20221110Reply Comments.pdf

Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. I1184
Givens Pursley LLP
601 W. Bannock St.
Boise, D 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
prestoncarter(@ eivenspursley. com
morsansoodinfa) givenspursl ey. com
Attorneys for Veolia Water ldaho, Inc.
BEFORE THE IDAHO PI]BLIC UTILITIES COMMISSION
H[fl[IVED
rii:i ii0'i l0 Pl{ 3: I I
-' r' , .' ; "-.{frLlt: I i- rt ;i_:ii{F*{lSSlON
IN THE MATTER OF VEOLIA WATER
IDAHO, INC.'S APPLICATION TO AMEND
BRIAN WATER SURCHARGE AND
REFUND CUSTOMERS.
CaseNo. VEO-W-22-03
Vrolra WereR Ioeuo [NC.'s Rrplv
CouusNrs
Veolia Water ldaho, Inc. ("Veolia" or "Company") submits these comments in response
to the comments filed in this case by the Idaho Public Utility Commission Staff ("Staff
Comments").
Veolia appreciates Staff s concerns and diligence in reviewing the Application in this
case, as well as Staffs general support for approving the tariffrevisions. StaffComments at 2.
Regarding administration of the credit, Veolia does not dispute that StafPs analysis is
theoretically sound, but it is difficult to implement. See id. at24. Staffs recommendation-
crediting individual customer principal balances on the date the payments were made-<reates
complexity. Because this would need to be computed manually and tracked individually, StafPs
method would increase overall costs as well as the likelihood of mistakes. [t may also be more
difficult for customers to understand than a one-time credit. Finally, Veolia's proposal of the
one-time credit benefits customers by returning the refund now rather than waiting.
CoMpeNv's REPLY CoMMENTS PAGE 1 oF 3
In light of the Application, the supporting informatioq aod the oomments received in the
casg Veolia respectfully requests that the Commission issue an order granting tho relief sought
in the Applicatioo.
DATED: November 10, 2022.
a,A-b
By:
PrestonN. Carter
Givens PursleyLLP
Auorneysfor Yeolia Water ldaho, Inc.
Coupauy's REpr,y CotrlueNrs P.lae 2 or3
CERTIFICATE OF SERVICE
I IIEREBY CERTIFY THAT onNovember 10, 2022,I caused a tnre and correct copy of
the foregoing to be s€rved upon the following parties as indicated below:
JanNoripki
Commission Seo*ary
Idaho Public Utilities Commission
P.O. Box 83720
Boise,Idaho 8372G0074
ian.noriyuki@Auc. idaho. gov
secretarv(Dnuc.idaho. eov
EI
Etr
Fmail
U.S. Mail
Fax
Hand Delivery
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PrestonN. Carter
CoupaNv'sRrplv@uurNm PeoB 3 or3