20230720Comments of Commission Staff.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )OF VEOLIA WATER IDAHO,INC.FOR )CASE NO.VEO-W-23-01
APPROVAL OF WATER MAIN )INSTALLATION AGREEMENT )
)COMMENTS OF THE
)COMMISSION STAFF
COMMISSION STAFF ("STAFF")OF the Idaho Public Utilities Commission,by and
through its Attorneyof record,Chris Burdin,Deputy Attorney General,submits the following
comments.
BACKGROUND
On May 17,2023,Veolia Water Idaho,Inc.("Company"),filed an application
("Application")with the Idaho Public Utilities Commission ("Commission")requesting approval
of a Water Main Installation Agreement ("Agreement")between the Company and Ada County
(the "County").
On June 13,2023,the Commission issued a Notice of Application.Order No.35811.
The Company represents that the County has been awarded a grant of federal funds under the
American Rescue Plan Act ("ARPA")and that one of the allowable expenditures for the ARPA
funds is investments in necessary water infrastructure.Application at 1.
STAFF COMMENTS 1 JULY 20,2023
The Company represents that certain wells in southern Ada County are not adequate to
provide drinking water to residences,and that these residences that lack adequate water service
are located within the Company's certificated service area.Id.at 1-2.
The Company represents that in February 2023,the Company and the County entered
into the Agreement with the intent to use ARPA funds to install water main extensions that will
connect certain residences of the County to the Company's water system.Id.at 2.
The Company represents that under the Agreement,the Company will competitively
solicit bids for constructing the water main extensions and will submit a proposal that includes
the bids for the completion of the construction to the County.Id.
The Company represents that under the Agreement,the County will pay the Company for
the construction of the water main extensions,and that upon completion of the water main
extensions,the residents will be able to connect to the Company's system,under the same
conditions,and subject to the same rates,charges,and rules as other Company customers.Id.
The Company represents that it will solely own the infrastructure and will treat the
infrastructure as Contribution in Aid of Construction ("CIAC").Id.
Public Comments
As of July 20,2023,five comments have been received,all from affected residents who
hope to receive water from the Company,and who therefore support the Agreement.In addition,
the Commission received a letter from the Ada County Commissioners recommending that the
Commission support the proposed Agreement.
STAFF ANALYSIS
Staff reviewed the Company's Application and its responses to discovery requests.Staff
recommends that the Commission approve the Agreement because Staff believes that the
resulting expansion of the water system will benefit residents in the Company's service area at
no cost to existing customers.
Benefit to Customers
Staff confirmed that the proposed water main extensions will serve customers that are
within the Company's certificated service territory,and Staff believes that the proposed water
main extensions will provide benefits to customers by providing clean,reliable water to residents
STAFF COMMENTS 2 JULY 20,2023
who are currentlynot able to obtain sufficient water through private wells.Staff notes that the
Company,Ada County Commissioners,and potential new customers that will be serviced by the
proposed project have provided written comments supporting the Agreement and representing
that existing wells are failing in certain neighborhoods of southern Ada County.
No Cost to ExistingCustomers
Staff confirmed that the Agreement will not increase costs to existing customers.
According to the Agreement,Ada County will be responsible for the full cost of constructing the
line extensions and will receive funds covering the cost from the federal government via the
American Rescue Plan Act ("ARPA").Application at 1.The Company represents that
payments from Ada Countyfor the construction costs will be treated as CIAC,and once the
project is built it will become part of the Company's system.In addition,the Company indicated
that the CIAC will not incur any tax burden,which would otherwise be a cost borne by existing
customers.Company Response to Production Request No.7.
Staff believes that revenue generated from additional customers served by the line
extension will cover any incremental maintenance cost,and the Company represented that
ongoing maintenance cost should be negligible.Company Response to Production Request
No.2.
STAFF RECOMMENDATION
Staff recommends that the Commission issue an order approving the Agreement.
Respectfully submitted this 20th day of July 2023.
Chris Burdin
Deputy AttorneyGeneral
Technical Staff:Matt Suess
Shubhra Deb Paul
Kevin Keyt
Dylan Mulvaney
i:umisc/comments/veow23.lcbms comments
STAFF COMMENTS 3 JULY 20,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF JULY 2023,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF TO
VEOLIA WATER IDAHO,INC.,,IN CASE NO.VEO-W-23-01,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]
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE