why is Aqua PA seeking rate relief at this time? 14 A. The Company’s last water base rate case was filed nearly seven years ago. Rates 15 established in that case went effective on June 8, 2012. The Company has not filed a 16 base rate increase for its wastewater operations since October 29, 2010. Since that time, 17 the Company invested nearly $1.4 billion in utility infrastructure through March 31, 2018 18 and another $800 million approximately is projected to be invested through the fully 19 projected test year (“FPFTY”) ending March 31, 2020. 20 The Company was able to support this level of investment without increasing its 21 base rates and for a majority of this time period without implementing a Distribution 22 System Improvement Charge (“DSIC”) because of its decision to adopt a change to its 23 method of tax accounting with regard to units of property. This change allowed the 3 AQUA PENNSYLVANIA, INC. DIRECT TESTIMONY OF WILLIAM C. PACKER 1 Company to deduct certain expenditures that were previously capitalized for tax 2 accounting purposes. The change in method of accounting for repairs is described in 3 more detail in the direct testimony of William Jerdon (AP Statement No. 7). Pursuant to 4 the terms of the settlement of the Company’s 2011 water base rate case, the Company 5 flowed-through the tax effects of such repairs deductions for book and ratemaking 6 purposes. 7 The settlement of the Company’s 2011 base rate case also provided that the 8 Company would notify the Commission and the statutory parties if it decided to change 9 its method of accounting to treat certain expenditures as deductible repairs. Accordingly, 10 at the end of 2012, the Company concluded its analysis of the units of property it would 11 use under its changed method of tax for its 2012 tax year. The change, combined with 12 the use of flow-through accounting, allowed the Company to reduce its Federal and State 13 income taxes. The Company, in its December 2012 DSIC surcharge filing, reduced its 14 DSIC from its then-effective rate of 2.82% to 0.00%. The reduction of the DSIC was 15 done on a forward-looking basis in anticipation of exceeding the DSIC allowable return 16 on equity. 17 In May of 2013, the Company notified the Commission and statutory parties that: 18 (1) beginning in tax year