20250106VEO to Staff 41-43_46-50_60.pdf

RECEIVED
January 6, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Megann E. Meier, ISB No. 11948
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarter(&r zivenspursle,
morgan o�ggivenspursley.com
memk ia�g venspursle�com
Attorneys for Veolia Water Idaho, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. VEO-W-24-01
OF VEOLIA WATER IDAHO, INC. FOR A )
GENERAL RATE CASE ) VEOLIA WATER IDAHO,INC.'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
COMMISSION STAFF
)
Veolia Water Idaho, Inc. ("Veolia" or"Company")provides the following in response to
the Second Production Request of the Commission Staff dated December 13, 2024. Responsive
documents are available for download using the link provided in the accompanying email.
Confidential responses and documents are subject to the protective agreement in this case, and
are available for download using a password-protected link that will be provided separately by
email. The password will be provided in a third email.
Dated: January 6, 2025.
VEOLIA WATER IDAHO,INC.
Preston N. Carter
Attorney for Veolia Water Idaho, Inc.
RESPONSE TO STAFF'S SECOND PRODUCTION REQUEST PAGE 1 OF 2

CERTIFICATE OF SERVICE
I certify that on January 6, 2025, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:
Commission Staff Via Electronic Mail
Monica Barrios-Sanchez, Commission Secretary [e-mail]
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Chris Burdin [e-mail]
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Preston N. Carter
RESPONSE TO STAFF'S SECOND PRODUCTION REQUEST PAGE 2 OF 2

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob
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.
RESPONSE NO. 41:
Please refer to Confidential M&S supporting workpaper, namely, "07-VEO-W-24-01
M&S Fees Adjustment No. 19-Workpaper" submitted to Idaho Commission Staff on December
12th, 2024.
VEO-W-24-01
IPUC DR 41
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob
REQUEST NO. 42:
Please identify the hardware or software that is included in M&S fees and the associated
cost. Include ongoing subscription costs and upgrade fees for each.
RESPONSE NO. 42:
Please note that while the response to Data Request No.4 c.includes amounts that represent
all Digital Business & Technology("DB&T") costs,this response specifically includes hardware,
software, related subscription fees, computer peripherals, and related consultant costs. The table
below shows total amounts incurred for the period beginning January 2023 through October 2024
as well as the amounts allocated to VWID using the three-factor formula:
Jan-Dec 2023 Jan-Oct 2024
Other
Business Other
Dept Total VWID Units Total VWID Business Units
DB&T
Multiple
De is $11,783,534 $689,950 $11,093,584 $10,568,434 $606,2201 $9,962,214
For details of the hardware and software costs the Company is seeking recovery for,which
includes subscription costs and upgrade fees, please refer to Confidential M&S supporting
workpaper, namely, "07-VEO-W-24-01 M&S Fees Adjustment No 19-Workpaper" submitted to
Idaho Commission Staff on December 12th, 2024. Please refer to tab "8.31.24 Data Projected" for
the source data,and tabs"Pivot 305"and"Pivot 987"for summaries, for reference,which includes
projected costs to December 2024.
VEO-W-24-01
IPUC DR 42
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob
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.
RESPONSE NO. 43:
The description of the services provided by the various M&S departments is outlined in the Cost
Allocation Manual ("CAM") attached as part of this response. The number of employees in each
of these areas is outlined in the table below:
Corporate Communications 1
Customer Care 10
Engineering & Technical Services 21
Environmental Health and Safety 6
Executive Services 2
Facilities 3
Financial Planning 4
General Accounting & Tax 30
Human Resources 16
Information Technology 69
Legal 12
Procurement 16
Regulatory Business 11
Treasury 4
Total No. of Employees providing services to VWID 205
As described in the CAM, M&S employees do not separately track hours spent on specific tasks.
The gross costs of the departments that are allocated includes resources used to complete the
work performed such as rents, facilities charges, software and hardware.
VEO-W-24-01
IPUC DR 43
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SUEZ North America, Inc.
SUEZ Water Management & Services, Inc.
Cost Allocation Manual
VEO-W-24-01
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INDEX
Table of Contents
Section Subject Page
1 Introduction 3
2 Responsibility for Maintaining the CAM 3
3 Definitions 3
4 General Principles 5
5 SUEZ Organizational Structure 6
6 Description of Services Provided by M&S to SNA Affiliates 6
7 Services Provided by Affiliates Other Than M&S 13
8 Cost Allocation Methodology 14
9 Time Reporting Procedures 16
10 Mid-Year Changes 16
11 Reporting 17
12 Distribution 17
13 Shared Services Assets 17
Appendix A Sample Service Agreement
Appendix B Organization Charts
Appendix C Allocation Factor Calculation
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1. Introduction
SUEZ North America, Inc. ("SNA"), a wholly owned of Suez Inc., a publicly traded
company based in France, is a water utility holding company with operating utility
subsidiaries throughout the United States, which are directly owned by SNA's
intermediate subsidiary, SUEZ Water, Inc.
SUEZ Water Management and Services, Inc. (M&S or Shared Services Company)
provides administrative, engineering, legal, operations, accounting, finance, human
resources, purchasing, insurance, data processing, customer service, billing, public
relations, planning and ratemaking services, collectively known as "Shared Services" to
the operating subsidiaries of SUEZ Water, Inc., as listed in Appendix B.
M&S also provides Shared Services to SUEZ Water Environmental Services,Inc. (SUEZ
Environmental), which provides non-regulated water distribution services to several
municipalities throughout the United States and limited services to SUEZ Treatment
Solutions Inc. and Utility Service Group Inc.
M&S is a wholly owned subsidiary of SUEZ Water, Inc., which is a wholly owned
subsidiary of SNA.
The provision of shared services from M&S to its regulated affiliates throughout SNA,
are specified in service agreements filed with the appropriate regulatory commissions.
The services provided are listed below.
The purpose of the Cost Allocation Manual("CAM")is to prescribe the manner in which
costs will be charged to the regulated and non-regulated affiliates of SNA. The prevailing
premise of these cost allocation guidelines is that allocation methods should not result in
subsidization of the non-regulated services or products by regulated entities unless
specifically authorized by the regulator.
These guidelines serve to lessen the possibility of subsidization in order to protect SUEZ
ratepayers and to help establish and preserve competition in the water supply and related
competitive services markets. The guidelines also provide flexibility to accommodate
exceptions where the outcome is in the best interest of the utility, its ratepayers and
competitors.The burden of proof for any exception from the general rule rests with M&S.
This Cost Allocation Manual addresses the allocation of the costs of services provided
by M&S to its affiliates within SNA.
2. Responsibility for Maintaining the CAM
The overall responsibility for the Company's cost allocation policies and procedures will
be with the Regulated Segment Vice President & Chief Financial Officer. The day-to-
day responsibility for maintaining the CAM and ensuring that accounting records reflect
the policies and procedures described in the CAM will be that of the M&S Corporate
Controller.
3. Definitions
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a. Affiliates -companies that are related to each other due to common ownership or
control.
b. Commission—Appropriate State Regulatory Commission(e.g.New York Public
Service Commission).
c. Cost Allocation Manual (CAM) - an indexed compilation and documentation
of the Company's cost allocation policies and related procedures.
d. Cost Allocations-the methods or ratios used to apportion costs. A cost allocator
can be based on the origin of costs, as in the case of cost drivers; cost-causative
linkage of an indirect nature; or one or more overall factors (also known as
general allocators).
e. Cost Center—a function or service where costs are accumulated.
f. Common Costs - costs associated with services or products that are of joint
benefit among regulated and non-regulated business units.
g. Cost Driver - a measurable event or quantity which influences the level of costs
incurred and which can be directly traced to the origin of the costs themselves.
h. Cross-subsidization —the offering of a competitive product and/or service by a
public utility, or the offering of a product and/or service by an affiliate, which
relies in whole or in part on the utilization of utility employees, equipment or
other assets, and for which full compensation (via cost allocation or direct
payment), as determined by the Commission, has not been provided for the use
of such public utility assets,resulting in the inappropriate transfer of benefits from
the utility ratepayers to the competitive product and/or service or affiliate.
i. Department—a function or service for which costs are accumulated.
j. Direct Costs-costs that can be specifically identified with a particular service or
product.
k. Fully Allocated Costs—the sum of the direct, indirect and other economic costs
of all equipment,vehicles,labor,related fringe benefits and overheads,real estate,
furniture, fixtures, computer hardware and software, and other administrative
resources utilized, and other assets utilized and costs incurred, directly or
indirectly in the providing of services from the utility to an affiliate.
1. Indirect Costs - costs that cannot be identified with a particular service or
product. This includes but is not limited to overhead costs, administrative and
general, and taxes.
m. Non-Regulated — those entities, products and services which are not subject to
regulation by regulatory authorities.
n. Regulated-that which is subject to regulation by relevant regulatory authorities.
o. Shared Services — administrative and support services that do not involve
merchant functions, including by way of example: payroll, taxes, shareholder
services,insurance,financial reporting,financial planning and analysis,corporate
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accounting, corporate security, human resources (compensation, benefits,
employment practices),employee records,regulatory affairs,lobbying, legal,and
pension management.
p. Shared Services Assets — primarily computer hardware and software related,
shared services assets are assets utilized by Shared Services and/or utilized in
common among affiliates.
q. Subsidization - the recovery of costs from one class of customers or business
unit, which are more properly attributable to another.
4. General Principles
The following principles guide the allocation of costs for products or services provided
by M&S to its regulated and non-regulated affiliates.
• To the extent practicable, in consideration of administrative costs, costs should
be collected and classified on a direct basis for each asset, service or product
provided;
• The general method for charging indirect costs should be on a fully allocated,
cost-causative allocation basis;
• All direct and allocated costs between regulated and non-regulated services and
products should be traceable on the books of the applicable regulated utility to
the applicable Uniform System of Accounts to the extent possible;
• Documentation should be made available to the appropriate regulatory authority
upon request regarding transactions between the regulated utility and its affiliates;
• Costs should be classified to services or products which,by their very nature, are
either regulated, non-regulated, or common to both; and,
• The primary cost driver of common costs, or a relevant proxy in the absence of a
primary cost driver, should be identified and used to allocate the cost between
regulated and non-regulated services or products and between regulated entities.
