20241122Application.pdf

RECEIVED
Friday, November 22, 2024
IDAHO PUBLIC
Preston N. Carter, ISB No. 8462 UTILITIES COMMISSION
Morgan D. Goodin, ISB No. 11184
Megann E. Meier, ISB No. 11948
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarter(&r zivenspursle,
morgan o�ggivenspursley.com
memk ia�g venspursle�com
Attorneys for Veolia Water Idaho, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. VEO-W-24-01
OF VEOLIA WATER IDAHO, INC. FOR A )
GENERAL RATE CASE ) APPLICATION
Veolia Water Idaho, Inc., ("Veolia Water Idaho," "Applicant," or"Company") hereby
moves the Idaho Public Utilities Commission("Commission")requesting an Order approving
revisions to Applicant's schedules of rates and charges for water service in the State of Idaho to
become effective on or after December 23, 2024.
I.
Applicant is a public utility water corporation within the meaning of the Idaho Public
Utility Law, is duly organized and existing under the laws of the State of Idaho and is engaged in
conducting a general water business in and about Boise City, Ada County, Idaho, having its
principal office and place of business at 8248 West Victory Road, Boise, Idaho. A certified copy
of Applicant's Articles of Incorporation, together with all amendments to date, is on file with the
Commission, along with Applicant's most recent annual report. Applicant's current Certificate
APPLICATION OF VEOLIA WATER IDAHO,INC. PAGE I OF 7

of Public Convenience and Necessity("CPCN") is Amended Certificate No. 143, most recently
amended by the Commission in Case No. VEO-W-23-05.
II.
Veolia Water Idaho has been providing water service to the public in Boise City and
surrounding areas for more than 100 years. Currently, Veolia Water Idaho provides service to
approximately 108,000 customer connections within Ada County, Idaho.
III.
Veolia Water Idaho's operations, and rates and charges for service have been reviewed in
several rate proceedings before the Commission, most recently, two years ago in Case No. VEO-
W-22-02.
IV.
Attached hereto as Attachment 1 are copies of Applicant's Schedule Number 1, General
Metered Service; Schedule Number 1B, Flat Rate Service; Schedule Number 2, Public Hydrants
and Street Sprinkling; Schedule Number 3, Private Fire Sprinkling and Service; and Schedule
Number 4, Private Fire Hydrant Service, containing the rates under which water service is
currently rendered and charged to Applicant's customers.
V.
Attached hereto as Attachment 2 are copies of Applicant's new proposed Schedule
Numbers 1, 1B, 2 and 3 setting forth changes to be made to Applicant's customers rates on and
after December 23, 2024, as requested in this Application.
VI.
Applicant proposes to increase rates by $11,158,946. This represents an overall average
increase of 19.84% over Veolia Water Idaho's rates as approved by the Commission in 2022.
Applicant proposes a two-phase rate plan, with 70% of the requested increase to be effective
APPLICATION OF VEOLIA WATER IDAHO,INC. PAGE 2 OF 7

December 23, 2024 and the remaining 30% of the requested increase to be effective twelve
months later on December 23, 2025.
Veolia Water Idaho submits that the proposed changes in rates and charges set forth on
Attachment 2 are just and reasonable. The expected rate of return under the revised rates and
charges will be 7.47%, which is a fair rate of return on Veolia Water Idaho's investment in
property used and useful in rendering water service.
VII.
The revenue realized by Applicant under its presently authorized rates produces a rate of
return of 4.78%based on a historical year ending August 31, 2024. Applicant seeks additional
revenues to recover increased operating expenses and costs associated with plant additions, and
to produce a fair rate of return, thereby enabling it to continue to provide adequate and reliable
service to its customers.
VIII.
Applicant is proposing a revision to its Rules and Regulations Governing the Rendering
of Water Service to remove Private Fire Hydrant charges from the Tariff; to add a definition of
"private fire hydrant"that improves upon the current definition and that has been vetted by Fire
Districts within Applicant's service territory; and to define the responsibilities associated with
owning a private fire hydrant. Applicant is also proposing to add a 12-inch meter charge under
General Metered Service as a pre-emptive measure and to add President's Day and Juneteenth to
Observed Holidays related to reconnection availability/charges. In addition, Applicant is
proposing to update the manner in which service requests may be taken to include online or
personal visit to the applicant office by appointment; to update language to confirm the normal
routing for water main extensions shall be in dedicated public rights-of ways; and to specify that
APPLICATION OF VEOLIA WATER IDAHO,INC. PAGE 3 OF 7

