20220930Cooper Direct with Exhibits.pdf

Preston N. Carter (ISB No. 8462)
Morgan D. Goodin (ISB No. 11184)
Givens Pursley LLP 601 W. Bannock St. Boise, ID 83702 Telephone: [phone]
Facsimile: [phone]
[e-mail] [e-mail]
Attorneys for Veolia Water Idaho, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
OF VEOLIA WATER IDAHO, INC. FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO

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DIRECT TESTIMONY OF CATHERINE COOPER FOR VEOLIA WATER IDAHO, INC.
SEPTEMBER 2022
COOPER, DI 2 Veolia Water Idaho, Inc.
Q. Please state your name, occupation and business address. 1
A. My name is Catherine Cooper. I am the Director of Engineering for Veolia Water 2
Idaho, Inc. (“Veolia” or “Company”). My business address is 8248 W. Victory 3
Road, Boise, Idaho 83709. 4
Q. Please summarize your educational background and professional experience. 5
A. I am a graduate of the University of Colorado at Boulder with a Bachelor of Science 6
in Civil Engineering. I completed my Master of Science in Civil Engineering at 7
the University of Washington in Seattle. I have been a licensed Professional 8
Engineer in the State of Idaho since 1999. 9
I have been employed as a civil engineer for 28 years. My work experience includes 10
22 years at Boise area consulting firms where I focused on water system 11
engineering. My experience includes preparing detailed hydraulic calculations; 12
designs for storage tanks, pump stations, pressure reducing stations, pipelines, and 13
well houses; water system Master Facility plans; hydraulic models; and project cost 14
estimates. I was an Owner and Managing Partner at my last consulting firm. 15
I have been employed by Veolia (formerly Suez) since July 2016 as the Director of 16
Engineering in Idaho. 17
Q. Please describe your duties as Director of Engineering. 18
A. I have oversight over the Company’s capital expenditure budget and short and long-19
term facility and water supply planning. In addition, I manage selected engineering 20
projects for the Company. 21
Q. What is the purpose of your testimony? 22
A. The purpose of my testimony is to discuss: 23
COOPER, DI 3 Veolia Water Idaho, Inc.
● Pro forma adjustments to the historic test year (ending June 30, 2022) to 1
recognize investments in plant in service through March 31, 2023. 2
● Explanation of the purchased water expense and adjustments thereto as it 3
relates to drought protection and weather conditions. 4
Q. What Exhibits are you sponsoring? 5
A. I am sponsoring the following Exhibits: 6
1. Exhibit No. 3 - Test Year Period Plant Additions and Retirements 7
2. Exhibit No. 4 - Purchased Water 8
Q. Since the last general rate case, has the Company continued to invest in utility 9
plant in service? 10
A. Yes. The total plant in service investment net of CIAC from January 1, 2021 to 11
March 31, 2023 is approximately $70 million, an increase of about 14% over the 12
Company’s Plant in Service at January 1, 2021 of approximately $512 million. The 13
Company continues to provide new and replacement utility plant in all areas of the 14
business including source of supply, water treatment, pumping, transmission and 15
distribution mains, distribution storage, customer service lines, customer meters, 16
information technology, and general plant. 17
Q. Are these plant in service additions used and useful in providing service to the 18
Company’s customers? 19
A. Yes, they are. Additionally, the projects included in the test year rate base from 20
July 1, 2022 through March 31, 2023 will also be in service before the time new 21
rates that reflect these investments go into effect. 22
COOPER, DI 4 Veolia Water Idaho, Inc.
Q. Can you discuss, in general terms, the capital additions planned to be placed 1
in service from July 1, 2022 through March 31, 2023? 2
A. Yes. The capital additions include meters and services, pumping equipment, new 3
and replacement mains, a new storage tank, treatment equipment, control 4
equipment, facility improvements, engineering studies, information technology 5
systems, and security upgrades. The test year plant additions for this time period 6
are detailed in two locations with associated exhibits. Plant in service additions for 7
the period of July 1, 2022 to March 31, 2023 are summarized by account number 8
in Exhibit No. 11, Schedule 3 sponsored by witness Njuguna, and are also listed by 9
project name on the attached Exhibit No. 3. 10
Q. Does Exhibit No. 3 also show retirements, cost of removal and salvage for the 11
pro forma period? 12
A. Yes. The retirements include service lines, meters, pumping equipment, new and 13
replacement mains, treatment equipment, control equipment, information 14
technology equipment, and facility improvements. The cost of removal is included 15
for additions that involve removing an existing asset. In some cases there is no 16
existing asset to remove with the plant addition. Salvage value is included for 17
assets that are anticipated to have an actual salvage value. 18
Q. Will these plant additions be in service by the end of the test year? 19
A. Yes. These plant additions are underway and/or planned for completion by the end 20
of the test year, March 31, 2023.21
COOPER, DI 5 Veolia Water Idaho, Inc.
Q. Will the plant additions shown on Exhibit No. 3 be used and useful in providing 1
service to the Company’s customers? 2
A. Yes, they will. 3
Q. Please discuss the basis for Veolia Water Idaho’s purchased water expense in 4
the pro forma amount of $316,694 as shown on Exhibit No. 4. 5
A. The annual cost of surface water is dependent on multiple factors including 6
snowpack, drought conditions, and summer high temperatures. Annual purchased 7
water costs have ranged from $329,862 to $349,754 from 2021 to 2022. The 8
Historic Test Year purchased water cost was $378,302. It was higher than the 9
individual years largely because it included two natural flow water bank rental 10
charges due to timing of Idaho Department of Water Resources (IDWR) processing 11
of the rental application. The test year purchased water costs are described in 12
Company witness Wilson’s testimony, Exhibit No. 10, Schedule 1, Adjustment No. 13
9. 14
Veolia’s surface water portfolio is diverse, balanced across natural flow 15
water rights, storage contracts, exchanges, irrigation district shares both owned and 16
leased, long term rental pool lease agreements, and short term rental pool and 17
natural flow water bank rentals. Short term (one season) rental pool and natural 18
flow rentals are used to make up any shortfalls in surface water supply for the year 19
when necessary. 20
Veolia anticipates the water market in the Treasure Valley will tighten as 21
growth continues over the coming decades. In addition, drought and flood 22
conditions may be exacerbated as an effect of climate change. With this in mind, 23
COOPER, DI 6 Veolia Water Idaho, Inc.
Veolia is working towards more permanent surface water arrangements to solidify 1
surface water availability over the long-term for our customers. Natural flow 2
rights, where available, are favored over storage rights that may be more 3
susceptible to drought conditions. Purchases are preferred over leases. 4
The test year amount is lower than the historic test year for two reasons 5
1) there is only one natural flow water bank rental included, and 2) to reflect a shift 6
towards more storage water rental than natural flow rental. 7
Q. Are the lease/contract costs generally known and measurable related to 8
purchased water expense? 9
A. Yes, the costs are generally known and measurable. These agreements have been 10
executed or are in planning/progress, and are shown on Exhibit No. 4. 11
Q. Can you clarify why the purchased water expense proposed in the test year 12
period is less than the historic test year expense by $61,608? 13
A. Yes. In the historic test year, there were two charges for natural flow water bank 14
rentals, one in 2021 and one in 2022. It is not expected to be typical that two 15
charges like this would occur in the same year, so the best estimate of this total cost 16
was made for the test year period, which caused the majority of the decrease. 17
Q. Do you believe $316,694 as depicted on Exhibit No. 4 is a reasonable allowance 18
for purchased water expense for rate making purposes? 19
A. Yes. 20
Q. Does this conclude your testimony? 21
A. Yes. 22

Preston N. Carter (ISB No. 8462)
Morgan D. Goodin (ISB No. 11184)
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Veolia Water Idaho, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF
VEOLIA WATER IDAHO, INC. FOR
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR WATER SERVICE IN THE
STATE OF IDAHO

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Case No. VEO-W-22-02

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

EXHIBITS 3 AND 4 TO ACCOMPANY THE

DIRECT TESTIMONY OF CATHERINE COOPER

Case No. VEO-W-22-02
Exhibit 3
C. Cooper
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Project ID Project Title
In
Service
Date
Forecast Forecast
Forecast
Cost of Forecast
Source of Supply
C22A101 Water Rights Various 121,338$ -$ -$ -$
C22A104 EWC Water Right Transfers Dec-22 11,235$ -$ -$ -$
Subtotals 132,573$ -$ -$ -$
Treatment
C20B511 Taggart Wells Treatment Jun-22 56,175$ -$ -$ -$
C22B501 Replace Treatment Equipment Various 100,215$ 25,200$ 900$ -$
C22B503 Replace Valves, Meters, & Actuators at WTP's Various 50,258$ 7,200$ 300$ -$
C22B504 Chlorination Equipment Various 228,318$ 29,500$ 2,000$ -$
C22B505 CWTP PLC Upgrade Mar-23 428,165$ 173,000$ 10,000$ -$
C22B506 Surface Treatment Plant Roll-Up Various 698,805$ 108,000$ 9,000$ -$
C22B507 CL2 Generator Replacement Various 759,528$ 24,300$ 5,000$ -$
Subtotals 2,321,463$ 367,200$ 27,200$ -$
Pumping Plant
C20C531 Redwood Creek Pump and Pipe Replacement Mar-23 617,290$ 168,288$ 1,500$ -$
C22C101 Pump Equip-Sources of Supply Various 746,205$ 52,200$ 1,800$ -$
C22C102 Replace Booster Pump Equipment Various 98,115$ 18,000$ 3,000$ -$
C22C501 Reconstruct Pumping Facilities and Tank Roads Various 191,819$ 2,500$ 300$ -$
C22C503 Replace Control Equipment Various 59,469$ 7,200$ 1,200$ -$
C22C506 Facility Cooling / HVAC Replacement Various 71,228$ 19,000$ 1,800$ -$
C22C507 Landscaping Replacement - System Facilities Various 111,950$ 4,000$ 400$ -$
C22C512 Sage Acres Booster Pump Improvements/Generator Mar-23 786,305$ 2,000$ 1,000$ -$
C22C513 VFD Replacement - key well sources Dec-22 133,820$ 5,000$ 1,000$ -$
C22C514 EWC Production Roll-up Various 284,489$ 2,000$ 500$ -$
C22C515 EWC Well 8 and PRV Mar-23 280,875$ -$ -$ -$
Subtotals 3,381,564$ 280,188$ 12,500$ -$
Storage
C21E105 Whistle Pig Tank Nov-22 6,191,545$ -$ -$ -$
Subtotals 6,191,545$ -$ -$ -$
T & D Mains
C21D103 Maple Grove Bore to Maple Hills PZ Sep-22 1,693,767$ -$ -$ -$
C21D104 Gowen Road Main Extension Jul-22 2,213,799$ -$ -$ -$
C22C509 System PRV re-builds Various 44,940$ -$ -$ -$
C22C510 Replace PRV Stations Various 89,180$ 3,000$ 700$ -$
C22D101 Five Mile - Seneca to Sandpiper Mar-23 786,450$ -$ -$ -$
C22D300 Developer Extensions Various 2,117,200$ -$ -$ -$
C22D609 T&D Main Replacements Mar-23 461,253$ 30,000$ 5,000$ -$
C22D611 EWC TD Main Replacements Sep-22 87,880$ 4,400$ 2,000$ -$
C22D701 Agency Mains Various 3,601,413$ 105,050$ 20,500$ -$
C22D901 Master Meter New/Replacement Dec-22 67,410$ -$ -$ -$
CYYD001 Fire Hydrants Various 719,939$ -$ -$ -$
CYYD002 New Short Mains & Valves Various 83,925$ -$ -$ -$
CYYD502 Replace Short Mains & Valves Various 555,833$ 2,970$ 300$ -$
Subtotals 12,522,988$ 145,420$ 28,500$ -$
Services
CYYF003 New Fire Services Various 303,345$ -$ -$ -$
CYYF505 Services Various 2,400,660$ 108,000$ 26,100$ 6,300$
Subtotals 2,704,005$ 108,000$ 26,100$ 6,300$
Veolia Water Idaho
Test Year Plant Additions and Retirements
July 1, 2022 to March 31, 2023
Case No. VEO-W-22-02
Exhibit 3
C. Cooper
Page-2 of 2
Project ID Project Title
In
Service
Date
Forecast Forecast
Forecast
Cost of Forecast
Meters
CYYG501 Customer Meters Various 1,122,588$ 270,000$ 9,900$ 9,000$
