20250107Staff 96-134 to VEO.pdf

RECEIVED
Tuesday, January 7, 2025 11:18:15 AM
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 ) FOURTH 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,JANUARY 28, 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.
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 1 JANUARY 7, 2025

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. 96: Please provide the following information for project C22D710_060
(Exec-FY22 Phase 1 Main Replace) listed in the Company's attachment to its response to
Production Request No. 29:
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 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 Request for Proposal ("RFP") or Request for Quote ("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 related to completion of the project:
i. A breakdown of the final project expenditures. Separately show the additional
markups such as the Allowance for Funds Used During Construction
("AFUDC"), local overhead, and corporate overhead; and
ii. List the major details of the contract change order.
REQUEST NO. 97: Please provide the following information for project C22D609_060
(Exec-T&D Main Replacements) listed in the Company's attachment to its response to
Production Request No. 29:
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 2 JANUARY 7, 2025

a. Please provide a detailed explanation of the need for the project and include any
evidence justifying the need. For this project,please provide evidence that the
replaced piping was at its end of life.
b. Please provide a map depicting the pipe sections that were replaced.
c. Please provide the following 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. Please provide the following related to completion of the project:
i. A breakdown of the final project expenditure. Separately show the additional
markups such as the AFUDC, local overhead, and corporate overhead; and
ii. Please explain the reasons for the cost overruns and provide evidence that an
authorized official approved them.
REQUEST NO. 98: Please provide the following information for project C22D705_060
(Exec-1 lth St. Main-River to) listed in the Company's attachment to its response to Production
Request No. 29:
a. Please provide a detailed explanation of the need for the project and include any
evidence justifying the need. For this project,please provide evidence that the
replaced piping was at its end of life.
b. Please provide a map depicting the pipe sections that were replaced.
c. Please provide the following 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. Please provide the following related to completion of the project:
i. A breakdown of the final project expenditures. Separately show the additional
markups such as the AFUDC, local overhead, and corporate overhead.
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 3 JANUARY 7, 2025

REQUEST NO. 99: Please provide the following information for project C23D711_060
(Exec-2023 ACHD Drainage) listed in the Company's attachment to its response to Production
Request No. 29:
a. Please provide a detailed explanation of the need for the project and include any
evidence justifying the need;
b. Please provide the initial project scope and evidence that it was authorized by an
appropriate company official; and
c. Please provide the project scope description from the RFP.
REQUEST NO. 100: Please provide the following information for project
C23D107_060 (Exec-Meridian Interconnect) listed in the Company's attachment to its response
to Production Request No. 29:
a. Please provide the following related to completion of the project:
i. A breakdown of the final project expenditures incurred by Veolia. Separately
show the additional markups such as the AFUDC, local overhead, and corporate
overhead.
ii. A summary of the project expenditures incurred by the City of Meridian.
REQUEST NO. 101: Please provide the following information for project
C23D706_060 (Exec-Eagle & State Replacement) listed in the Company's attachment to its
response to Production Request No. 30:
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 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.
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 4 JANUARY 7, 2025

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
M. A copy of the winning bid.
e. Please provide the following related to completion of the project:
i. A breakdown of the final project expenditures. Separately show the additional
markups such as the AFUDC, local overhead, and corporate overhead.
ii. Explain why the project exceeded its approved budget by nearly 100%.
iii. Provide evidence that an appropriate official approved the cost overrun.
REQUEST NO. 102: Please provide the following information for project
C22D703_060 (Exec-State St 1st to 16th) listed in the Company's attachment to its response to
Production Request No. 30:
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 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 related to completion of the project:
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 5 JANUARY 7, 2025

i. A breakdown of the final project expenditures. Separately show the additional
markups such as the AFUDC, local overhead, and corporate overhead.
REQUEST NO. 103: Please provide the following information for project
C22D706_060 (Exec-Grove St main replacement) listed in the Company's attachment to its
response to Production Request No. 30:
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 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 related to completion of the project:
i. A breakdown of the final project expenditures. Separately show the additional
markups such as the AFUDC, local overhead, and corporate overhead.
REQUEST NO. 104: For each of the following blanket orders,please provide a sortable
list of the underlying work orders that were rolled up into it. Each list should include the
subordinate work order numbers, the titles and descriptions, the expenditures, and the in-service
dates:
a. Blanket Order C23F505_060 Domestic Services;
b. Blanket Order C23D502_060 Replace Short Mains &Valves;
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 6 JANUARY 7, 2025

