20241213Staff 41-62 to VEO.pdf

RECEIVED
Friday, December 13, 2024 12:19:36 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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
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 ) SECOND 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
FRIDAY,JANUARY 3, 2025.
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.
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 1 DECEMBER 13, 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. 41: Please provide supporting workpaper(s), in Excel format with
formulas intact, for Management & Service ("M&S") Fee Adjustment No. 19. Please update
workpaper(s)with actual amounts as data become available.
REQUEST NO. 42: Please identify the hardware or software that is included in M&S
fees and the associated cost. Please include ongoing subscription costs and upgrade fees for
each.
REQUEST NO. 43: Please provide a description of the work that was provided by each
of the M&S Shared Services departments including the number of employees and amount of
time allocated to each service, and the resources used to complete the work performed in direct
support of the Company.
REQUEST NO. 44: Please provide the following for each employee that allocated time
to the Company that is included in M&S fees:
a. Number of hours spent in direct support of the Company; and
b. Percentage pay increase received per year since hired.
REQUEST NO. 45: Please provide a copy of the Company's most recent Cityworks
contract.
REQUEST NO. 46: Please provide Cityworks annual software subscription cost and
annual software support cost. Please also itemize current Cityworks licenses, the status of each,
and annual Cityworks licensing cost per employee.
REQUEST NO. 47: Please provide copies of the Company's 2023 and 2024 SOX Audit
reports and a description of the steps taken to address any issues identified within the audit
reports or as a result of the audit process.
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 2 DECEMBER 13, 2024

REQUEST NO. 48: For any grant or federal funding awarded or pending distribution to
benefit the Company,please provide the following:
a. Name of the grant or funding program;
b. Amount awarded;
c. Account the funds were allocated to; and
d. Explanation of why the allocation of funds was appropriate.
REQUEST NO. 49: What is the Company's post construction evaluation process for
general contractors?
REQUEST NO. 50: What criteria does the Company use to determine if a general or
sub-contractor is eligible to bid or be awarded a construction contract?
REQUEST NO. 51: Please respond to the following requests for the Columbia Water
Treatment Plant Membrane Replacement and Expansion project referenced in the Direct
Testimony of David Johns. Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project including the served
area's population and water demand forecast justifying the need;
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected. Please provide the Company's
economic analysis (costs and benefits) that justified this project;
c. Please provide measured and requested trans-membrane pressure and permeate flux
data for I year before and after the membrane replacement to justify the replacement
with Excel spreadsheet;
d. If a Request for Proposal ("RFP"), Request for Quote ("RFQ") or Invitation to Bid
("ITB") was published,please provide the following information:
i. A copy of the RFP, RFQ or ITB that was published;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 3 DECEMBER 13, 2024

iv. A copy of the winning bid.
e. Please provide the following for the Baseline Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by Work-Breakdown Structure
("WBS");
iii. Project status reports; and
iv. Contractor change orders.
f. Please provide the following information related to completion of the project:
i. Baseline budget-to-actual comparison by WBS and by year; and
ii. For any budget-to-actual cost overages by major WBS category that is over
five percent,please explain the reason for the differences and provide
evidence that the amount was approved at the appropriate level.
REQUEST NO. 52: Please respond to the following requests for the New Booster
Station, Pressure Reducing Valve in Sage Acres Area, and New Pressure Zones in Northern
Service Territory project referenced in the Direct Testimony of David Johns. Please include any
available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project including the
hydraulic modeling results before and after the project from the pump station to
customers;
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected. Please provide the Company's
economic analysis (costs and benefits) that justified this project;
c. If a RFP, RFQ, or ITB was published, please provide the following information:
i. A copy of the RFP, RFQ or ITB that was published;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the following for the Baseline Project Plan including the following:
i. Baseline project scope;
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 4 DECEMBER 13, 2024

ii. Baseline project budget broken down by WBS;
iii. Project status reports; and
iv. Contractor change orders.
e. Please provide the following information related to completion of the project:
i. Baseline budget-to-actual comparison by WBS and by year; and
ii. For any budget-to-actual cost overages by major WBS category that is over
five percent,please explain the reason for the differences and provide
evidence that the amount was approved at the appropriate level.
REQUEST NO. 53: Please respond to the following requests for the Ustick Pump
Station Upgrade project referenced in the Direct Testimony of David Johns. Please include any
available workpapers with formulas intact:
a. Please provide a detailed explanation for the need of the project including the
hydraulic modeling results before and after the project from the pump station to
customers;
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected. Please provide the Company's
economic analysis (costs and benefits) that justified this project;
c. If a RFP, RFQ, or ITB was published, please provide the following information:
i. A copy of the RFP, RFQ, or ITB that was published;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the following for the Baseline Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Project status reports; and
iv. Contractor change orders.
e. Please provide the following information related to completion of the project:
i. Baseline budget-to-actual comparison by WBS and by year; and
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 5 DECEMBER 13, 2024

