20230329Rebuttal Cary - Corrected.pdf

CORRECTED REBUTTAL TESTIMONY OF JARMILA CARY PAGE 1 OF 4
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
16686282_1.docx[30.235]

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

CASE NO. VEO-W-22-02

CORRECTED REBUTTAL TESTIMONY
OF JARMILA CARY

On March 8, 2023, Rebuttal Testimony of Jarmila Cary was filed with the Commission.
By way of Attachment 1, Revision to Ms. Cary’s Rebuttal Testimony, page 7, lines 5-7 of Ms.
Cary’s Rebuttal Testimony is corrected as follows, with changes shown in bold, red text:
Current Rebuttal Testimony: “For Non-Bargaining employees performance ratings
consist of 70% individual objective performance and 30% Veolia Values performance (Respect,
Customer Focus, Solidarity, and Innovation).”
Corrected Rebuttal Testimony: “For Non-Bargaining employees performance ratings
consist of 25% individual objective performance and 75% Veolia Values performance (Respect,
Customer Focus, Solidarity, and Innovation).”

RECEIVED
2023 March, 29 3:05PM
IDAHO PUBLIC
UTILITIES COMMISSION
CORRECTED REBUTTAL TESTIMONY OF JARMILA CARY PAGE 2 OF 4
DATED: March 29, 2023
VEOLIA WATER IDAHO, INC.
By
Preston N. Carter
Attorneys for Veolia Water Idaho, Inc.

CORRECTED REBUTTAL TESTIMONY OF JARMILA CARY PAGE 3 OF 4
CERTIFICATE OF SERVICE

I certify that on March 29, 2023, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:

Commission Staff Via Electronic Mail
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
[e-mail]

Lorna K. Jorgensen
Meg Waddel
Ada County Prosecuting Attorney’s Office
Civil Division
200 W. Front Street, Room 3191
Boise, ID 83702
[e-mail]

Sharon M. Ullman, pro se
5991 E. Black Gold St.
Boise, ID 83716
[e-mail]

Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Jim Swier
Micron Technology , Inc.
8000 South Federal Way
Boise, ID 83707
[e-mail]

CORRECTED REBUTTAL TESTIMONY OF JARMILA CARY PAGE 4 OF 4

Mary Grant
Deputy City Attorney
Boise, City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500

[e-mail]
[e-mail]

Preston N. Carter

ATTACHMENT 1
ATTACHMENT 1
Corrected Page 7 to Jarmila Cary's
Rebuttal Testimony
CARY, Di-Reb
Page 7 of 22
Veolia Water Idaho, Inc.
are known, measurable and contractually obligated. It is the Company’s position that 1
bargaining unit wage increases should be reflected in payroll costs for recovery. 2
Q. Are the Non-Bargaining Unit 2023 pay increases known and measurable? 3
A. Yes. The Company is finalizing the 2022 performance evaluations for non-bargaining 4
unit employees in early March, the ratings guide wage increases. For Non-Bargaining 5
employees performance ratings consist of 25% individual objective performance and 6
75% Veolia Values performance (Respect, Customer Focus, Solidarity, and Innovation). 7
The overall Non-Bargaining Unit 2022 performance rating completed in March 2023 8
resulted in an wage increase of 3.6% with an effective date of April 1, 2023. The 9
Company’s as-filed position anticipated a 4% increase in Non-Bargaining employee 10
wages. The Company’s Rebuttal position removes 0.4% or $24,117 the difference 11
between the anticipated and actual wage increases for the Non-Bargaining employees. 12
Mr. Johnson proposed eliminating all wage increases, a total of $402,776. The 13
Company’s position is that pay increases are justified, necessary to adjust for cost of 14
living increases from rising inflation, and to allow for competitive wages to attract and 15
retain talent. The Company requests recovery of $161,610 for Bargaining Unit employees 16
wage increases and $217,049 for Non-Bargaining Unit employees, a total of $378,659. 17
Overtime & Stand By Pay 18
Q. Do you agree with Staff Witness Johnson’s proposal to remove the 2023 Overtime 19
pay increases of $14,514 and $1,176 pay increases for Stand-by pay? 20
A. No. Overtime pay and Stand-by pay rates are identified in the collective bargaining unit 21
agreement and follow the established rates of pay. As of April 1, 2023 bargaining unit 22
wages increase by 2.75% and Overtime and Stand-by pay will follow suit. The 23