c. Blanket Order C24F505 060 Domestic Services; and
d. Blanket Order C24D502_060 Replace Short Mains &Valves.
REQUEST NO. 105: Please respond to the following request for the Hillcrest Tank
Replacement project (ID C2IE510_060) referenced by Attachment in response to Production
Request No. 29. Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project including the steel
tank lifespan justifying the need.
b. Please provide a list of all the potential alternatives that the Company considered to
fulfill the need and explain why the project or the material were selected among the
alternatives supported by the Company's economic analysis comparing them.
c. If a RFP, 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;
M. 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; and
ii. Baseline project budget broken down by Work-Breakdown Structure ("WBS").
e. Please provide the following related to completion of the project:
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 29; and
ii. The reason for the differences between the latest approved budget (excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 106: Please respond to the following request for the Pump Equipment—
Sources of Supply(ID C23C101_060)project referenced by Attachment in response to
Production Request No 29. Please include any available workpapers with formulas intact.
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 7 JANUARY 7, 2025

a. Please provide a detailed explanation for the need of the project including the cost,
lifespan, and specification of the equipment.
b. 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.
c. Please provide the following for the Baseline Project Plan including the following:
i. Baseline project scope; and
ii. Baseline project budget broken down by WBS.
d. Please provide the following related to completion of the project
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 29; and
ii. The reason for the differences between the latest approved budget(excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 107: Please respond to the following request for the Pump Equipment—
Sources of Supply(ID C22C101_060)project referenced by Attachment in response to
Production Request No 29. Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project including the cost,
lifespan, and specification of the equipment;
b. If a RFP, RFQ, or ITB was published, please provide the following information:
i. A copy of the RFP or RFQ 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.
c. Please provide the following for the Baseline Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS; and
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 8 JANUARY 7, 2025

iii. Change orders.
d. Please provide the following related to completion of the project:
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 29; and
ii. The reason for the differences between the latest approved budget (excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 108: Please respond to the following request for the CL2 Generator
Replacement(ID C2213507_060)project referenced by Attachment in response to Production
Request No. 29. Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project including the
chlorine generator lifespan justifying the need.
b. 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;
M. The short-list bidder scorecard; and
iv. A copy of the winning bid.
c. Please provide the following for the Baseline Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by VMS; and
iii. Change orders.
d. Please provide the following related to completion of the project:
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 29; and
ii. The reason for the differences between the latest approved budget (excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 109: Please respond to the following request for the CL2 Generator
Replacement(ID C2313505_060)project referenced by Attachment in response to Production
Request No 29. Please include any available workpapers with formulas intact.
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 9 JANUARY 7, 2025

a. Please provide a detailed explanation for the need of the project including the
chlorine generator lifespan justifying the need.
b. 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.
c. Please provide the following for the Baseline Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS; and
iii. Change orders.
d. Please provide the following related to completion of the project:
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 29; and
ii. The reason for the differences between the latest approved budget(excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 110: Please respond to following request for the Bench WQ Master
Plan (ID C21K008_060)project referenced by Attachment in response to Production Request
No. 29. Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project.
b. Please provide the final master plan study report.
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:
i. Baseline project scope;
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 10 JANUARY 7, 2025

ii. Baseline project budget broken down by WBS; and
iii. Change orders.
e. Please provide the following related to completion of the project:
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 29; and
ii. The reason for the differences between the latest approved budget (excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 111: Please respond to following request for the Well Profiling WQ
project(ID C23K108_060)referenced by Attachment in response to Production Request No. 29.
Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project.
b. Please provide the final report.
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; and
iii. Change orders.
e. Please provide the following related to completion of the project
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 29; and
ii. The reason for the differences between the latest approved budget(excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 11 JANUARY 7, 2025

REQUEST NO. 112: Please respond to following request for the Planning Secure site c
project(ID C21A102_060)referenced by Attachment in response to Production Request No. 30.
Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project including served
population forecast and water demand justifying the need.
b. Please provide a list of all the potential alternatives that the Company considered to
fulfill the need and explain why the project was selected among the alternatives
supported by the Company's economic analysis comparing them.
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; and
ill. Change orders.
e. Please provide the following related to completion of the project:
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 30; and
ii. The reason for the differences between the latest approved budget (excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 113: Please respond to following request for the Abandon Several
Wells project (ID C23K003_060) referenced by Attachment in response to Production Request
No. 30. Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project including the reason
for abandoning the wells and whether any other wells are replaced;
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 12 JANUARY 7, 2025

b. Please provide a list of all the potential alternatives that the Company considered to
fulfill the need and explain why the project was selected among the alternatives
supported by the Company's economic analysis comparing them;
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; and
iii. Change orders.
e. Please provide the following related to completion of the project:
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 30; and
ii. The reason for the differences between the latest approved budget (excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 114: Please respond to following request for the Upgrade PRV Stations
project(ID C23C517_060) referenced by Attachment in response to Production Request No. 30.
Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project including the reason
to upgrade the PRV stations.
b. Please provide a list of all the potential alternatives that the Company considered to
fulfill the need and explain why the project was selected among the alternatives
supported by the Company's economic analysis comparing them.
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;
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 13 JANUARY 7, 2025

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; and
Ili. Change orders.
e. Please provide the following related to completion of the project:
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 30; and
ii. The reason for the differences between the latest approved budget (excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 115: Please respond to following request for the Pump Equipment—
SOS Phase 1 project(ID C24C101_060) referenced by Attachment in response to Production
Request No. 30. Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project including the cost,
lifespan, and specification of the equipment.
b. 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.
c. Please provide the following for the Baseline Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS; and
iii. Change orders.
d. Please provide the following related to completion of the project:
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 30; and
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 14 JANUARY 7, 2025

ii. The reason for the differences between the latest approved budget (excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 116: Please respond to following request for the CL2 Generator
Replacement project (ID C2413505_060) referenced by Attachment in response to Production
Request No. 30. Please include any available workpapers with formulas intact.
a. Please provide a detailed explanation for the need of the project including the
chlorine generator lifespan justifying the need.
b. 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.
c. Please provide the following for the Baseline Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS; and
ill. Change orders.
d. Please provide the following related to completion of the project:
i. The breakdown of total expenditure, Column K of the Attachment in response
to Production Request No. 30; and
ii. The reason for the differences between the latest approved budget (excl.
overhead), Column H and total expenditure (incl. overhead), Column K.
REQUEST NO. 117: Please provide the following information for project
C22K101_060 (Fleet Veh 2) listed in the Company's attachment to its response to Production
Request No. 29:
a. Please provide a detailed explanation of the need for the vehicles and include any
evidence justifying the need;
b. Make, model, and age of the asset this item is replacing or"New" if not a
replacement;
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 15 JANUARY 7, 2025

c. Copies of all quotes received;
d. For all modifications made to the vehicles,provide detailed description,justification,
and cost for each;
e. Provide a copy of the invoices and payment plan;
f. The breakdown of total expenditures; and
g. Separately show the additional markups such as the AFUDC, local overhead, and
corporate overhead.
REQUEST NO. 118: Please provide the following information for project
C23KI01_060 (Fleet Vehicles) listed in the Company's attachment to its response to Production
Request No. 29:
a. Please provide a detailed explanation of the need for the vehicles and include any
evidence justifying the need;
b. Make, model, and age of the asset this item is replacing or"New" if not a
replacement;
c. Copies of all quotes received;
d. For all modifications made to the vehicles,provide detailed description,justification,
and cost for each;
e. Provide a copy of the invoices and payment plan;
f. The breakdown of total expenditures; and
g. Separately show the additional markups such as the AFUDC, local overhead, and
corporate overhead.
REQUEST NO. 119: Please provide the following information for project
C24K503_060 (Fleet Rehabs) listed in the Company's attachment to its response to Production
Request No. 29:
a. Please provide a detailed explanation of the need for the project and include any
evidence justifying the need;
b. Copies of all quotes received;
c. For all modifications made to the vehicles,provide detailed description,justification,
and cost for each;
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 16 JANUARY 7, 2025

