20241122Direct Catherine Cooper_Exhibits.pdf

RECEIVED
Friday, November 22, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Megann E. Meier, ISB No. 11948
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
18557801.1 [30.264]
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
DIRECT TESTIMONY OF CATHERINE COOPER
FOR VEOLIA WATER IDAHO,INC.
NOVEMBER 22,2024

I INTRODUCTION
2 Q. Please state your name, occupation and business address.
3 A. My name is Catherine Cooper. I am the Director of Engineering for Veolia Water Idaho,
4 Inc. ("Veolia Water Idaho" or"Company"). My business address is 8248 W. Victory
5 Road, Boise, Idaho 83709.
6 Q. Please summarize your educational background and professional experience.
7 A. I am a graduate of the University of Colorado at Boulder with a Bachelor of Science in
8 Civil Engineering. I completed my Master of Science in Civil Engineering at the
9 University of Washington in Seattle. I have been a licensed Professional Engineer in the
10 State of Idaho since 1999.
11 1 have been employed as a civil engineer for 30 years. My work experience
12 includes 22 years at Boise area consulting firms where I focused on water system
13 engineering. My experience includes preparing detailed hydraulic calculations; designs for
14 storage tanks,pump stations, pressure reducing stations,pipelines, and well houses; water
15 system Master Facility plans; hydraulic models; and project cost estimates. I was an
16 Owner and Managing Partner at my last consulting firm.
17 1 have been employed by Veolia Water Idaho (formerly Suez) since July 2016 as
18 the Director of Engineering. As the Director of Engineering, I have oversight over the
19 Company's capital expenditure budget and short and long-term facility and water supply
20 planning. In addition, I manage selected engineering projects for the Company.
21 Q. What is the purpose of your testimony?
22 A. I will discuss these topics:
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C. COOPER,DI
VEOLIA WATER IDAHO,INC.

I • Pro forma adjustments to Plant in Service, Contributions in Aid of Construction
2 (CIAC), and retirements from the historic test year(ending August 31, 2024) for plant
3 in service through December 31, 2024;
4 • Purchased water expense and adjustments thereto as it relates to drought protection and
5 weather conditions;
6 • Anticipated PFAS related projects to meet the new EPA regulations around PFAS that
7 will take effect in April 2027 and be implemented through 2029.
8 Q. What Exhibits are you sponsoring?
9 A. I am sponsoring the following Exhibits:
10 1. Exhibit No. 3 - Test Year Period Plant Additions and Retirements
11 2. Exhibit No. 4 - Purchased Water
12 PROFORMA ADJUSTMENTS TO PLANT IN SERVICE
13 Q. Since the last proceeding has the Company continued to invest in utility plant in
14 service?
15 A. Yes. The total plant in service investment net of CIAC from January 1, 2023 to December
16 31, 2024 is approximately $74 million, an increase of about 13% over the Company's
17 Plant in Service at January 1, 2023 of approximately $571 million. The company continues
18 to provide new and replacement utility plant in all areas of the business including source of
19 supply, water treatment, pumping, transmission and distribution mains, distribution
20 storage, customer service lines, customer meters, information technology, and general
21 plant.
22 As of August 31, 2024, the Plant in Service balance net of CIAC was $504 million.
23 Projected Additions to Plant in Service from September 1 through December 31, 2024 will
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C. COOPER,DI
VEOLIA WATER IDAHO,INC.

I be $14.7 million. As of December 31, 2024, the balance of Plant in Service is $651 million
2 and CIAC will be $132.5 million.
3 Q. Are these plant in service additions used and useful in providing service to the
4 Company's customers?
5 A. Yes. Additionally, the projects included in pro forma Rate Base from September 1, 2024
6 through December 31, 2024 will also be in service by December 31, 2024.
7 Q. In general terms,what do the capital additions planned to be placed in service from
8 September 1, 2024 through December 31, 2024, relate to?
9 A. The capital additions include source of supply, meters and services, pumping equipment,
10 new and replacement mains, treatment equipment, control equipment, facility
11 improvements, engineering studies, and information technology systems which represent
12 normal ongoing capital improvements. The pro forma plant additions for this time period
13 are detailed in two locations with associated exhibits. Plant in service additions for the
14 period of September 1, 2024, to December 31, 2024, are summarized by account number
15 in Exhibit No. 11, Schedule 3 sponsored by Witness Arp, and are also listed by project
16 name on the attached Exhibit No. 3.
17 Q. Does Exhibit No. 3 also show retirements, cost of removal and salvage for the pro
18 forma period?
19 A. Yes. The retirements include wells, service lines, meters, pumping equipment, mains,
20 treatment equipment, control equipment, information technology equipment, and facility
21 improvements. The cost of removal is included for additions that involve removing an
22 existing asset. In some cases there is no existing asset to remove with the plant addition.
23 Salvage value is included for assets that are anticipated to have an actual salvage value.
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C. COOPER,DI
VEOLIA WATER IDAHO,INC.

