20230301Supplemental to Testimony.pdf

ERRATA TO TESTIMONY 1 MARCH 1, 2023
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF VEOLIA WATER IDAHO, INC. FOR A
GENERAL RATE CASE
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CASE NO. VEO-W-22-02

SUPPLEMENTALTO
TESTIMONY OF THE
COMMISSION STAFF

On February 15, 2023, Testimony of the Commission Staff (“Staff”) were filed with the
Commission. On February 21, 2023, Veolia Water Idaho, Inc. submitted a response to Staff’s
Production Request No. 163. The following changes have been made to the following Testimony’s:
1. Mr. English Page 3, Line 5-6:
READS:
“… providing the Company with an additional $3.44 million in revenue for an
increase of 6.56%.”
SHOULD READ:
“… providing the Company with an additional $3.4 million in revenue for an
increase of 6.48%.”
2. Mr. Culbertson Page 2, Line 15-16:
READS:
“… $55,854,457, an increase in the Company’s annual revenues of $3,438,334,
or 6.56%.”
SHOULD READ:
“… $55,854,138, an increase in the Company’s annual revenues of $3,397,931,
or 6.48%.”
3. Mr. Culbertson Page 16, Line 21:
READS:
“… recommended 6.56% increase to each customer class.”
SHOULD READ:
“… recommended 6.48% increase to each customer class.”

RECEIVED
2023 March 1, PM 3:48
IDAHO PUBLIC
UTILITIES COMMISSION

ERRATA TO TESTIMONY 2 MARCH 1, 2023
The attachments include revised pages that replace the respected Staff’s Testimony as
mentioned above. Mr. Culbertson Exhibit Nos. 130, 131, and 135 have been revised to reflect
the changes to his testimony and Mr. Eldred amended Testimony should replace in full the
Testimony filed on February 15, 2023.

DATED at Boise, Idaho this 1st day of March 2023.

__________________________________
Chris Burdin
Deputy Attorney General

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1st DAY OF MARCH 2023, SERVED THE FOREGOING REVISED DIRECT TESTIMONY OF DONN ENGLISH, TRAVIS CULBERTSON, AND MICHAEL ELDRED, IN CASE NO. VEO-W-22-02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
PRESTON N CARTER MORGAN GOODIN
GIVENS PURSLEY LLP
PO BOX 2720 BOISE ID 83701-2720 E-MAIL: [e-mail]@givenspursley.com
[e-mail]
LORNA K. JORGENSEN MEG WADDEL ADA COUNTY PROSECUTING
ATTORNEY'S OFFICE I CIVIL DIVISION 200 W. FRONT STREET, ROOM 3191 BOISE, ID 83702
E-MAIL: ci [e-mail]. gov
JIM SWIER MICRON TECHNOLOGY, INC.
8000 SOUTH FEDERAL WAY BOISE, ID 83707 E-MAIL: [e-mail]
MARY R. GRANT DEPUTY CITY ATTORNEY BOISE CITY ATTORNEY'S OFFICE
105 N. CAPITOL BLVD.
PO BOX 500 BOISE, ID 83701-0500 E-MAIL: [e-mail]@cityofboise.om:
DA YID NJUGUNA MGR-REGULATORY BUSINESS
VEOLIA WATER M&S INC 461 FROM ROAD STE 400 PARAMUA NJ 07052 E-MAIL: [e-mail]
SHARON M. ULLMAN, PRO SE
5991 E. BLACK GOLD STREET
BOISE, ID 83 716 E-MAIL: [e-mail]
AUSTIN RUESCHHOFF
THORVALD A. NELSON AUSTIN W. JENSEN HOLLAND & HART, LLP 555 17TH STREET SUITE 3200 DENVER, CO 80202 E-MAIL: darueschho ff@ho llandhart. [e-mail] [e-mail]
[e-mail] [e-mail]
CERTIFICATE OF SERVICE
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further proposes to update the Company's test year to the
12 months ending December 31, 2022, which coincides with
the close of the calendar year. Based on the 2022 test
year, Staff calculated a revenue requirement of $55.85
million, providing the Company with an additional $3.4
million in revenue for an increase of 6.48%. This number
excludes normalization adjustments to the Company's revenue
as discussed in Staff witness Eldred's testimony, which
Staff will update when information is received. Staff's
revenue requirement is calculated using a weighted average
cost of capital of 6.77%, including 9.0% Return on Equity
("ROE"), applied to the 2022 average net rate base of
$261,118,238. Staff's proposed revenue increase is spread
uniformly across all billing components. Additionally,
Staff does not support the Company's proposal to implement
a Distribution System Improvement Charge ("DSIC") at this ·
time.
Q.How does Staff's recommendation compare to the
Company's request in its Application?
A.The Company requested a revenue requirement of
$63.83 million, increasing its annual revenues by
approximately $12.1 million, or 23.4%. The Company's
CASE NO. VEO-W-22-02 03/01/23 ENGLISH, D. STAFF 3
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A.My testimony is organized by the following
topics:
Revenue Requirement Pg. 2
O&M Expense Adjustments Pg. 7
Rate Design Pg. 15
DSIC Pg. 17
Q.What is your educational and experience
background?
A.My education and experience are provided in
Exhibit No. 129.
Revenue Requirement
Q.Please provide a summary of Staff's proposed
revenue requirement in this case.
A.Staff recommends a total revenue requirement of
$55,854,138, an increase in the Company's annual revenues
of $3,397,931, or 6.48%. Staff's revenue requirement is
based on a 9.0% Return on Equity ("ROE") and a capital
structure consisting of 44.43% debt and 55.57% equity for
a Weighted Average Cost of Capital ( "WACC") of 6. 77%
applied to net rate base of $261,118,238.
Q. Please outline Staff's adjustments to the
Company's proposed revenue requirement components.
A. Staff is
to the
recommending
Company's
twenty-eight
requested
( 2 8)
revenue adjustments
requirement. Exhibit No. 130 provides a brief summary of
CASE NO. VEO-W-22-02 03/01/23 CULBERTSON, T. (Di) STAFF 2
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proposed in Company's Application?
A. Yes. Although the Company is requesting an
across the board, uniform percentage rate increase to all
customer classes, they are requesting no rate increase to
the Private Fire Protection customer class. As such, the
increases to other classes absorb additional revenues that
are not going to be collected from the Private Fire
Protection customer class.
Q.Does Staff support the Company's rate design
proposal?
A.Not entirely.I do recommend spreading Staff's
increase uniformly across all rate components within
Schedule No. 1 similar to what the Company proposed in its
Application; however, I do not support the Company's
proposal to not increase rates for the Private Fire
Protection customer class for reasons explained in Staff
witness Eldred's testimony. Instead, Staff is recommending
the increase be spread across all rate components for all
classes including Private Fire Protection. Exhibit No.
135 provides the rate design associated with Staff's
recommended 6.48% increase to each customer class, and the
Existing Eagle Water Company customers.
Q.Do.you believe the current rate design structure
is fair, just, and reasonable?
A. Yes. Without a valid load and Cost of Service
CASE NO. VEO-W-22-02 03/01/23 CULBERTSON, T. (Di) STAFF 16
Revised Exhibit No. 130
Case No. VEO-W-22-02
T. Culbertson, Staff
03/01/23
Revised Exhibit No. 131
Case No. VEO-W-22-02
T. Culbertson, Staff
03/01/23
Revised Exhibit No. 135
Case No. VEO-W-22-02
T. Culbertson, Staff
03/01/23 Page 1 of 4
Revised Exhibit No. 135
Case No. VEO-W-22-02
T. Culbertson, Staff
03/01/23 Page 2 of 4
Revised Exhibit No. 135
Case No. VEO-W-22-02
T. Culbertson, Staff
03/01/23 Page 3 of 4
Revised Exhibit No. 135
Case No. VEO-W-22-02
T. Culbertson, Staff
03/01/23 Page 4 of 4