20241126Staff to VEO 1-40.pdf

RECEIVED
2024 NOVEMBER 26
CHRIS BURDIN IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
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
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF VEOLIA WATER )
IDAHO, INC.'S APPLICATION TO ) CASE NO. VEO-W-24-01
INCREASE ITS RATES AND CHARGES FOR )
WATER SERVICE IN THE STATE OF )
IDAHO ) FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO VEOLIA WATER IDAHO,
INC.
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Veolia Water Idaho, Inc. ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY,DECEMBER 17, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 1 NOVEMBER 26, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide copies of the monthly trial balances from January 1,
2023, through the most current month available. Please supplement your response when
additional months become available through 2024 and 2025.
REQUEST NO. 2: Please provide a copy of the Company's Chart of Accounts.
REQUEST NO. 3: Please provide a list of all external attorneys who performed services
for the Company or who were paid by the Company for services during 2023 and 2024 to date.
Please list the amounts paid, accounts charged, and date of payment. Please also provide a
summary of the services performed. If services were performed in support of a docketed
federal/state court or regulatory action,please identify the case name, case number, and
jurisdiction.
REQUEST NO. 4: Please provide the total amount that the Company spent on the
following activities for 2023 and 2024 to date, and show how the Company allocated the
amounts between its operating division and the rest of the Company and its subsidiaries:
a. The Company's annual report;
b. Rating agencies;
c. All software or information system-related issues;
d. Board of Directors compensation, travel expenses, and meeting expenses;
e. Travel and training for all shared executives of Veolia North America and affiliates;
f. Insurance coverage;
g. Overhead items including utilities, property taxes, security services, and other
corporate headquarter expenses; and
h. All other allocated or shared expenses.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 2 NOVEMBER 26, 2024

REQUEST NO. 5: Please provide an analysis of any sales of land and/or plant for the
years 2023 through 2024 to date, if any. Please show gains, losses, and supporting
documentation including accounting entries for removal of items from rate base.
REQUEST NO. 6: Please provide details of any planned sales of land and/or plant for
2023 and 2024 to date if any. Please include within your response the estimated date of these
sales and the planned accounting treatment.
REQUEST NO. 7: Please provide a list of"out-of-period adjustments" and
"extraordinary items" for the years 2023 and 2024 to date.
REQUEST NO. 8: Please provide a schedule showing injuries and damages claims for
the years 2023 and 2024 to date. Please include within your response the description of each
item, the amount for each item, and the account charged.
REQUEST NO. 9: Please provide a listing and websites of all organizations the
Company participates in and the costs of participating in those organizations (e.g.NAWC, IACI,
etc.). If the costs are allocated from a parent company,please illustrate how the amounts were
allocated.
REQUEST NO. 10: Please provide a list of all advertising expenses recorded above the
line, including account and subaccounts, where posted, dates posted, vendor names,
explanations, and amounts posted during 2023 and 2024.
REQUEST NO. 11: Please provide copies of all advertisements used during 2023 and
2024 and correlate the advertisement with the specific detail provided in the Company's
response to Request No. 10.
REQUEST NO. 12: Please provide copies of all billing inserts for 2023 and 2024 and
indicate the date they were sent. Please also provide a schedule showing the amount and account
numbers charged for all costs to produce, print, and distribute the inserts.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 3 NOVEMBER 26, 2024