5. SUEZ Organizational Structure
SNA is a holding company that provides water and wastewater services to over 7.5
million people in North America through its subsidiaries. See Appendix C for an
organization chart of the SNA Corporate Structure.
The table below identifies the SNA affiliates including SUEZ Water Management &
Services at December 31, 2015.
SNA Affiliates
Affiliate Description of Business
SUEZ North America (SNA) Holding company for all North America affiliates.
It is wholly owned by SUEZ, S.A.S.
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Holding Company for M&S and the regulated and
SUEZ Water, Inc. (SWI) non-regulated USA water and wastewater
operations.
Owns and operates regulated water and
wastewater utilities.
SUEZ Water Resources, Inc. (SWR)
Also operates municipal water and waste water
systems through public-private partnerships.
• SUEZ Water Arlington Hills Sewer Inc.
• SUEZ Water Bethel Inc.
• SUEZ Water Delaware Inc.
• SUEZ Water Idaho Inc.
• SUEZ Water West Milford Sewer Inc.
• SUEZ Water New Jersey Inc.
• SUEZ Water New Rochelle Inc.
Regulated Water&Wastewater Utilities 0 SUEZ Water New York Inc.
• SUEZ Water Owego Inc.
• SUEZ Water Pennsylvania Inc.
• SUEZ Water Princeton Meadows Inc.
• SUEZ Water Rhode Island Inc.
• SUEZ Water South County Sewer Inc.
• SUEZ Water Toms River Inc.
• SUEZ Water Westchester Inc.
M&S provides administrative, engineering, legal,
operations, accounting, finance, human
SUEZ Water Management&Services, resources, purchasing, insurance, data
Inc. (M&S) processing, customer service, billing, public
relations, planning and ratemaking services,
collectively known as "Shared Services" to the
operating subsidiaries of SNA.
Parent company for the SNA non-regulated
subsidiaries:
• Bayonne Water
SUEZ Water Environmental Services, Inc. Middletown Water
• SUEZ Water Indiana
• SUEZ Water Long Island
• SUEZ Water Mississippi
Provides local authorities and industries with
SUEZ Treatment Solutions Inc. water treatment solutions and services.
Provides comprehensive condition assessments,
rehabilitation services and sustainable asset
SUEZ Utility Services Group management solutions to help municipal and
industrial water industries manage their water
systems.
6. Description of M&S Products and Services Provided To SNA Affiliates
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SUEZ Water Management & Services, Inc. (M&S) is a wholly owned subsidiary of
SUEZ Water, Inc., which is a wholly owned subsidiary of SUEZ North America, Inc.
(SNA).
M&S provides administrative, engineering, legal, operations, accounting, finance,
human resources, purchasing, insurance, data processing, customer service, billing,
public relations, planning and ratemaking services, collectively known as "Shared
Services" to the subsidiaries of SNA. These services are described below.
Services Provided By M&S
Service Provided Description of Services Provided
This includes executive management and support in the Office of
Executive Services the CEO, the Office of the COO, and other executive positions not
otherwise described herein.
Assessing the business environment; identification of key issues;
developing business unit strategies and objectives, and
examination of alternatives; developing multi-year earnings,
margin, cash, O&M, and capital plan; modeling the financial impact
of new capital investments and balance sheet restructuring;
forecasting for regulatory filings; performing analytic support for
external stakeholders, and governing corporate capital
expenditures;
Develop business unit and department financial business plans for
Financial Planning the next year including earnings, margin, cash, O&M and capital
plans;
Perform analysis of results and prepares variance commentary for
earnings, margin, O&M, and Capital within the Company and
business unit;
Prepare and revise forecasts for earnings, margin, cash, O&M,and
Capital within the business units; and,
Review actual information and projects the remainder of the current
year future years. This function performs "what-if' analysis for
various scenarios for business unit decision-making.
Managing the monthly closing process including account
reconciliations, accounting issue resolution, and process
improvement; preparing standard monthly journal entries and
analysis to support accounting;
Managing the accounting for fixed assets including: work order
creation and set-up, analysis and monitoring of capital projects;
Accounting and Tax creating and managing fixed asset records including asset
addition, retirements, transfers or adjustments and the
preparation of any related journal entries and account
reconciliations; reporting of plant asset information for financial,
audits, regulatory reporting, rate cases or other internal needs;
process associated with the development, analysis, and
accounting for depreciation;
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Service Provided Description of Services Provided
Managing accounting policies, GAAP research, and
implementation of new accounting pronouncements; providing
guidance on accounting issues; communicating any new
accounting guidelines and procedures and their impact to
appropriate organizations organization;
Determining technical accounting details for specific transactions;
performs research, consultations with external audit and guidance
provided to the Company;
Preparing and filing standard regulatory reports, and other
mandated reports as well as with preparing the accounting
information needed to complete the annual report;
Ensure accurate accounting in all accounts.
Perform tax services including audit of assessed property taxes,
payment of property taxes, and the accounting for property taxes.
Develop long-range tax planning to optimize tax positions for the
Company; this also involves analysis of laws and regulations as
they impact the company's interest;
File federal state and local tax returns and defends all related
income tax audits as well as all applicable sales, use, and gross
receipts tax returns; and,
Ensure proper accounting in all tax accounts.
Short term borrowing and investing, including activities such as,
commercial paper issuance and associated activity or issuance
fees,rating agency activity or issuance fees, money,cash pooling,
EFT originations, tax payments, intercompany loans
administration of transactions and daily settlement, determining
daily cash position, and costs for issuing and paying agents;
Daily cash account reconciliations, treasury workstation
administration; bank or third-party fees, such as service charges,
positive pay fees, and security related fees for both utility and non-
Treasury utility account; all bank credit facility costs (e.g. bank lines, credit
lines, revolvers) including any upfront fees and on-going fees;
Develop a long-range financing and dividend strategy consistent
with the targeted credit profile, setting balance sheet targets,
developing and recommending hurdle rates for the company's
business lines; and,
Rating agency relations includes managing communications with
the agencies and includes annual rating maintenance fees and
commercial paper surveillance fees.
Performs independent, objective assurance and control advisory
Internal Audit services. This includes all audits as well as development of forward
looking audit plans that are independent and reviewed with the
Company's Audit Committee; and,
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Service Provided Description of Services Provided
Manage and administer corporate ethics compliance programs,
including codes of conduct requirements, whistle-blower cases,
ombudsmen services, and associated compliance reporting.
Operate and monitor data center infrastructure and applications,
backup & restore services, change management administration,
batch job management, hardware and software installation and
decommissioning;
Technical support, problem resolution, and the application of minor
enhancements, upgrades and patches to applications;
Develop, support and manage methodologies and measurements
for effective delivery of business solutions; and,
Design, develop, test and implement new information technology
and new information technology standards and tools for computing
environments.
Provide support center user interface as well as Tier 1 and Tier 2
support for End User support requests;
Install, maintain and resolve service problems for end user
computing devices, software, LANs and peripherals;
Manage the installation, operation, and on-going network security
administration including: identity and access management, user
provisioning, access control, monitoring and managing security
Information Technology systems including firewalls, IDS/IPS, and event management
systems, vulnerability management (patching and antivirus
administration), etc.;
Architecture design, implementation, technical support, problem
resolution, application of minor enhancements, upgrades and
patches for operating and financial systems;
Monitor security events, assists with information gathering for
required system audits and provides project management support
for new system implementations, upgrades and enhancements;
Set standards for procuring network equipment and supporting
configurations;
Implement the cyber security policies and controls development
and architecture evaluation of security solutions and it monitors
alignment with best practices, incident response planning, and;
Manage equipment, service and usage expenses paid to telecom
providers for phone, data circuits, Internet, etc. This includes WAN
costs such as fiber backbone or microwave, whether those WAN
costs are external service provider costs or are provided by internal
resources.
Handle all matters related to general litigation involving the
Legal corporation;
Perform legal services for securities and corporate financial
transactions, financial reporting and disclosures, business
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Service Provided Description of Services Provided
organizations, mergers, acquisitions and business development,
corporate governance, internal controls and risk management,
insurance, executive compensation;
Manage legal services for commercial and contract law matters for
the corporation, including real estate matters and land use permits;
Serve as board secretary and support corporate governance
functions, board of directors meetings, legal opinion letters, assists
audit and compliance functions, performs and attests internal
controls, and ensures compliance with corporate registration and
regulation;
Retain and manage external counsel to provide legal
representation in specialized areas of law and to manage variable
level legal work;
Legal work supporting the negotiation of water purchase
agreements and other procurement contracts as well as legal work
related to franchise renewals, water rights;
Provide legal advice and representation with regard to intellectual
property matters;
Perform legal services for matters involving environmental law for
the corporation including environmental permitting activities, due
diligence, defense in enforcement actions, compliance advice,
representation in environmental cleanup and environmental
litigation costs;
Provide legal advice, representation and counseling in matters
arising under federal and state water regulatory laws, regulations
and policies as they relate to the Company's utility related assets
for water and waste water;
Provide risk management services including management of the
insurance and surety bond programs; and,
Manage and administers corporate legal and regulatory
compliance programs, other than Ethics Compliance.
Procurement planning and scheduling; RFP, RFQ, RFI creation.
Management of the bidding process which consists of bidder
Procurement selection, invitation, bid package preparation and distribution, bid
evaluations, vendor selection, and contract award, including
master agreements.
Media Relations: Research and develop media response,
positioning, and strategy to respond to media inquiries or place
stories in the media. Develop press releases, arrange interviews,
Corporate and maintain 24/7 media relations availability. Act as company
Communications spokesperson. Also includes communications resources with
respect to corporate responsibility, etc.
Corporate Awareness Communications or Advertising: General
corporate awareness and brand image purposes, including "issue
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Service Provided Description of Services Provided
advertising". Spend includes agency/vendor fees to create and
execute advertising.
External Informational, Safety, and Educational Communications:
Communications or advertising spend that provides information
and educational messaging on topics such as: billing and payment
options, such as e-billing, budget billing, and direct debit; rate
options; low-income programs, consumer protection and privacy
rights notices; general water efficiency information; public safety,
including "call before you dig" programs; school education
programs; and special educational programs such as
environmental programs.
Product/Service Promotion: Communications or advertising spend
that promotes products or/or services from which the utility will
benefit.
Internal and Intranet Communications: Internal Communications
included Company communications between employees or
departments across all levels, or divisions, of an organization.
Intranet Communications includes posting of content to the internal
intranet, managing intranet user experience, interfacing with IT for
intranet administration, measurement and analysis of intranet
traffic and other data.
External Publication and Communications: Communication
targeted for non-employee audiences (public, media).
Annual Report: Design, production, printing and distribution of the
Annual report, including postage.
Internet Website Content Development and Maintenance:
Development and/or curation of content for all externally facing
company websites.
Social Media Communications: Management and administration of
established corporate social media accounts, such as Facebook,
Twitter, Instagram, and others, and the delivery of content through
those social media channels.
Translation of financial data into a State and regulated revenue
requirements, including the preparation of supporting work papers
for rate cases and other regulatory filings;
Internal and external costs for cost of capital and cost of equity
testimony; calculations of formula rates and filings associated with
these calculations;
Regulatory Business Oversight and policy guidance on regulatory proceedings;
Management and maintenance of routine State economic
regulatory relationships and contacts;
Management and maintenance of routine regulatory contacts, with
stakeholders;
Monitors issues and advocates positions in federal regulatory
proceedings as they pertain to the Company's businesses;
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Service Provided Description of Services Provided
Rate design and tariff administration activities. This also includes
tariff interpretation activities, marginal cost analyses, and the
pricing and tariff-related aspects of special contracts requiring
regulatory approval;
Participation in technical conferences, monitoring regulatory
activities, and discussing issues with PUC staff; and,
Prepare required State and Federal regulatory reporting for
initiatives including service quality indicator quarterly reports.
Revenue Management The Revenue Management function manages non-revenue water
issues and automatic meter deployment.
Manages corporate and shared services facilities as well as certain
Facilities other more centrally located facilities. Supports facility remodeling
and renovation efforts.
Develop and grow the non-regulated segment, i.e., Environmental
Services;
Business Development The costs associated with Business Development are charged to
the non-regulated segment and are not in the M&S fees allocated
to the regulated business units; and,
Manage SUEZ Water's strategic planning process.
Advises and provide engineering services to assist the operating
companies with planning, operating, maintenance, and
construction functions.
Assist the operating companies in conducting distribution system
surveys, hydraulic analysis, water quality control, system mapping,
Engineering &Technical charting, and other pertinent statistical analyses.
Services Provide periodic inspection of company structures including,tanks,
reservoirs, wells, and electrical and mechanical equipment.
Gather all pertinent statistics, reports, cost estimates, studies,
specifications and other data necessary to aid in the construction
of additions or improvements to the sources of supply, treatment
plant, pumping stations, distribution system, and other facilities as
requested by the various operating companies.
Environmental Health Mostly performed by employees embedded in the utility business
and Safety units with only two employees providing oversight at M&S.
Provides guidance,training, control and, management reporting for
the Customer Service process;
Customer Care Standardizes customer service practices throughout the SUEZ
Water regulated business units; and,
Plans for consolidation of operational activities in the future.
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Service Provided Description of Services Provided
The recruitment, screening, and selection of internal and external
candidates;
Establishing relocation programs and management of employee
relocations, including all administration and execution costs of the
relocation program;
Design and administer compensation processes including job
evaluations, annual salary planning, incentive programs, executive
compensation, deferred compensation, long term incentive
programs;
Design, management and implementation of health, prescription,
life insurance, pension and retirement, reimbursement accounts,
employee assistance programs, and other benefits for all
employees;
Manage strategy, negotiations, and contract interpretation. This
includes arbitration resolution, mutual gains bargaining, local
management support on grievances, discipline, adherence to the
contract and training;
Identification, development, and delivery of training programs to
enhance the skills and capabilities of the workforce;
Provide support on Human Resources technology and processes,
Human Resources technology strategy and solutions, portfolio management,
corporate and ad hoc reporting, data analysis, data integrity and
oversight, and system testing; and, process and release
management;
Succession planning, performance management, career
development, mentoring, executive coaching, career planning &
development, and employee/organizational assessments;
Management and administration of all short and long term disability
programs and FMLA, whether done internally or by a third party;
disability insurance premiums, if any,and the cost of claims for self-
insured programs and insured programs with a deductible; medical
services required by the Company for disability cases, such as
second opinions, consultations, etc.; disability case management
and return to work programs; investigations of short term disability
claims; legal services, whether internal or external, related to
disability cases;
Provide safety training requirements and communication tools,
needs assessments and training program development, and
compliance reporting, including investigation leadership and
support; and,
Labor Relations including contract negotiations and grievance
management.
7. Services Provided by Affiliates Other Than M&S
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In addition to the services provided by the Service Company to its affiliates, services may
on occasion be provided among SNA affiliates. Examples of these services include:
• Emergency response services
• Call center services
• Fleet services
Consistent with the cost allocation principles described above, these services are
provided on a fully-costed basis and are either direct charged to the affiliate receiving the
benefit of the service provided or allocated using an appropriate cost driver.
8. Cost Allocation Methodology
The Company's approach to cost allocation is as follows:
Direct charge: For those departments performing work related to specific construction
projects, costs are charged directly to the appropriate capital project. Engineering and
Information Technology are the departments to which this most generally applies. In
addition, certain other costs incurred for the benefit of a specific affiliate are charged
directly to that affiliate. Examples include certain legal fees and bank fees.
Segment specific allocation: To the extent practicable, shared services functions are
aligned with the business segments to whom services are provided. For functions
supporting the regulated utility business segment, costs are allocated to the individual
regulated utility affiliates using the three-factor formula described below.
Services benefiting all affiliates: For services provided which benefit all business
segments, costs are allocated based on the three-factor formula described below.l
Three-Factor Formula
The three-factor formula used to allocate costs which are not direct charged is based on
the Massachusetts Formula (MF). The Massachusetts Formulae consists of Plant,
Revenues, and Labor. However, since there is no authoritative guidance on the specific
definitions of these three components,variations have emerged over time among utilities
using to use the MF. For example, revenues may be defined as top line revenues from
the income statement or as gross margins;plant may be defined as utility plant or as total
assets; and labor may be defined as headcount or as payroll dollars. In all cases, these
variations are sufficiently minor to be considered a Modified Massachusetts Formula.
The specific components of a Modified Massachusetts Formula may vary based on the
individual circumstances and business model of the organization. Based on its
combination of regulated and non-regulated affiliates, an allocator comprised of the
'The first step in the process is to capitalize that portion of A&G costs associated with the services provided
by M&S. These procedures refer to the allocation of the net remaining balances. Amounts subject to
capitalization are distributed to affiliates each month based on the proportion of direct capital expenditures.
2 It is called the Massachusetts Formula based on the Federal Energy Commission decision in Distrigas of
Massachusetts Corp. (41 FERC¶61,205 (1987))
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following three components best reflects the underlying cost drivers associated with the
circumstances and business model of SNA.
The Company will utilize the following factors, equally weighted:
• Gross Revenue;
• Total Assets, excluding investments in subsidiaries and goodwill; and,
• Payroll.
The three-factor formula used to allocate the M&S costs is determined using the
following process:
Step 1: Calculate the average Revenue,Asset and Payroll for affiliates receiving M&S
services
Separately total the revenue, assets and payroll of all affiliates
Revenue Total Assets Payroll
Company
000 000 (000)
SUEZ A $558 $1,669 $906
SUEZ B 2,008 6,312 4,085
SUEZ C 4,428 18,231 9,074
SUEZ D 2,990 10,633 7,754
SUEZ E 4,199 12,550 8,237
SUEZ F(Non Regulated) 3,664 18,776 5,653
SUEZ G(Non-Regulated 1,018 3,131 2,568
Total $18,865 $71,302 $38,277
Step 2: Determine the percentage of M&S total costs to be allocated to each facility
Calculate the percent to total for each affiliates revenue, assets and Determine the average
payroll of(1)+(2)+(3)for
each company
Revenue Total payroll
Assets Average
Company Percent percent to /°
Percent
to Total Total to Total Total %
(1) (2) (3)
SUEZ A 2.96% 2.34% 2.37% 7.67% 2.56%
SUEZ B 10.64% 8.85% 10.67% 30.17% 10.06%
SUEZ C 23.47% 25.57% 23.71% 72.75% 24.25%
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SUEZ D 15.85% 14.91% 20.26% 51.02% 17.01%
SUEZ E 22.26% 17.60% 21.52% 61.38% 20.46%
SUEZ F (Non Regulated) 19.42% 26.33% 14.77% 60.52% 20.17%
SUEZ G(Non-Regulated 5.40% 4.39% 6.71% 16.50% 5.50%
Total 100.00% 100.00% 100.00% 300.00% 100.00%
** This result is the allocation factor for each affiliates share of M&S costs.
Step 3: Allocate M&S O&M Cost to Affiliates
Multiply the allocation factor, determined in step two above,by the actual prior year costs
for each shared service for each individual operating utility or business segment
Actual Cost of MMF Allocation Allocated Cost
Company Service Factor (000)
(000)
Shared Service: (name of service)
SUEZ A $21,542 2.56% $549
SUEZ B $21,542 10.06% $2,158
SUEZ C $21,542 24.25% $5,202
SUEZ D $21,542 17.01% $3,649
SUEZ E 21,542 20.46% $4,389
SUEZ F (Non Regulated) $21,542 20.17% $4,326
SUEZ G(Non-Regulated $21,542 5.50% $1,179
Total $21,542 100.00% $21,542
9. Time Reporting Procedures
All employees shall report time to reflect the actual number of productive and non-
productive hours worked. For Engineering, Information Technology and other
employees working on specific projects, time shall be directly charged to those projects.
Total functional area costs, which include employee labor costs, will be allocated using
the three-factor formula to either specific business segments or all affiliates based on the
department to which the employee is assigned and is not based on employee coded time
through the time reporting process.
10. Mid-Year Changes
SUEZ Management &Services, Inc. - Cost Allocation Manual 16
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If a significant organizational modification occurs in mid-year, allocation pools based on
historical usage statistics will be reviewed and modified at that time. In this situation,
allocations using predetermined rates will be modified as part of the following quarterly
true up process.
On occasion, the Company may acquire an affiliate which continues to self-provide
certain services otherwise provided by the Service Company. In those instances, only
those services actually provided by the Service Company to the affiliate will be reflected
in the cost allocation processes described above.
11. Reporting
On a monthly basis, M&S shall make a report available to each affiliates and/or business
segment for the cost of the services received by service provided. In addition,the Service
Company will make available electronically the capability to drill-down on each element
in the invoice.
12. Distribution
Distribution of the CAM shall be made to all holders of the SNA Policy and Procedures
Manuals.
13. Shared Services Assets
Affiliates to whom M&S provides services may use shared assets related to the services
provided, primarily computer hardware and software. Additionally, certain assets are
utilized for the provision of shared services, for example, leasehold improvements.
Historically, the cost of these assets was not recorded at M&S; instead, a portion of the
fully loaded cost of such assets was recorded on the books of each of the affiliates
utilizing those assets at the time the assets were placed in service.
Beginning December 2015, shared assets that have not yet been allocated to the affiliates
using those assets will remain assets of M&S. In lieu of allocating asset balances among
those affiliates, the cost allocation process will include a component representing the
return on and of the asset, that is, depreciation, a return on the net investment in such
assets (including ADIT) and applicable federal and state income taxes. The allocation of
the return on and of the asset cost will be specific to each asset and costs will be allocated
only to those companies utilizing the services provided by those assets. Depreciation
expense shall be recorded at M&S and allocated based upon the proportion of assets
allocated to each business unit. The return component of the allocation shall be
calculated based upon the net asset balance allocated to each business unit at the last
regulated rate of return authorized by the respective regulatory jurisdiction for the
specific business unit.
APPENDIX A
ORGANIZATION CHARTS
SUEZ Management &Services, Inc. — Cost Allocation Manual 17
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SUEZ North America Legal Structure Organization Chart
SUEZ NORTH AMERICA °`
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SUEZ Management &Services, Inc. — Cost Allocation Manual 18
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Attachment
Page 18 of 19

APPENDIX B
Sample Calculation of the Three-Factor Formula (for 2016)
Utility Division i
Old BU New BU OU BU Name 2015Actuals 2015Actuals 2015Actuals
00002 00002 9991 Suez Water Pennsylvania 242,863,327 37,320,528 6,546,850 7.7% 3.5% 3.2% 4.8%
00027 00027 9992 Suez Water Delaware 146,669,488 26,299,536 3,954,130 47°k 2.5% 2.0% 3.0%
00029 00029 9993 Suez Water Bethel 8,010,120 1,686,300 20,663 0.3% 0.20k 0.0% 0.1%
00044 00044 9994 Suez Water Tans River 173,593,674 32,553,482 4,529,691 5 5% 3.1% 2.2% 3.6%
00046 00046 9951 Suez Water Owego 8,719,910 2,018,749 362,345 0.3% 0.2% 0.2% 0.2%
00049 00049 9950 Suez Water SouthCountySerer 3,989,127 1,017,104 187,442 0.1% 0.1% 0.1% 0.1%
00053 00053 9053 Suez Water Westchester 239,850,323 54,605,563 4,195,956 7 6°k 5.1% 2.1% 4.9%
00055 00055 9055 Suez water Westchester 52,620,173 15,213,874 1,415,347 1.7% 1.4% 0.7% 1.3%
00060 00060 9960 Suez Waterldaho 286,435,047 46,511,941 5,960,384 9.1% 4.4% 2.9% 5.5%
00061 00061 9952 Suez Water Rhode Island 26,471,091 5,059,124 691,011 0.81k 0.5% 0.3% 0.6%
M100 001M 9940 Suez Water New Jersey 1,080,625,228 222,983,430 29,913,102 34.3% 20.9% 14.8% 23.3%
00200 00200 9953 Suez Water Nee'York 438,992,738 84,530,333 10,140,411 13.9°k 7.9% 5.0% 9.0%
00311 00301 2550 Suez Water Operations Inc(Allendale) 315,303 669,664 171,430 0 01k 0.1% 0.1% 0.1%
00315 00301 1014 Suez Water Operations Inc(Mandapan) 550,919 1,581,043 133,694 0 01k 0.1% 0.1% 0.1%
M720 00720 9941 Suez Water Arlington Hills 8,199,764 925,121 196,282 0.3% 0.1% 0.1% 0.1%
00765 00765 9996 Suez Water Matchaponix 12,545,104 3,129,323 496,803 0.4% 0.3% 0.2% 0.3%
00770 00770 9942 Suez Water'Nest MBad 3,557,145 690,394 164,369 0A% 0.1% 0.1% 0.1%
M780 00780 9997 Suez Water Princeton Meadm 10,608,376 2,735,207 517,247 _ 0.3% 0.30k 0.3% 0.3%
Total Utility Division 2,74616,657 539,53Q717 69,996,956 87.1% 50.610 34,4°0 57.41.