I Q. Will these plant additions be in service by the end of the pro forma period?
2 A. Yes. These plant additions are underway and/or planned for completion by the end of the
3 pro forma period, December 31, 2024.
4 Q. Will the plant additions shown on Exhibit No. 3 be used and useful in providing
5 service to the Company's customers?
6 A. Yes.
7 PURCHASED WATER EXPENSE
8 Q. Please discuss the basis for Veolia Water Idaho's purchased water expense in the pro
9 forma amount of$433,064 as shown on Exhibit 4.
10 A. The annual cost of surface water is dependent on multiple factors including snowpack,
11 drought conditions, and summer high temperatures. The test year(September 1, 2023 to
12 August 31, 2024)purchased water cost was $433,064. The test year purchased water costs
13 are described in Company Witness Bucci's testimony, Exhibit 10, Schedule 1, Adjustment
14 No. 9.
15 Veolia Water Idaho's surface water portfolio is diverse, balanced across natural
16 flow water rights, storage contracts, exchanges, irrigation district shares both owned and
17 leased, and long term rental pool lease agreements. Short term (one season) rental pool
18 and natural flow rentals are used to make up any shortfalls in surface water supply for the
19 year when necessary -none of these were included in the test year costs.
20 Veolia Water Idaho anticipates the water market in the Valley will tighten as
21 growth continues over the coming decades. In addition, drought and flood conditions may
22 be exacerbated as an effect of climate change. With this in mind, Veolia Water Idaho is
23 working towards more permanent surface water arrangements to solidify surface water
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C. COOPER,DI
VEOLIA WATER IDAHO,INC.

I availability over the long-term for our customers. Natural flow rights, where available, are
2 favored over storage rights that may be more susceptible to drought conditions. Purchases
3 are preferred over leases. Veolia Water Idaho added additional rental storage since the
4 drought conditions of 2021 in order to help protect our customers against dry years.
5 Q. Are the lease/contract costs generally known and measurable related to purchased
6 water expense?
7 A. Yes, the costs are generally known and measurable. These agreements have been executed
8 or are in planning/progress and are shown on Exhibit No. 4.
9 Q. Do you believe $433,064 as depicted on Exhibit No. 4 is a reasonable allowance for
10 purchased water expense for rate making purposes?
11 A. Yes. The costs generally stay the same for several years at a time and are known, although
12 drought conditions, growth, rising costs, or other factors could affect costs over time.
13 PFAS RELATED PROJECTS
14 Q. Please describe the EPA's PFAS rule,which is anticipated to take effect in April
15 2027?
16 A. Yes. On April 26, 2024, EPA published the final National Primary Drinking Water
17 Regulation for six PFAS.1 The PFAS rule sets maximum contaminant levels (MCLs) for
18 PFOS and PFOA of 4 parts per trillion in drinking water for each contaminant. The rule
19 also sets MCLs for three other PFAS and a calculation method for a mixture of PFAS.
20 Water systems must monitor for these HAS and have 3 years to complete initial
21 monitoring (by April 2027). They have 5 years (by April 2029) to implement solutions
1 To date,multiple legal challenges have been filed against the EPA's final rule.
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VEOLIA WATER IDAHO,INC.

I that reduce these PFAS if monitoring shows that drinking water exceeds these limits.
2 Veolia Water Idaho has been conducting preliminary testing in order to be ready for the
3 rule implementation in 2027.
4 Q. What measures does the Company anticipate will need to be implemented due to the
5 EPA's PFAS rule?
6 A. Currently, the Company anticipates that measures will be needed to comply with the EPA
7 rule; we are currently assessing those needs. This assessment will continue so that the
8 Company can comply with the rule.
9 Q. Are there any capital projects related to PFAS that are included in this rate case?
10 A. Yes. There are several initial PFAS projects that are already complete (or will be complete
I I by December 31, 2024) and are included in this rate case. These include: PFAS Planning
12 Study of approximately $48,600, PFAS Projects - Well Profiling of approximately
13 $176,000, PFAS Projects - Treatability Study of approximately $430,000, and PFAS
14 Projects -Well Lube Line Automation of approximately $144,500.
15 Q. Does this conclude your testimony?
16 A. Yes.
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C. COOPER,DI
VEOLIA WATER IDAHO,INC.

Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Megann E. Meier, ISB No. 11948
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
18557695.1 [30-264]
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
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
EXHIBIT TO ACCOMPANY THE
DIRECT TESTIMONY OF CATHERINE COOPER

Veolia Water Idaho
Pro Forma Period Plant Additions and Retirements
for September 2024 - December 2024
Forecast
Forecast Forecast Cost of Forecast
Project ID Project Title In Service Date Additions Retirements Removal Salvage
Source of Supply
C20A101 IDWR Rules of Procedure Dec-24 44,084 - - -
C21A105 Payette Storage Exchange Dec-24 8,266 - - -
C21A102 Sherman Oaks New Well Nov-24 1,884,020 - - -
C23A101 Water Rights Dec-24 88,168 - - -
C23K003 Abandon Hummel, Willow Lane#1, Mesa#2 Wells (and other well rehab work) Dec-24 450,759 159,700 151,000 -
C24A109 16th Street Well Rehab Dec-24 201,278 - - -
Subtotals $ 2,676,575 $ 159,700 $ 151,000 $ -
Treatment
C21 B504 CWTP 6 MGD Membrane Replace Already in service 124,207 - - -
C24B503 Chlorination Equipment Dec-24 13,021 5,400 1,000 -
C24B504 Treatment Plant Roll-Up Dec-24 310,778 15,000 4,000 -
C24B505 CL2 Generator Replacement Dec-24 379,283 152,902 2,200 -
Subtotals $ 827,288 $ 173,302 $ 7,200 $
Pumping Plant
C24C101 Pump Equip-Sources of Supply Phase 1 Various 154,792 84,900 2,000 -
C24C106 PFAS Projects - Well Lube Line Automation Nov-24 144,469 - - -
C24C501 Reconstruct Pumping Facilities and Tank Roads Dec-24 140,963 12,000 2,000 -
C24C505 Landscaping Replacement- System Facilities Dec-24 35,563 3,956 500 -
C24C506 System PRV re-builds Dec-24 27,553 4,570 500 -
C24C508 VFD Replacement Dec-24 168,115 32,000 1,000 -
C24C509 EWC Production Roll-up Various 15,621 - - -
C24C515 Pump Equip - Sources of Supply Phase 2 Various 278,525 22,000 1,500 -
C24D901 Master Meter New/Replacement Dec-24 67,726 3,423 2,000 -
Subtotals $ 1,033,326 $ 162,849 $ 9,500 $ -
T & D Mains
C22D101 Five Mile - Seneca to Sandpiper Already in service 167,299 - - -
C22D703 Agency Mains State Nov-24 1,322,284 128,200 10,000 -
C22D706 Agency Mains Grove 9th to 16th Dec-24 872,534 11,751 11000 -
C23C517 Upgrade PRV Stations Sep-24 416,653 - - -
C23D706 Agency Mains Eagle and State Nov-24 1,885,128 5,728 2,200 -
C23D709 Agency Main Rose Hill and Owyhee Dec-24 226,140 8,235 1,000 -
C24D001 Fire Hydrants Various 551,050 - - -
C24D002 New Short Mains &Valves Various 82,658 - - -
C24D502 Replacement Short Mains &Valves/ Blow-Offs Various 132,252 3,000 31,200 -
Subtotals $ 5,655,998 $ 156,913 $ 45,400 $
Services
C241`003 New Fire Services Various 88,168 - - -
C24F505 Domestic Services Various 1,623,393 65,200 70,000 -
Subtotals $ 1,711,561 $ 65,200 $ 70,000 $ -
Meters
C24G501 Replacement Customer Meters Various 137,763 289,200 103,600 9,200
Subtotals $ 137,763 $ 289,200 $ 103,600 $ 9,200
Information Technology (IT)
C24J101 IT Equipment Various 84,858 19,775 220 -
C24J501 Replace I&C Equipment Various 90,168 8,900 500 -
C24J506 SCADA Master Plan Rollup 2024 Dec-24 551,829 15,000 2,000 -
Subtotals $ 726,855 $ 43,675 $ 2,720 $ -
General Plant
C21 K501 Victory Tool Doc Storage Building Dec-24 651,892 - - -
C23C504 Replace Control Equipment Various 27,586 19,200 250 -
C24C502 Replace Control Equipment Dec-24 112,910 28,260 2,100 -
C23J502 Replace I&C Equipment various 124,286 - - -
C23K106 Lead/Copper Service Line Study Dec-24 64,473 - - -
C24K002 Hydraulic Model Updates / UDF Plans Dec-24 44,084 - - -
C24K101 Fleet Vehicles Dec-24 225,931 - - -
C24K104 PFAS Projects -Treatability Study Dec-24 429,819 - - -
C24K105 PFAS Projects -Well Profiling Nov-24 176,336 - - -
C24K501 New and Replacement Tools Various 88,168 6,036 1 -
Subtotals $ 1,945,484 $ 53,496 $ 2,351 $
Gross Plant Adds, Retirements, COR & Salvage $14,714,850 $1,104,335 $391,771 $9,200
CIAC $0
Gross Plant Less CIAC $14,714,850
Developer Refunds $0
Case No. VEO-W-24-01
Exhibit No. 3
C.Cooper
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Veolia Water Idaho - Purchased Water Exhibit 4
Dates: September 1, 2023 - August 31, 2024
ID# UNITS PRICE PER MISC. TOTAL COST COMMENTS
UNIT FEES DURING TEST YEAR
SHARES IN CANAL
Points of diversion at Marden WTP in Thurman
Thurman Mill 46.5 40 $ 1,860.00 Mill name.
Boise City Canal Company- Owned Shares 45 105 $ 4,725.00 Point of diversion at Marden WTP in BCCC name.
Boise City Canal Company- 2020 Owned Shares 400 157.5 $ 63,000.00 Pipeline to Marden WTP from BCCC
Boise City Canal Company- Leased Shares 200 105 $ 21,000.00 Pipeline to Marden WTP from BCCC
Boise Valley Irrigation District 89.3 23.64 35 $ 2,146.00 Point of diversion at Marden WTP in BVID name.
CO NTRACT/LEAS E/STO RAGE
Annual payment same even if not used. Held in
Anderson Ranch Reservoir Bureau of Reclamation Anderson Ranch Reservoir for drought
(1,000 AF) 13205638 10001 24.36 $ 24,360.00 protection and collector miitgation.
Lucky Peak Reservoir Bureau of Reclamation Fixed Rate: Hold for drought. 40 year
Repayment (1,100 AF) 059D101468 1100 15.1588727 $ 16,674.76 repayment contract (ends 12/31/2046)
Lucky Peak Reservoir Bureau of Reclamation
Maintenance (1,100 AF) 1100 7.30 $ 8,030.00 BOR estimates O&M yearly and updates costs.
BASIN 63 RENTAL POOL/WATER BANK
Volume rented varies with snow pack and ability
Annual Basin 63 Rental Pool 12000 23 $ 276,000.00 to get commitments from other space holders.
INCENTIVE PAYMENTS TO BASIN 63 SPACE HOLDERS
Pay Space Holders that put water into the rental pool $ 11,500.00 Boise Valley Irrigation Ditch Company
OTHER
Three Veolia Water Idaho customers on Joplin
Garden City-Joplin $ 2,369.36 Street get their water from the GC system.
Annual assessment to the WD overseeing the
Water District 63 Annual Assessment $ 1,398.38 Boise River.
Total $ 433,063.50
Case No. VEO-W-24-01
Exhibit No.4
C.Cooper
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