REQUEST NO. 13: Please provide copies of the monthly, quarterly, and annual
comparison of operating and capital budget to actual expenditures for 2023 and 2024 as data
become available. Please include within your response a narrative explanation for budget
variations. This should include, but not be limited to,written operating and capital budget
variance reports and explanations used by Company officers and managers to monitor and
control budgets under their responsibility. Please supplement your response as additional
information becomes available through 2025.
REQUEST NO. 14: Please provide a list of all leased items in 2023 and 2024 to date.
Please separate capital leases from operating leases and show the dates, terms, amounts, and
accounts used for each lease.
REQUEST NO. 15: Please provide a schedule of prepaid items for 2023 and 2024 to
date showing amounts posted, vendor names, explanations, and accounts to which these items
were booked. Please include within your response any significant changes to prepaid items
occurring or planned to occur in 2023 and 2024.
REQUEST NO. 16: Please provide the following direct labor related information as
recorded for the twelve months ending December 31, 2023, and December 31, 2024.
Information, where applicable, should be listed by O&M expense, other expense, construction,
and other account groups. The response should include wages and salaries for each employee
category (officer, exempt, non-exempt, and union), paid time-off, overtime,bonuses, incentive
pay, and overheads for pension, benefits, and payroll taxes. Please also include average and
year-end number of employees by employee category. Include part-time and temporary
employees as full-time equivalents.
REQUEST NO. 17: Please provide the quantifiable savings from any cost/workforce
reduction programs during the past five years. Please provide any additional workforce
reduction programs planned for 2023 and 2024.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 4 NOVEMBER 26, 2024

REQUEST NO. 18: Please summarize all benefit and retirement plans provided to
Company employees of all classifications. Please also include any changes that have occurred to
the benefits/accruals during the past five years.
REQUEST NO. 19: Please provide copies of the Company's pension and actuarial
reports for the years 2023 and 2024. Also,please provide any actuarial calculations and
documentation that shows the development of FAS 87 expenses (ASC 715 Compensation -
Retirement Benefits as codified), Company contributions, balances, and assumptions.
REQUEST NO. 20: Please provide access to copies of all studies used to determine
employee compensation, including executive compensation, and explanations of how the
Company applied them in the years 2023 and 2024 to date.
REQUEST NO. 21: Please provide the yearly percentage pay rate increase by employee
and position since the last general rate case in 2022. Please provide in an excel spreadsheet with
formulas intact.
REQUEST NO. 22: Please provide a schedule showing the estimated external rate case
expenses the Company expects to incur for the preparation and processing of this case.
REQUEST NO. 23: Please provide a copy of the Company's property tax bills for 2023
and 2024.
REQUEST NO. 24: Please provide all Company Bank Statements for 2023 and 2024.
REQUEST NO. 25: Please provide statements for any Company credit cards that
include spending during 2023 and 2024 to date.
REQUEST NO. 26: Please provide a list of all property that the Company leases to
others. Please include lease revenue and provide copies of all lease contracts.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 5 NOVEMBER 26, 2024

REQUEST NO. 27: Please list all the Company's long-term debt issuances. Please
include the following: dates of issuance and expiration, amounts,premiums or discounts, interest
rates, dates of pre-payment, and payment schedules for each issuance.
REQUEST NO. 28: Please provide the Company's organizational chart of all related
entities. Include parent company's, subsidiary's, sister companies, etc.
REQUEST NO. 29: Please provide a sortable spreadsheet listing all the fully completed
capital projects placed in service since the end of the test period in the last general rate case
(December 31, 2022) and the last date actual plant-in-service is included in the Company's
Application(end of the Company's Historic Test Year on August 31, 2024. Projects that are
partially placed in service during the Historic Test Year or estimated for completion during the
proforma period SHOULD NOT be included on this list.
Additionally,please identify which projects are unique one-time projects and which are
"blanket"projects that capture multiple recurring smaller projects such as vehicle replacements
or O&M type of projects that are capitalized.
The list should contain the following minimum information for each project:
a. The project unique identification number;
b. The project title;
c. A short description of the project scope;
d. Classification as "one-time" or"blanket"project;
e. The project's primary function (based on standard accounting practices);
f. The initial approved budget for the project;
g. The latest approved budget for the project;
h. The actual expenditures for the project;
i. The final in-service date for the project;
j. Yes or no: the Company solicited contractors to execute some or all of the project;
k. The number of change orders; and
1. The total cost of the change orders.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 6 NOVEMBER 26, 2024

REQUEST NO. 30: Please provide a sortable spreadsheet listing all the projected
capital projects that the Company expects to be placed in service between the last date actual
plant-in-service was included in the Company's Application (end of the Company's Historic Test
Year on August 31, 2024 and the end of the Company's proforma period(end of the Company's
Adjusted Test Year on December 31, 2024. Projects that are partially placed in service during
the Historic Test Year or estimated for completion during the proforma period SHOULD be
included on this list.
Additionally,please identify which projects are unique one-time projects and which are
"blanket"projects that capture multiple recurring smaller projects such as vehicle replacements
or O&M type of projects that are capitalized.
The list should contain the following minimum information for each project:
a. The project unique identification number;
b. The project title;
c. A short description of the project scope;
d. Classification as "one-time" or"blanket"project;
e. The project's primary function (based on standard accounting practices);
f. The initial approved budget for the project;
g. The latest approved budget for the project;
h. The actual expenditures to date for the project;
i. The estimated in-service date for the project;
j. Yes or no: the Company is soliciting contractors to execute some or all of the project;
k. The number of change orders; and
1. The total cost of the change orders.
REQUEST NO. 31: Please provide a matrix identifying the major capital expenditure
approval levels. Please include the dollar level of authorization by employee title, division, and
company. Please also include the dollar level that requires approval by the Board of Directors.
REQUEST NO. 32: Please provide a schedule of all plant retirements since January 1,
2023, including installation date, account, installed cost, estimated depreciable life, cost of
removal, and salvage value, if any.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 7 NOVEMBER 26, 2024

REQUEST NO. 33: Please provide a current hydraulic model of the Company's water
system.
REQUEST NO. 34: Please provide the most recent version of the Company's Drinking
Water Facilities Capital Plan.
REQUEST NO. 35: Please provide a copy of the Company's policy for main
extensions.
REQUEST NO. 36: For each of the Company's wells, please provide the quantity
(gallons)pumped for each month between January 2020 and 2024 to date.
REQUEST NO. 37: Please provide the Idaho Department of Water Resource,unique
identifier(e.g. Well Tag/D-Tag Number) for each of the Company's wells.
REQUEST NO. 38: Please describe the Company's methodology for developing,
contracting, managing, executing, and completing Capital Projects in a least cost manner. Please
provide a copy of all Company policies and procedures documenting the process.
REQUEST NO. 39: Please provide the following for each meter size for each month
from January 2023 through 2024 to date:
a. Number of Billed Customer Charges;
b. Gallons of water provided to customers at no charge as part of the Minimum Charge;
and
c. Gallons sold to customers more than the maximum gallons allowed in the Minimum
Charge.
REQUEST NO. 40: Please provide all the workpapers, models, and data used to derive
the weather normalized amounts of consumption for residential and commercial customers.
Please include in native format with all formula intact.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 8 NOVEMBER 26, 2024

DATED at Boise, Idaho, this 26t" day of November 2024.
0,- , -,A-
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\VEO-W-24-01 PR#l.docx
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 9 NOVEMBER 26, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF NOVEMBER 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO VEOLIA WATER, IDAHO, INC., IN CASE NO. VEO-
W-24-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
PRESTON N CARTER DAVID NJUGUNA
MEGAN D. GOODIN DIRECTOR—REGULATORY BUSINESS
MEGANN E. MEIER VEOLIA WATER M&S (PARAMUS), INC.
GIVENS PURSLEY LLP 461 FROM ROAD, SUITE 400
PO BOX 2720 PARAMUS,NJ 07052
BOISE ID 83701-2720 E-MAIL: david.njuguna(c�r�,veolia.com
E-MAIL: prestoncarter(k i_ venspursley.com
morgan og odin@ ig venspursle,
mem(�b i'g venspursley.com
stephaniew@ ig venspursle.
Keri J. Ha ker
Legal Assistant to Chris Burdin
CERTIFICATE OF SERVICE