Environmental Services Division
Ackols YTD Sept
Old BU New BU OU BU Name 2015 Actuals 2015Actuals annualized
00420 00420 9904 Suez Water Long Island Inc 7,276,981 60,375,663 7,490,190 0.2% 1.9% 3.7%
00486 00486 9905 Suez Water Indiana LC 12,232,087 47,870,449 13,088,910 0-4% 1.5% 6.5%
00676 OD676 9908 Suez Water Mississippi LLC 3,243,352 12,171,120 2,432,101 0.1% 0.4% 1.2%
00682 00682 9909 Suez Water Env.Services Inc (16,931,634) 28,452,110 9,897,954 (0.5%) 0.9% 4.9%
00460 00460 9902 Suez Canada Holdings Inc 49,158,521 27,055,714 14,656,189 1.61k 0.9% 7.2%
00462 OD462 9902 Suez Water Env.Services Inc 0.0°k 0.0% 0.0%
00463 00463 9902 Suez Canada Waste Services Inc - 0.0% 0.0% 0.0%
00401 00401 9902 Suez Water Env.Services Inc 83,749,976 143,404,215 40,868.448 2-7% 4.5% 20.2%
Total Environmental Services Division 13&729,283 319,329,271 88,433,792 4.4% 29.9'0 43.7% 26,011,
Total ES+Utilities Only 2.883,346.140 85 101988 158.030.748 91.5% 80.5% 78.1% 83,4%
Treatment Solutions Division
2015 Actuals 2015 Actuals
Total Treatment Solutions Division 268,798.033 2ri7,133,421d 44.191.091 8.5% 19.5% 21.9% 16.62%
Grand Total 3.152,144.173 1,0%593,417 202,221.839 100,0% 100.01. 100.0% 100.0%
SUEZ Management &Services, Inc. - Cost Allocation Manual 19
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VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
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.
RESPONSE NO. 46:
The company's Cityworks licensing cost covering October 15, 2024 through October 14,
2025 is a total of$243,064.69 for 118 licenses, or a cost of$2,059.87 per license. In addition,
for the same time period, the AWS Infrastructure (web hosting) fees are $10,713.58. Please also
refer to Response No. 45.
VEO-W-24-01
IPUC DR 46
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob
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.
RESPONSE NO. 47:
The Company has not had any SOX Audits performed in 2023 and 2024.
VEO-W-24-01
IPUC DR 47
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Johns
REQUEST NO. 48:
For any grant or federal funding awarded or pending distribution to benefit Veolia Water
Idaho, Inc., 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.
RESPONSE NO. 48:
The Company has not as yet applied for grant or federal funding. As such, no grant or
federal funding has been awarded, or is pending distribution, to benefit Veolia Water Idaho, Inc.
VEO-W-24-01
IPUC DR 48
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
REQUEST NO. 49:
What is the Company's post construction evaluation process for general contractors?
RESPONSE NO. 49:
For pipeline contractors, Veolia Water Idaho, Inc.'s ("VWID") company inspector (T&D
department) on the project fills out a form evaluating them on a number of factors, such as quality
and timeliness of work, safety, and cleanliness. The VWID construction group meets with each
Contractor every year in March/April to review their performance for the previous year. For
production contractors(e.g.,work at treatment plants,pump stations, storage tanks, etc.), feedback
is provided on an as-needed basis by the project manager and/or project inspector.
VEO-W-24-01
IPUC DR 49
Page I of I

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
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?
RESPONSE NO. 50:
The Company enters into agreements with General Contractors. Local Company staff
initially screen Contractors based on the work they've done for others (references), their capacity
to do the required work for the Company, the type of work they have successfully completed,
pricing, staffing capacity, and their safety record. Prior to performing work for the Company,
Contractors are required to establish a Professional Services Agreement(PSA)with the Company.
If the Contractor meets all the necessary requirements in the PSA including (e.g., framework for
working with the company, payment arrangements/timelines, insurance requirements, etc.), they
can be awarded work by the Company.
VEO-W-24-01
IPUC DR 50
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VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
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 Cooper 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.
RESPONSE NO. 60:
The $74M include actuals additions and projected additions for Plant and CIAC from
January 2023 to December 2024 which is the amount the Company invested in utility plant in
service.However,that does not include retirements. The ending Plant in Service balance of$651M
includes actual and projected plant additions and retirements, but does not include additions from
CIAC as that is not recorded in the Plant in Service account 101 but in account 271,CIAC. Details
are shown below.
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IPUC DR 60
Page 1 of 2

ACTUALS
Plant in Service at January 1, 2023 571,591,829 57115911829
Additions Jan 23 - Aug 24 72,339,366 72,339,366
Retirements Jan 23 - Aug 24 (6,574,653)
Additions CIAC Jan 23 - Aug 24 (13,063,058)
Retirements CIAC Jan 23 - Aug 24 71,839
Projected Additions Sept 24 - Dec 24 14,714,850 1497149850
Projected Retirements Sept 24 - Dec 24 (1,106,335)
645,582,988 651,036,897
Please also refer to Exhibit No. 11, Schedule 2 which provides the projected plant balance and
CIAC as at December 31, 2024
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