Subtotals 1,122,588$ 270,000$ 9,900$ 9,000$
Information Technology (IT)
C10J959 Computer Software CCB (Lighthouse)Sep-22 -$ 5,225,079$ -$ -$
C21J553 Computer Refresh Aug-22 206,872$ 56,500$ 2,000$ -$
C22J101 IT Equipment Dec-22 82,263$ 12,000$ 2,000$ -$
C22J501 Replace I&C Equipment Dec-22 44,688$ 6,000$ 1,000$ -$
C22J503 SCADA System Implementation Various 790,668$ 100,000$ 19,000$ -$
C22J504 Power Monitoring Dec-22 47,811$ 4,000$ 500$ -$
C22J505 Replace SCADA Equipment Dec-22 65,587$ 5,000$ 700$ -$
C22J507 GPS Unit Replacement Dec-22 44,440$ 4,000$ 500$ -$
Subtotals 1,282,327$ 5,412,579$ 25,700$ -$
General Plant
C20A101 Water Supply Study Dec-22 84,667$ -$ -$ -$
C20K502 File Relocation Plan Dec-22 179,760$ -$ -$ -$
C21K106 Well Profiling WQ Study Mar-23 325,478$ -$ -$ -$
C21K108 GIS Asset Tracking Nov-22 47,187$ -$ -$ -$
C21K502 Tools - VHF Radios Jul-22 20,111$ -$ -$ -$
C22K001 Safety/Security Upgrades Various 140,438$ -$ -$ -$
C22K002 Hydraulic Model Updates / UDF Plans Oct-22 56,175$ -$ -$ -$
C22K101 Fleet Vehicles Dec-22 724,658$ -$ -$ -$
C22K103 Map EWC System Nov-22 67,410$ -$ -$ -$
C22K104 Utility Network GIS and Hydraulic Study Mar-23 224,700$ -$ -$ -$
C22K106 Snake River Study Dec-22 140,438$ -$ -$ -$
C22K108 Service Area Studies Jul-22 31,907$ -$ -$ -$
C22K501 New and Replacement Tools Various 101,115$ -$ -$ -$
Subtotals 2,144,042$ -$ -$ -$
Gross Plant Adds, Retirements, COR & Salvage 31,803,095$ 6,583,387$ 129,900$ 15,300$
CIAC ($2,405,000)
Gross Plant Less CIAC $29,398,095
Developer Refunds $43,600
ID# UNITS PRICE PER
UNIT
MISC.
FEES
ANNUAL TOTAL UNIT
COST
SHARES IN CANAL
THURMAN MILL TM N/A 46.5 $40.00 $1,860.00
BOISE CITY CANAL CO. BCCC - Owned Shares N/A 45 $98.00 $4,410.00
BOISE CITY CANAL CO. BCCC -2020 Owned Shares N/A 400 $147.00 $58,800.00
Boise City Canal Co (BCCC) - 200 leased shares (10 year,
ex ires 2030 N/A 200 $98.00 $19,600.00
BOISE VALLEY IRRIGATION DISTRICT BVID N/A 89.29 $16.85 $35.00 $1,540.00
CONTRACT/LEASE/STORAGE
ANDERSON RANCH RESERVOIR B.O.R. (1000 af) 13205638 1000 $24.36 $24,360.00
LUCKY PEAK RESERVOIR B.O.R. Re a ment 1100 af 059D101468 1100 $15.16 $16,674.00
LUCKY PEAK RESERVOIR B.O.R. Maintenance 1100 af 1100 $8.00 $8,800.00
BASIN 63 RENTAL POOL / WATER BANK
ANNUAL BASIN 63 RENTAL POOL Mike Myers 3500 $20.00 $140,000.00
WATER BANK IDWR $28,800.00
INCENTIVE PAYMENTS TO BASIN 63 SPACE HOLDERS
Pay space holders that put water into the rental pool N/A 1000 $10.00 $10,000.00 Boise Valley Irrigation Ditch Company
OTHER
Garden City - Joplin $1,850.00
$316,694.00
3 Veolia Water Idaho customers on Joplin Street get their water from
the GC system
Point of diversion in BVID name at Marden WTP. Annual
assessments required to activate.
Annual payment same even if not used. Held in Anderson RSVR for
drought protection & collector mitigation
Fixed Rate: Hold for drought. 40 yr Repayment Contract (Ends
12/31/2046)
B.O.R.estimates O&M yearly & updates costs.
Volume rented varies with snow pack and ability to get commitments
from other space holders.
Water Bank natural flow rental.
Veolia Water Idaho - Purchased Water Exhibit 4
COMMENT
Points of diversion are in TM name at Marden WTP. Annual
assessments required to activate. $40.00/share x 46.5 shares.
Point of diversion are in BCCC name at Marden WTP. Annual
assessments required to activate river intake. $98/share x 45
shares.(.68cfsx2af/dx180d=245 af)
Pipe line to Marden WTP from BCCC - Lateral #3. $147/share x 400.
(6.0cfsx2af/dx180d=2160af)
Pipe line to Marden WTP from BCCC - Lateral #3. $98/share x 200.
(3.0cfsx2af/dx180d=1080af)
Case No. VEO-W-22-02
Exhibit No. 4
C.Coope
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