an applicant to Veolia Water Idaho agrees not to lay other pipes or conduits within Eve (5') feet,
measured horizontally, from water pipes as discussed in the testimony of witness Johns.
IX.
Applicant is filing concurrently herewith Direct Testimony of David Johns, Harold
Walker, III, Timothy Michaelson, Michael Wilson, Lino Bucci, Anupa Jacob, Catherine Cooper,
Katherine Arp, David Njuguna, James Cagle, Maryanne Hatch, Ian MacDougall, and Exhibit 1
through Exhibit 14. These Exhibits include financial statements, revenue analysis, analysis of
cost of service, and supporting work papers that justify and support the proposed increase.
X.
Applicant proposes to implement the requested increase in revenue by a uniform
percentage increase to all rate elements, except for private fire rates, which would see no
increase as outlined in the Testimony of Timothy Michaelson and supported by the results of the
Class Cost of Service Study further explained in the Testimony of Maryanne Hatch.
XI.
Notice to Veolia Water Idaho's customers is being accomplished by news media releases
simultaneously with the filing of this Application and by an individual notice mailed to each
customer. Copies of the press release and customer notice are attached to this Application as
Attachment 3. In addition, a copy of the Application and Applicant's present and proposed rate
schedules are available for public inspection at its office at 8248 West Victory Road, Boise,
Idaho at any time during office hours. The Application will be available on the Commission's
website at www.pue.idaho.gov. Customers may also subscribe to the Commission's RSS feed to
receive periodic updates.
APPLICATION OF VEOLIA WATER IDAHO,INC. PAGE 4 OF 7

XII.
Applicant stands ready for an immediate hearing on this Application and requests that a
hearing be held as soon as possible.
XIII.
Communications in reference to this Application should be addressed to:
Preston N. Carter(ISB No. 8462)
Morgan D. Goodin(ISB No. 11184)
Megann E. Meier(ISB No. 11948)
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarter(a) i_ig venspursley.com
morgan o�(a�givenspursle.
merrig ig venspursley.com
and
David Njuguna
Director-Regulatory Business
Veolia Water M&S (Paramus), Inc.
461 From Road, Suite 400
Paramus,NJ 07052
david.njuguna(a,veolia.com
Veolia Water Idaho respectfully requests:
1. That this Application be heard and acted upon at the earliest possible date,
2. That the Commission find that the Applicant's existing rates are unjust, unreasonable
and insufficient to provide Applicant with a fair rate of return and that the revised
rates and charges proposed in Attachment 2 of this Application are just and
reasonable and that Applicant be permitted to charge said rates to its customers,
effective December 23, 2024.
APPLICATION OF VEOLIA WATER IDAHO,INC. PAGE 5 OF 7

3. That the Commission grant such other and further relief as the Commission may
determine proper in the circumstances.
Date: November 22, 2024.
VEOLIA WATER IDAHO,INC.
Preston N. Carter
Attorney for Veolia Water Idaho, Inc.
APPLICATION OF VEOLIA WATER IDAHO,INC. PAGE 6 OF 7

CERTIFICATE OF SERVICE
I certify that on November 22, 2024, 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
Monica Barrios-Sanchez, Commission Secretary [e-mail]
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Dayn Hardie [e-mail]
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Preston N. Carter
APPLICATION OF VEOLIA WATER IDAHO,INC. PAGE 7 OF 7