d. Provide a copy of the invoices and payment plan;
e. The breakdown of total expenditures; and
f. Separately show the additional markups such as the AFUDC, local overhead, and
corporate overhead.
REQUEST NO. 120: Please provide the following information for project
C24KI01_060 (Fleet Vehicles) listed in the Company's attachment to its response to Production
Request No. 30:
a. Please provide a detailed explanation of the need for the vehicles and include any
evidence justifying the need;
b. Make, model, and age of the asset this item is replacing or"New" if not a
replacement;
c. Copies of all quotes received;
d. For all modifications made to the vehicles,provide detailed description,justification,
and cost for each;
e. Provide a copy of the invoices and payment plan;
f. The breakdown of total expenditures; and
g. Separately show the additional markups such as the AFUDC, local overhead, and
corporate overhead.
REQUEST NO. 121: Please provide a sortable list in Excel format of the underlying
work orders that were rolled up into Blanket Order C23D001_060 (Fire Hydrants), Blanket
Order C23G501_060 (Meters), and Blanket Order C2317003_060 (Fire Services)which are listed
in the Company's attachment to its response to Production Request No. 29. Each list should
include:
a. The initial project scope.
b. The breakdown of the original project budget and the method used to develop the
budget.
c. The subordinate work order numbers.
d. The titles and descriptions for each work order.
e. Each work order in-service date.
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 17 JANUARY 7, 2025

f. For any work order that was fulfilled by a sub-contractor please provide the RFP or
RFQ associated with either the blanket order or an individual work order.
g. For any RFP or RFQ please provide the following:
i. A detailed explanation of the selection process including the criteria used for
selection;
ii. The short-list bidder scorecard;
iii. A copy of the winning bid; and
iv. A copy of the contract.
h. The breakdown of the work order expenditures.
i. Explanation for the over estimation or under estimation of the appropriate blanket
budget.
j. Separately show the additional markups such as the AFUDC, local overhead, and
corporate overhead.
REQUEST NO. 122: Please provide a sortable list in Excel format of the underlying
work orders that were rolled up into Blanket Order C24G501_060 (Meters), Blanket Order
C24DO01_060 (Fire Hydrants), and Blanket Order C24F003_060 (Fire Services) which are listed
in the Company's attachment to its response to Production Request No. 30. Each list should
include:
a. The initial project scope.
b. The breakdown of the original project budget and the method used to develop the
budget.
c. The subordinate work order numbers.
d. The titles and descriptions for each work order.
e. Each work order in-service date.
£ For any work order that was fulfilled by a sub-contractor please provide the RFP or
RFQ associated with either the blanket order or an individual work order.
g. For any RFP or RFQ,please provide the following:
i. A detailed explanation of the selection process including the criteria used for
selection;
ii. The short-list bidder scorecard;
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 18 JANUARY 7, 2025

iii. A copy of the winning bid; and
iv. A copy of the contract.
h. The breakdown of the work order expenditures.
i. Explanation for the over estimation or under estimation of the appropriate blanket
budget.
j. Separately show the additional markups such as the AFUDC, local overhead, and
corporate overhead.
REQUEST NO. 123: Please provide the following information for C22KI07_060
(Network GIS and Hyd Study) listed in the Company's attachment to its response to Production
Request No. 29:
a. The initial project scope;
b. A detailed explanation of the need for the project and include any evidence justifying
the need;
c. Explain any anticipated cost savings the results of the study will provide;
d. Explain how the results of this study will benefit the consumer;
e. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected;
f. The breakdown of total expenditures;
g. Separately show the additional markups such as the AFUDC, local overhead, and
corporate overhead; and
h. Please provide the reason for the budget overrun shown in the Attachment in response
to Production Request No. 29.
REQUEST NO. 124: Please provide the following information for C20K502_060
(Concept Planning and Office La) listed in the Company's attachment to its response to
Production Request No. 29:
a. The initial project scope;
b. The breakdown of the original project budget and the method used to develop that
budget;
c. A detailed explanation of the need for the project and include any evidence justifying
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 19 JANUARY 7, 2025

the need;
d. Provide a list of all the potential alternatives the Company considered to fulfill the
need and explain why this project was selected;
e. Explain any anticipated cost savings the project will provide;
f. Explain how the results of this study will benefit the consumer;
g. The breakdown of total expenditures;
h. Separately show the additional markups such as the AFUDC, local overhead, and
corporate overhead; and
i. Please provide the reason this project budget was overestimated by $0.9M as shown
in the Attachment in response to Production Request No. 29.
REQUEST NO. 125: Please provide the following information for C23KO01_060
(Safety Security Upgrades) listed in the Company's attachment to its response to Production
Request No. 30:
a. The initial project scope.
b. A detailed explanation of the need for the project and include any evidence justifying
the need.
c. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why this project was selected.
d. Please provide the Company's economic analysis (costs and benefits) that justified
this project.
e. 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.
f. The breakdown of total expenditures.
g. Separately show the additional markups such as the AFUDC, local overhead, and
corporate overhead.
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 20 JANUARY 7, 2025

REQUEST NO. 126: Please provide a sortable list in Excel format of the purchases
made under C23JI01_060 (IT Equipment) and C24JI01_060 (IT Equipment) listed in the
Company's attachment to its response to Production Request Nos. 29 and 30 respectively. Each
list should include:
a. Items purchased;
b. Dept or group the item is assigned to;
c. Age and identification of the asset this item is replacing or"New" if not a
replacement;
d. List all services or subscriptions associated with the asset;
e. The breakdown of total expenditures;
f. Separately show the additional markups such as the AFUDC, local overhead, and
corporate overhead; and
g. Itemized invoices.
REQUEST NO. 127: While the Application indicates that the Company would like to
remove the Private Fire Hydrant charges from the Tarriff, the intended benefit and purpose of
this change is unclear. Please provide clarification on intent of this request and if this proposed
change will reclassify the Private Fire Hydrant to a Public Fire Hydrant upon completion of
installation.
REQUEST NO. 128: Please provide the following information, if available, for each
project listed in the attached spreadsheet, that was provided in the Company's attachment to its
response to Production Request No. 30:
a. Please provide a detailed explanation of the need for each project and include any
evidence justifying the need;
b. 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; and
c. A transaction list of each cost for each project, so that Staff may select a random
sampling.
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 21 JANUARY 7, 2025

REQUEST NO. 129: Please provide a copy of the Company's overhead calculation in
Excel format with formulas intact.
REQUEST NO. 130: Please provide the supporting documentation for rate case
expenses provided on lines 4-9 in Adjustment No. 23.
REQUEST NO. 131: Please provide the supporting documentation for the deferred
power calculation. (Adjustment No. 27)
REQUEST NO. 132: Please provide the supporting documentation the historic and
repricing of power expense as provided in Line Nos. 2-5 and 8-11 of Adjustment No. 10.
REQUEST NO. 133: Please provide the supporting documentation for the anticipated
demand response rebate in Adjustment No. 10.
REQUEST NO. 134: Please provide the supporting documentation for Line No. 18 in
the Adjustment No. 10.
DATED at Boise, Idaho, this 71h day of January 2025.
k N,
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\VEO-W-24-01 PR#4.docx
FOURTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 22 JANUARY 7, 2025

Project Work Order Description Project Scope In Service Date Classification
C20A101_060 Water Rights Water Rights work Expected Dec 2024 Roll-up
C22A101_060 Mason Creek Lease Water right study 02/27/2023 One-time
C22A104_060 EWC Water Right Transfers Transfer Eagle Water Company's Water Rights to 02/22/2023 One-time
C22K104_060 Surface WR Acquisition Studies Studies of potential water rights Veolia could acquire Varies Roll-up
C23A101_060 Water Rights Water Rights work Expected Dec 2024 Roll-up
C23C507_060 Landscaping Replacement- Syst Work on facility landscapes Varies Roll-up
C23KO07_060 Exec-Land Purchase Hillsboro P Purchase of land 01/25/2024 One-time
C23K110_060 Easement Purchase Perpetual Easement for Columbia 2nd Tank 05/12/2023 One-time
C24C505_060 Landscaping Replacement- Syst Work on facility landscapes Varies Roll-up
C24KO05_060 Exec-New Roosevelt Well Site Land Purchase 11/21/2024 One-time
C24KO08_060 Payette Storage Exchange Study to see if water rights on the Payette River could Expected Dec 2024 One-time
C24KI06_060 Exec-Central 1st Tank Property Land Purchase 10/31/2024 One-time
VEO-W-24-01
IPUC DR 29Attachment
Page 1 of 1

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF JANUARY 2025,
SERVED THE FOREGOING FOURTH 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.niuguna(cDveolia.com
E-MAIL: prestoncarter(a,givenspursley.com
morgan oodin ig venspursley.com
m em(a�givenspurs 1 ey.com
stephaniew(ib ig venspursley.com
PATRICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE