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Home My WebLink About20241223Staff to VEO 63-95.pdf RECEIVED December 23, 2024 IDAHO PUBLIC CHRIS BURDIN UTILITIES COMMISSION DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 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 ) THIRD 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 MONDAY,JANUARY 13, 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. THIRD PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 1 DECEMBER 23, 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. 63: Please provide the financial statements for Veolia Utility Resources LLC ("VUR"). REQUEST NO. 64: Please provide the supporting documentation for the capital structure proposed on page 14 of Company Witness Walker's testimony. REQUEST NO. 65: Please provide a list of all subsidiary utilities under VUR. REQUEST NO. 66: For each utility listed in the Company's response to PR No. 65 above,please provide: a. The date the rate case was filed; b. The date the final order was issued; c. The date that the rates took effect; d. Designate if the case was settled or fully litigated; and e. The Return on Equity approved. REQUEST NO. 67: Please provide the dividend policy for the Company issuing dividends to its parent company. REQUEST NO. 68: Please provide the supporting documentation for the VUR embedded debt rate of 4.43%. REQUEST NO. 69: Please provide the supporting documentation for the VUR capital structure. REQUEST NO. 70: Referencing Company Witness Walker's Exhibit No. 1 Schedule 13, please provide the methodology used that would create the variation in the historical 5-year growth in EPS between analysts. THIRD PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 2 DECEMBER 23, 2024 REQUEST NO. 71: Please provide a copy of the Company's Annual Incentive Plan and include score cards for each employee who achieved target goals. REQUEST NO. 72: Please provide a copy of the current bargaining unit contract. REQUEST NO. 73: With reference to Company Witness Wilson Direct Testimony, please provide the following workpapers and source documents (invoices, emails, reports, etc.) for the following adjustments, in native format with formulas intact: a. Adjustment No. 1 —Payroll; b. Adjustment No. 2—Workers Compensation; c. Adjustment No. 8 —Payroll Overheads (Fringe Benefit Allocation); d. Adjustment No. 10—Energy- Purchased Power& Other Utilities; e. Adjustment No. 11 —Chemicals; f. Adjustment No. 12— Subcontractors; g. Adjustment No. 16—Vehicle Allocation; h. Adjustment No. 17—Office Expenses; i. Adjustment No. 22— Safety; and j. Adjustment No. 29—Adjustment to Variable Expenses Due to Volume Normalization. REQUEST NO. 74: Please provide a list of all subcontractors used in 2023 and 2024. Please include in your response the process of hiring subcontractors and the managers involved in making the final decisions. REQUEST NO. 75: Please provide a narrative explaining the E-Payment Convenience Fee, found in Company Exhibit No. 10, Page 12 Subcontractors, Line No. 10. REQUEST NO. 76: With reference to Exhibit No. 10, Schedule 1, Adjustment 16 - Vehicle Allocation,please provide supporting documentation for the following transportation expenses. Please verify that the mechanic's payroll has not been already included in the Payroll Adjustment. THIRD PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 3 DECEMBER 23, 2024 a. Mechanic's payroll and benefits; b. Lease Cost; c. Fuel; d. Material, Maintenance; e. Auto Insurance; and f. Other Costs. REQUEST NO. 77: Please provide mechanical logs for repairs and maintenance on vehicles for 2023 through 2024. REQUEST NO. 78: Please provide a schedule showing the year, make, and model of the Company's current fleet of vehicles. For each vehicle,please state whether it is leased or owned by the Company, along with the purchase price and net book value. In addition, please include the lease contract for all leased vehicles. REQUEST NO. 79: Regarding vehicle replacement, please provide a copy of the Company's vehicle replacement policy and any studies the Company has carried out since the last general rate case. REQUEST NO. 80: With reference to Adjustment 23 -Amortization Expenses - Deferred Rate Case,please provide a schedule showing actual rate case costs incurred to date, including the entity paid and the service that entity provided. Please supplement this response each month as additional costs are incurred. REQUEST NO. 81: Please provide a copy of the Company credit card and purchase card policy. REQUEST NO. 82: Please provide the contracts with any cellular providers used by the Company. THIRD PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 4 DECEMBER 23, 2024 REQUEST NO. 83: Please provide the transaction detail reports for the following Cost Element Category accounts for Office Expense Account No. 50650, for the historical test year that ended August 31, 2024, in Excel format with formulas intact: a. 701016—Other Office Expense (Cityworks, Technology); b. 701005 —Dues and Subscriptions (NAWC, AWWA, etc.); c. 701014—Hotel and Lodging; and d. 701006—Licenses and Fees. REQUEST NO. 84: Please provide the transaction detail reports for the following accounts, for the historical test year that ended August 31, 2024, in Excel format with formulas intact: a. 150-151 et al—Materials and Supplies Inventory; b. 162-165 et al—Prepaid Expenses—Other (Prepayments); c. 90400&90405 —Bad Debt& Bad Debt Reserve; d. 92300—Bank Charges; and e. 92450— Severance Plan. REQUEST NO. 85: With reference to Adjustment 18 -Advertising,please provide the transaction detail report for Advertising Account 50651, for the historical test year that ended August 31, 2024, in Excel format with formulas intact. REQUEST NO. 86: Please provide a list of all worker's compensation insurance claims that Veolia paid for the test year. REQUEST NO. 87: For Company Exhibit No. 10. Page 23, Amortization Expense - Deferred Rate Case, please provide an itemized list of Miscellaneous & Other Costs in excel format. REQUEST NO. 88: Please provide a copy of each purchased water lease/contract with the following entities: a. Basin 63 Rental Pool/Water Bank; THIRD PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 5 DECEMBER 23, 2024 b. Boise City Canal Company—2020 Owned Shares; c. Boise Valley Irrigation District; and d. Anderson Ranch reservoir Bureau of Reclamation (1,000 AF). REQUEST NO. 89: In reference to Company Witness David Johns testimony, Page 7, Lines 1 — 16, regarding community engagement, conservation, and customer outreach,please provide total costs spent year-to-date, amount included in the Application, and the line number the expense can be found in Exhibit No. 10. REQUEST NO. 90: In reference to Company Witness David Johns' testimony, Page 12, Lines 8-22,please provide the Idaho Department of Environmental Quality's Improved Lead and Copper Rule regulatory requirements and specifically include where it requires an annual voluntary postcard campaign to determine customer's unknown service line material. REQUEST NO. 91: Please explain the rate that a customer currently receiving the discounted Eagle Water rate would pay if they moved to another service address within the area formerly serviced by Eagle Water Company. REQUEST NO. 92: Please provide a map of all private fire hydrants served by the Company's system. REQUEST NO. 93: Please explain if the Company currently provides service to any customers under Schedule No. 113, Flat Rate Service. If so,please provide the Company Exhibit and Schedule that includes the number of bills and revenue from these customers. REQUEST NO. 94: Please refer to the Testimony of Timothy Michaelson, Exhibit 5, Schedule No. 3 —Eagle Exist, and Schedule No. 3 —Eagle New. Please explain why the rows under"Summer Usage" are labeled"Up to 3 CCF" and"Over 3 CCF"when the volume charge for these customers changes at 1.5 CCF. THIRD PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 6 DECEMBER 23, 2024 REQUEST NO. 95: Please provide updates to all Exhibits and workpapers that are affected by the rate change that goes into effect on January 1, 2025, to existing customers taking service in the area formerly serviced by Eagle Water Company as of January 1, 2022. DATED at Boise, Idaho, this 23rd day of December 2024. 0 Chris Burdin Deputy Attorney General I:\Utility\UMISC\PRDREQ\VEO-W-24-01 PR#3.docx THIRD PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 7 DECEMBER 23, 2024 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF DECEMBER 2024, SERVED THE FOREGOING THIRD 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 HAWKER, SECRETARY CERTIFICATE OF SERVICE