20220524Comments.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.007 4
[phone]
IDAHO BAR NO. 98IO
CHANGE OF SUEZ WATER IDAHO INC. TO
vEoLIA WATER IDAHO, INC.
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Street Address for Express Mail:
1 I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE CORPORATE NAME)
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CASE NO. VEO-W-22-01
suz-w-22-01
COMMENTS OF THE
COMMISSION STAFF
coMES NOW the Staff of the Idaho Public Utilities commission ("staff'), by and
through its Attorney of record, Chris Burdin, Deputy Attorney General, and submits the following
comments.
BACKGROUND
On April 8,2022, Veolia Environment S.A. ("Veolia") filed a letter with the Commission
stating that its acquisition of SUEZ S.A. ("SUEZ") was completed on January 18,2022. Veolia
claimed that the Competition and Markets Authority provided antitrust clearance for the
transaction in the United Kingdom on March 70,2022, clearing the way for the Veolia and SUEZ
to commence the integration of the Veolia North America and the SUEZ North America ("SNA")
businesses, which include SUEZ Water Idaho Inc. Veolia explained that as pan of the integration,
there would be a rebranding of the SNA businesses to the Veolia brand.
1STAFF COMMENTS MAY 24,2022
At the Commission's April 28,2022, Decision Meeting, Staff recommended that the
Commission treat the Tariff Advice as an Applicationr and process the case by Modified Procedure
to allow additional time to review Veolia's proposal and for public input. To accomplish this,
Staff also recommended the Commission suspend the proposed effective date pursuant to ldaho
Code $ 6t-622(4).
Additionally, the Commission observed that Veolia had not requested a change to the
corporate name on the Certificate of Public Convenience and Necessity ("CPCN") No. 143. The
Commission noted that Veolia's application was likely premature until such a request was made
and reviewed by the Commission.
Veolia stated that if the name change was approved, customers would continue to receive
water service under the same rates, terms, and conditions as were presently on file with the
Commission. Veolia included a copy of its Commission approved tariffs with the indicated name
change and a proposed effective date of May 1,2022.
STAFF ANALYSN
Staff has reviewed the Application, tariffs, and other necessary documents to confirm that
the proposed filing will not harm customers. Staff confirmed that the proposed tariffs with the
name change have the same rates, terms, and conditions as the current tariffs on file with the
Commission. Staff reviewed the Secretary of State website2 and confirmed the name Veolia Water
Idaho, Inc. was adopted on March 28,2022, which is consistent with the Company's Application.
Veolia has requested to change the name on its tariffs. Staff is concerned that SUEZ has
not complied with the Commission's directive, ordering SUEZ to amend CPCN No. 143 "to reflect
the acquisition of Eagle Water's service territory and customers." Order No. 35247 at 20. Staff
recommends Veolia comply with Order No. 35247 and file an amended CPCN that includes the
Eagle Water service territory. During informal discussions with Veolia, Staff became aware that
the Company had begun surveying their entire Eagle Water service territory, and the Company
indicated that it may need up to 60 days to complete and file an amended CPCN. Therefore, Staff
recommends approval of the name change contingent upon the Company filing an amended CPCN
that includes the Eagle Water service territory within 60 days of the Commission's Final Order in
rsee Commission Rule of Procedure 134.02,IDAPA 31.01.01.134.02
2 sosbiz.idaho.gov.
2STAFF COMMENTS MAY 24,2022
this case. After review of the amended CPCN, Staff will make its recommendations regarding its
findings in a decision memo to the Commission.
As of May 24,2022, there have been no public comments on Veolia's application.
STAFF RECOMMENDATION
Staffrecommends approval of the name change contingent upon Veolia filing an amended
CPCN that includes the Eagle Water service territory within 60 days of a Commission's Final
Order on the rurme change.
Respectfully submitted this Ltlil day of May 2022.
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Chris Burdin
Deputy Attorney General
Technical Staff: Travis Culbertson
Chris Hecht
Kevin Keyt
i:umisc/commentVveow22. I suzw22. lcbtnccwhksk comments
JSTAFF COMMENTS MAY 24,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF MAY 2021,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NOS. SUZ-W.22.OIA/EO-W-22-OI, BY E.MAILING A COPY THEREOF, TO
THE FOLLOWING:
PRESTON N CARTER
GTVENS PURSLEY LLP
PO BOX 2720
BOrSE rD 83701-2720
E-MAIL: [e-mail]
MARSHALL THOMPSON
VEOLIA WATER IDAHO INC
8284 W. VICTORY RD
BOISE ID 83709
E-MAIL: [e-mail]
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SECRETARYT--
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CERTIFICATE OF SERVICE