ii. For any budget-to-actual cost overages by major WBS category that is over
five percent,please explain the reason for the differences and provide
evidence that the amount was approved at the appropriate level.
REQUEST NO. 54: Please respond to the following requests for the Redwood Creek
Well Capacity Expansion project referenced in the Direct Testimony of David Johns. Please
include any available workpapers with formulas intact:
a. Please provide a detailed explanation for the need of the project including the served
area's population and water demand forecast justifying the need;
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected. Please provide the Company's
economic analysis (costs and benefits)that justified this project;
c. If a RFP, RFQ, or ITB was published, please provide the following information:
i. A copy of the RFP, RFQ, or ITB that was published;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the following for the Baseline Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Project status reports; and
iv. Contractor change orders.
e. Please provide the following information related to completion of the project:
i. Baseline budget-to-actual comparison by WBS and by year; and
ii. For any budget-to-actual cost overages by major WBS category that is over
five percent,please explain the reason for the differences and provide
evidence that the amount was approved at the appropriate level.
REQUEST NO. 55: Please provide the following information for the Central Bench
Water Main Replacement project described in Company Witness Johns's testimony on page 5:
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 6 DECEMBER 13, 2024

a. Please provide a detailed explanation of the need for the project, and include any
evidence justifying the need;
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected. Please provide the Company's
economic analysis (costs and benefits) that justified this project;
c. Please provide the following information related to the initial project plan:
i. The initial project scope;
ii. The initial project budget,broken out by major cost element; and
iii. The initial authorization by an appropriate company official.
d. If a RFP or RFQ was issued for services or material greater than $250,000, please
provide the following:
i. A detailed explanation of the selection process including the criteria used to
select the project;
ii. The short-list bidder scorecard; and
iii. A copy of the winning bid.
e. Please provide the following information related to completion of the project:
i. A comparison of actual costs to budgeted costs. If actual costs exceeded
budgeted costs by more than 5 percent,please explain the reasons and provide
evidence that an authorized official approved the cost overruns;
ii. The most current construction schedule showing planned and actual progress
for each major feature of work(i.e., a Gantt chart); and
iii. List the major details of any contract change orders.
REQUEST NO. 56: Please provide the following information for the La Grange well
building,piping, and electrical replacement project described in Company Witness Johns's
testimony on page 6:
a. Please provide a detailed explanation of the need for the project, and include any
evidence justifying the need;
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected. Please provide the Company's
economic analysis (costs and benefits) that justified this project;
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 7 DECEMBER 13, 2024

c. Please provide the following information related to the initial project plan:
i. The initial project scope;
ii. The initial project budget,broken out by major cost element; and
iii. The initial authorization by an appropriate company official.
d. If a RFP or RFQ was issued for services or material greater than $250,000, please
provide the following:
i. A detailed explanation of the selection process including the criteria used to
select the project;
ii. The short-list bidder scorecard; and
iii. A copy of the winning bid.
e. Please provide the following information related to completion of the project:
i. A comparison of actual costs to budgeted costs. If actual costs exceeded
budgeted costs by more than 5 percent,please explain the reasons and provide
evidence that an authorized official approved the cost overruns.
ii. The most current construction schedule showing planned and actual progress
for each major feature of work(i.e., a Gantt chart).
iii. List the major details of any contract change orders.
REQUEST NO. 57: Please provide the following information for the Kootenai Water
Main Replacement project described in Company Witness Johns's testimony on page 6:
a. Please provide a detailed explanation of the need for the project, and include any
evidence justifying the need;
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected. Please provide the Company's
economic analysis (costs and benefits) that justified this project;
c. Please provide the following information related to the initial project plan:
i. The initial project scope;
ii. The initial project budget,broken out by major cost element; and
Ili. The initial authorization by an appropriate company official.
d. If a RFP or RFQ was issued for services or material greater than $250,000, please
provide the following:
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 8 DECEMBER 13, 2024

i. A detailed explanation of the selection process including the criteria used to
select the project;
ii. The short-list bidder scorecard; and
iii. A copy of the winning bid.
e. Please provide the following information related to completion of the project:
i. A comparison of actual costs to budgeted costs. If actual costs exceeded
budgeted costs by more than 5 percent,please explain the reasons and provide
evidence that an authorized official approved the cost overruns.
ii. The most current construction schedule showing planned and actual progress
for each major feature of work(i.e., a Gantt chart).
iii. List the major details of any contract change orders.
REQUEST NO. 58: Please provide the following information for the Generator at Eagle
Well Four project described in Company Witness Johns's testimony on page 6:
a. Please provide a detailed explanation of the need for the project, and include any
evidence justifying the need;
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected. Please provide the Company's
economic analysis (costs and benefits) that justified this project;
c. Please provide the following information related to the initial project plan:
i. The initial project scope;
ii. The initial project budget,broken out by major cost element; and
iii. The initial authorization by an appropriate company official.
d. If a RFP or RFQ was issued for services or material greater than $250,000, please
provide the following:
i. A detailed explanation of the selection process including the criteria used to
select the project;
ii. The short-list bidder scorecard; and
iii. A copy of the winning bid.
e. Please provide the following information related to completion of the project:
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 9 DECEMBER 13, 2024

i. A comparison of actual costs to budgeted costs. If actual costs exceeded
budgeted costs by more than 5 percent,please explain the reasons and provide
evidence that an authorized official approved the cost overruns.
ii. The most current construction schedule showing planned and actual progress
for each major feature of work(i.e., a Gantt chart).
iii. List the major details of any contract change orders.
REQUEST NO. 59: For Company Witness Cooper's testimony about"PFAS Related
Projects" on pages 5-6,please provide the following:
a. For each of the four PFAS projects,please explain the project's purpose and scope
and how it contributes to compliance with the EPA rule;
b. For each of the four PFAS projects,please explain why the Company believes it is in
use and useful, and should be included as plant in service; and
c. Please provide a copy of the PFAS Planning Study.
REQUEST NO. 60: Company Witness Cooper testifies that the Company's Plant in
Service on January 1, 2023, was approximately $571 million, and that the Company will add
approximately $74 million through December 31, 2024. Company Witness C000per also states
that"as of December 31, 2024, the balance of Plant in Service is $651 million." Cooper Direct
at 2-3. Because $571 million plus $74 million equals $645 million, please reconcile this with the
$651 million projected balance.
REQUEST NO. 61: Please provide the following information for the Five Mile Road
New Pipe Installation (Seneca to Sandpiper) described in Company Witness Johns's testimony
on page 5:
a. Please provide a detailed explanation of the need for the project, and include any
evidence justifying the need;
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected. Please provide the Company's
economic analysis (costs and benefits) that justified this project;
c. Please provide the following information related to the initial project plan:
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 10 DECEMBER 13, 2024

i. The initial project scope;
ii. The initial project budget,broken out by major cost element; and
iii. The initial authorization by an appropriate company official.
d. For any RFP or RFQ,please provide the following:
i. A detailed explanation of the selection process including the criteria used to
select the winning bid;
ii. The short-list bidder scorecard;
iii. A copy of the winning bid; and
iv. A copy of the contract.
e. Please provide the following information related to execution and completion of the
project:
i. Copy of both the initial and most current construction schedule showing
planned and actual progress for each major feature of work(i.e., a Gantt
chart);
ii. Copies of status reports provided by General Contractor and or Project
Manager to the Company;
iii. Copy of all executed change orders and contract amendments;
iv. Copies of invoices and the related documentation from General Contractor
and or Sub Contractors;
V. Copies of all incurred fees, fines, and penalties associated with execution of
the project;
vi. Copies of all communications between the Company and General Contractor
related to fees, fines,penalties, delays, as well as schedule and cost
adjustments; and
vii. If actual costs exceeded budgeted costs by more than five percent,please
explain the reasons and provide evidence that an authorized official approved
the cost overruns.
REQUEST NO. 62: Please provide the following information for the New Vactor
Truck described in Company Witness Johns's testimony on page 5:
a. Please provide a detailed explanation of the need for the vehicle, and include any
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. I I DECEMBER 13, 2024

evidence justifying the need;
b. Copies of all quotes received;
c. If any modifications were made to the vehicle, provide detailed description,
justification, and cost for each; and
d. Provide a copy of the invoice and payment plan.
DATED at Boise, Idaho, this 13' day of December 2024.
6-t-A f
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\VEO-W-24-01 PR#2.docx
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 12 DECEMBER 13, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF DECEMBER 2024,
SERVED THE FOREGOING SECOND 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.njugunakveolia.com
E-MAIL: prestoncarterggivenspursley.com
morgangooding ig venspursle co
mem(a�,givenspursley.corri
stgphaniewk ig venspursle
AATRICIA JORD ECRETARY
CERTIFICATE OF SERVICE