20250109Staff 135-143 to VEO.pdf

RECEIVED
Thursday, January 9, 2025 10:02:46 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 ) FIFTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO VEOLIA WATER IDAHO,
INC.
Staff of the Idaho Public Utilities Commission("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 THURSDAY,JANUARY 30, 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.
FIFTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 1 JANUARY 9, 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. 135: Please provide an updated Company Exhibit No. 5 based on a
Test Year using actuals through December 31, 2024, by updating the Company's workpaper file
"05-VEO-W-24-01 Revenue Exhibits-Workpapers." Please provide in electronic format with
formulas enabled and include actual customer counts and customer consumption through
December 31, 2024.
REQUEST NO. 136: Please provide an updated Company Cost of Service Study
("COSS")based on a Test Year using actuals through December 31, 2024, by updating the
Company's workpaper file "Ol-VEO-W-24-01 Cost of Service Exhibits-Workpapers." Please
provide in electronic format with formulas enabled.
REQUEST NO. 137: Please provide an update to the Company's revenue requirement
model with actual expenses,rate base, etc. through December 31, 2024.
REQUEST NO. 138: In Company Witness Hatch's Direct Testimony, page 9, it states,
"based on currently available data, there are not discernable factors that suggest Veolia Water
Idaho's different customer classes cause costs to be incurred by the Company differently,
negating the need for separate rate classes, and therefore different rate schedules." Please
respond to the following:
a. Please explain and provide the currently available data that shows there are no
discernable factors that suggest Veolia Water Idaho's different customer classes cause
costs to be incurred differently by the Company; and
b. If this statement is referring to the customer classes (Residential, Commercial, Public
Authority, Private Fire)used in the COSS provided in this case,please explain why
the Company believes the Residential and Commercial Classes do not cause the
Company to incur costs differently when the results of the COSS suggests an increase
of 24.7 percent for Residential and 16.9 percent for Commercial.
FIFTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 2 JANUARY 9, 2025

REQUEST NO. 139: On page 10 of Company Witness Hatch's Direct Testimony, it
states, "Veolia Water Idaho's use of a general service rate is consistent with water utility
practices in other jurisdictions." Please respond to the following:
a. Please provide a list of jurisdictions with similar characteristics as Company's service
area that use a single general service rate for all customers outside of Public Authority
and Private Fire; and
b. Please provide a list of jurisdictions with similar characteristics as the Company's
service area that use different rate structures other than a single general service rate
for all customers outside of Public Authority and Private Fire.
REQUEST NO. 140: In his Direct Testimony, pages 6-7, Company Witness
Michaelson discusses modeling customer usage based on Commission's suggested
improvements in Case No. VEO-W-22-02. Please explain and provide all workpapers, models,
and data used by the Company to create the models using these suggestions. Please include in
native format with all formulas enabled.
REQUEST NO. 141: Please provide all property tax assessments and bills for 2024.
Please also include any property tax settlements with the Idaho State Tax Commission.
REQUEST NO. 142: Please refer to Exhibit No. 13, Schedule 1, provided in the Direct
Testimony of Company Witness Hatch.
a. Please explain the criteria and characteristics that the Company uses to classify
customers into the Residential, Commercial, Public Authority, and Private Fire
classes; and
b. Please explain if the Company has evaluated different rate schedules for the different
customer classes identified in Exhibit No. 13, Schedule 1.
REQUEST NO. 143: Please provide the monthly metered amount of water usage, in
CCF, for every metered customer during the period from l/l/2022 to 12/31/2024. Please include
for each customer the classification(Residential, Commercial, Public Authority), meter size, date
of meter read, and rate schedule (VWID, Eagle New, Eagle Exist). For customers that are billed
FIFTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 3 JANUARY 9, 2025

bi-monthly, please explain if the consumption amounts represent a bi-monthly time span or a
monthly time span.
DATED at Boise, Idaho, this 91h day of January 2025.
a,k1A,-<
Chris Burdin
Deputy Attorney General
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FIFTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 4 JANUARY 9, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS q:o�`DAY OF JANUARY 2025
SERVED THE FOREGOING FIFTH 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 CAR-K ER 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.nju unagveolia.com
E-MAIL: prestoncarterkgivenspursle.�com
morgan og odinn ivenspursley.com
mem givenspursley.com
stephaniew g, i_g venspursle.
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE