20221031Comments(8)_8.pdf

From:Bruce Bistline
To:Jan Noriyuki
Subject:Public comment re Veolia application VEO-W-22-02
Date:Saturday, October 29, 2022 4:19:50 PM
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I attempted to submit comment via the form provided on the Commissions website but could not
get the form to “send” Marsha suggested I send my comments directly to you.

Bruce Bistline
559 W. Mesa Grande Drive
Boise, Idaho 83702
208-989-7771
[e-mail]
Water service from Veolia

I acknowledge that submitting a comment in an open case constitutes a public record
under Idaho Code § 74-101 (13) and all information provided by me on this form is available
for public and media inspection. My comment may be reviewed by the utility.

For the purpose of this comment, I will assume, without conceding, that: 1) Veolia in fact
spent $70 million in meaningful improvements in the Treasure Valley's water system (as opposed,
for example, to maintenance for which it is already compensated by existing rate authorizations); 2)
it is fair and reasonable for Veolia to seek a 7.75% ROI on this investment; and, 3) it is fair,
reasonable or necessary to spread the cost of these improvements disproportionately among
various areas served by Veolia.

If, as asserted in the public notice, the requested rate increase will produce additional
revenue of $12.1 million dollars per year then the requested rate increase would fully reimburse the
investment principal ($70 million) in just under 6 years. Allowing for a fair ROI which could be
accounted for monthly with the portion of the proposed rate increase which exceeds the monthly
ROI to be applied to the reimbursement of the principal investment, Veolia should be fully
compensated both for the investment principal and the fair ROI on the diminishing principal within 8
years.

This being the case, the proposed rate increase should "sunset" at the point where Veolia
has been fully reimbursed for the original investment principal ($70 million) and the appropriate ROI
on that principal as it is reduced by funds collected as a result of the proposed rate increase. Once
full reimbursement has been accomplished the proposed rate increase can no longer be justified by
reference to any out-of-pocket expense or warranted ROI and will thereafter be manifestly
unconscionable.

From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Monday, October 31, 2022 10:00:06 AM
The following comment was submitted via PUCWeb:
Name: Greg Westermeier
Submission Time: Oct 31 2022 9:24AMEmail: [e-mail]
Telephone: [phone]Address: 1659 S REINHART DRIVE
Boise, ID 83706
Name of Utility Company: Veolia Water
Case ID: VEO-W-22-02
Comment: "I understand that you are not a Non- profit Company, nor a Charity organization. There are certain improvements that are required to keep water, clean, and available for all of
your customers. I'm not an unreasonable man. I'm 71 yrs. old retired Carpenter living on a pension. The issue I have with your rate hike is that it seems rather high, considering that it's
not just me who is getting the rate hike, but thousands of others like me. That is a lot of money if you include all your customers. If I buy a car, it's up to me to pay for the upkeep. I can't go
back to the car company and ask them to help. I bought it ,it's my responsibility only. You purchased the company, and have a duty to perform, and fulfill, all it takes to provide clean
water, and reliable service. I do not say you cannot raise your rates, but you need to keep them reasonable. All of us have other bills besides our water bill. Thank you. Sincerely, Greg
Westermeier "
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From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Monday, October 31, 2022 11:00:11 AM
The following comment was submitted via PUCWeb:
Name: Mike Hardesty
Submission Time: Oct 31 2022 10:02AMEmail: [e-mail]
Telephone: [phone]Address: 1010 ranch road
Boise, ID 83702
Name of Utility Company: Veolia
Case ID: VEO-W-22-02
Comment: "I ask that the request to increase water rates be denied. In Boise we have already seen a significant increase in our property taxes. The green landscape we enjoy is tough
enough to maintain currently and increasing water costs will change the beauty we all enjoy."
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From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Monday, October 31, 2022 1:00:08 PM
The following comment was submitted via PUCWeb:
Name: STEVE WILLIAMS
Submission Time: Oct 31 2022 12:03PMEmail: [e-mail]
Telephone: [phone]Address: 4227 W HIGH MEADOW DR
Boise, ID 83714-5066
Name of Utility Company: Veolia rate increase
Case ID: VEO-W-22-01
Comment: "As noted in Volia's application their last rate increase was two years ago, and it was not very long ago that an increase occurred before the 2020 increase. I am not in favor of
just granting this increase given that Veolia just acquired Suez, and it was in their best interest to know the financial outlook for the acquisition. I have no idea what the outlook of Suez was
in respect to a fair return on their money, but to just substitute Veolia's new costs into this picture right after acquisition seems wrong. Does Veolia just have higher costs than Suez?
What is the PUC's estimate of a fair return.? I believe what I am asking the commission to do is dig into some of the numbers provided by Veolia and compare them with industry and PUC
standards before granting this request. Public utilities can show any return they want just be increasing or decreasing costs, and because they are a virtual monopoly the PUC needs to keep
their costs aligned with industry standards. Please make sure these are justified. The Eagle phase-in timeline costs are just such a cost that the company somehow choses to make, or they
acquired the conditions of the phase-in in their acquisition. Either way, it does not seem like the non-Eagle residents should be asked to bear any part of the Eagle costs to raise Veolia's
return to 7.79% immediately. Those Eagle costs should be excluded from Veolia"s analysis when considering their current return on their money. "
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From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Monday, October 31, 2022 9:00:16 AM
The following comments were submitted via PUCWeb:
Name: Maryann Hardesty
Submission Time: Oct 31 2022 8:48AMEmail: [e-mail]
Telephone: [phone]Address: 2102 W Moccasin Court
Boise, ID 83703
Name of Utility Company: Veolia
Case ID: VEO-W-22-02
Comment: "I am writing to protest the proposed 24.1 percent increase in water bill submitted by Veolia. That is an absurd amount of increase without cause. The fact that this is being
considered is unbelievable. We cannot support anymore increases in the rates or you will be looking at brown lawns, and increase fire danger, especially in the foothills. This company is
not locally owned which is another issue. Seriously, please do not support this request. Maryann Hardesty"
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Name: Frank Hardesty
Submission Time: Oct 31 2022 8:50AMEmail: [e-mail]
Telephone: [phone]Address: 3834 S Suntree Way
Boise, ID 83706
Name of Utility Company: Veolia
Case ID: VEO-W-22-02
Comment: "I am writing to protest the request by Veolia to increase rates by 24.1 percent. Why do they need a increase in revenue of over 12.1 million a year? We cannot support
another increase in utilities! Think about those who are on restricted budgets and limited income. Please reject this proposal. Frank Hardesty"
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From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Monday, October 31, 2022 12:00:07 PM
The following comments were submitted via PUCWeb:
Name: James DeWitt
Submission Time: Oct 31 2022 11:08AMEmail: [e-mail]
Telephone: [phone]Address: 919 N. 20th Street
Boise, ID 83702
Name of Utility Company: Veolia Water Idaho
Case ID: VEO-W-22-02
Comment: "I have reviewed Veolia's application for a 24.1% rate increase and the pre-fileddirect testimony in support of the application. I find Veolia's case unpersuasive. An increase
nearly three times the inflation rate just two years after the PUC's rate study strongly suggeststhe rate increase is not justified. In fact, the only substantive change in circumstances since the
rate study was Veolia's purchase of Suez. That circumstance strongly suggests Veolia overpaidand is seeking to recapture its acquisition expense from ratepayers. My back of the envelope
calculation shows that the primary cause of Veolia's claimed lower rate of return to Veolia wasthe increased capital basis created by Veolia's overly generous purchase price to Suez. That's
not a proper basis for approving a rate increase, and certainly not a rate increase of thismagnitude. Remember, too, that when that sale came before the PUC for approval Veolia had
promised ratepayers that there would be no rate increases resulting from the purchase. if, asthe numbers suggest, Veolia overpaid, that's it's problem, not one to be shifted to ratepayers.
For many years, I practiced public utility law in Alaska. In a parallel kind of case involvingacquisition of a natural gas distribution company, the chair of Alaska PUC, at the public
hearing, told the applicant, "Your piss-poor business judgment is not a proper basis for a rateincrease." The same can be said for Veolia's rate increase sought in this docket. I urge the
Idaho PuC to deny Veolia's application. Jim DeWitt"
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Name: Gregg ServheenSubmission Time: Oct 31 2022 11:25AM
Email: [e-mail]: 208-871-7712
Address: 2816 South Colorado AveBoise, ID 83706
Name of Utility Company: Veolia
Case ID: VEO-W-22-02
Comment: "As to the request by Veolia to adjust their rates up by 24.1%. I oppose any and all
rate increases by Veolia for their water services. It is not in the public interest or good to increase the profits of a for profit water delivery company. I suggest no rate increases
requested by Veolia should be allowed or approved by the PUC. If Veolia requires rate increases to meet its costs, then I suggest the PUC make it a requirement of Veolia that they
first reregister their company as a B corporation. Once Veolia has made this change, then I would agree it is appropriate for the PUC to contemplate needed rate increases, but not before
this happens. Thank you."
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