20250113VEO to Staff 65_67-70_74-76_79_81_83-91_93-95.pdf

RECEIVED
January 13, 2025
IDAHO PUBLIC
Preston N. Carter, ISB No. 8462 UTILITIES COMMISSION
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 THIRD PRODUCTION
REQUEST OF COMMISSION STAFF
)
)
Veolia Water Idaho, Inc. ("Veolia" or"Company")provides the following in response to
the Third Production Request of the Commission Staff dated December 23, 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 13, 2025.
VEOLIA WATER IDAHO,INC.
Preston N. Carter
Attorney for Veolia Water Idaho, Inc.
RESPONSE TO STAFF's THIRD PRODUCTION REQUEST PAGE I OF 2

CERTIFICATE OF SERVICE
I certify that on January 13, 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
Austin Rueschhoff [e-mail]
Thorvald A. Nelson [e-mail]
Kristine A.K. Roach [e-mail]
Holland& Hart, LLP [e-mail]
555 17th St., Ste. 3200
Denver, CO 80202
Attorneys for Micron Technology, Inc.
Preston N. Carter
RESPONSE TO STAFF'S THIRD PRODUCTION REQUEST PAGE 2 OF 2

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob
REQUEST NO. 65:
Please provide a list of all subsidiary utilities under VUR.
RESPONSE NO. 65:
The subsidiaries of VUR are:
Veolia Water Idaho, Inc. - Regulated
Veolia Water Delaware, Inc. - Regulated
Veolia Water Pennsylvania, Inc. - Regulated
Veolia Water Rhode Island, Inc. -Regulated
Veolia Water New Jersey, Inc. - Regulated
Corwick Realty Corporation(a wholly owned subsidiary of Veolia Water New Jersey, Inc.)
Veolia Water New York, Inc. - Regulated
Veolia Sewer Operations New York, Inc.
Veolia Sewer New York, Inc.
The Dundee Water Power and Land Company (50% owned by North Jersey District Water
Supply Commission)
Veolia Water Operations (Paramus), Inc.
VEO-W-24-01
IPUC DR 65
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob
REQUEST NO. 67:
Please provide the dividend policy for the Company issuing dividends to its parent company.
RESPONSE NO. 67:
The Company does not have a specific dividend policy to issue dividends to its parent company.
In the normal course of business, Treasury reviews the capital infusions and distributions for
Veolia Utility Resources LLC ("VUR") and its subsidiaries semi-annually in June and then again
in December. If a subsidiary has generated cash, the subsidiary will pay a dividend to the parent
company. If the subsidiary requires cash due to large capital spending throughout the year or
because operating expenses exceed the revenue stream, VUR will infuse a cash contribution into
that subsidiary.
Treasury will prepare the Dividend/Cash Infusion memo,which details the dividend/cash infusion
requests that are being made based on the June and December month-end closing information that
is available. Treasury will verify that the payment of these transactions will not violate any
covenants and the transactions are made via journal entry with no cash movements, as the cash is
settled through the intercompany money pool process.
VEO-W-24-01
IPUC DR 67
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Njuguna
REQUEST NO. 68:
Please provide the supporting documentation for the VUR embedded debt rate of 4.43%.
RESPONSE NO. 68:
Please see the confidential attachment to Data Request No 64 Response.
VEO-W-24-01
IPUC DR 68
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Njuguna
REQUEST NO. 69:
Please provide the supporting documentation for the VUR capital structure.
RESPONSE NO. 69:
Please see Data Request 64 Response.
VEO-W-24-01
IPUC DR 69
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Walker
REQUEST NO. 70:
Referencing Company Witness Walker's Exhibit No. 1 Schedule 13, please provide the
methodology used that would create the variation in the historical 5-year growth in EPS between
analysts.
RESPONSE NO. 70:
Value Line, FirstCall and Zacks do not generally discuss the particular methodologies they use to
determine historical growth rates. Variation in the historical 5-year growth in EPS can arise based
on the use of moving 12-month data versus annual EPS data, use of "normalized" versus "as
reported" EPS data, use of log linear growth versus compound growth rate, or the use of single
period versus multi-year period base periods which are 5-years apart.
VEO-W-24-01
IPUC DR 70
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 74:
Please provide a list of all subcontractors used in 2023 and 2024. Please include in your response
the process of hiring subcontractors and the managers involved in making the final decisions.
RESPONSE NO. 74:
Please see Attachment 1 for a list of subcontractors and vendors used in 2023 and 2024.
Please see Attachment 2 for the Veolia North America (VNA) policy with guidelines on hiring
subcontractors. This policy provides the framework for the Purchasing Cycle and establishes the
minimum standards for procurement of all goods, services and works for VNA, including essential
controls related to the financial and accounting aspects of purchasing. Proper application of this
policy is required in order to be in compliance with Veolia guidelines and Internal Control
requirements. The managers involved in making the final decision on the selection of
subcontractors for work are responsible for ensuring adherence to this policy and monitoring the
correct application of procedures related to this policy. Managers of the project, or department
requiring the work, are ultimately the ones making the final decision on subcontractor selection.
VEO-W-24-01
IPUC DR 74
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 75:
Please provide a narrative explaining the E-Payment Convenience Fee, found in Company
Exhibit No. 10, Page 12 Subcontractors, Line No. 10.
RESPONSE NO. 75:
E-Payment Convenience Fees are costs paid by the company on behalf of customers who
make electronic payments on their account. A$1.20 per transaction convenience fee is charged by
the third party vendor ACI Payments Inc. (Speedpay, formerly Western Union) when a customer
utilizes approved electronic methods to make a payment such as making a payment by telephone,
on Veolia's website (formerly SUEZ) via debit card, credit card, ATM card, or pay in person at a
payment location (such as Albertsons, Fred Meyer, Check Into Cash, Money Tree). When
customers utilize Veolia's Direct Debit option to have funds automatically withdrawn from their
bank account or when customers mail their payment to the company's payment center(Lockbox),
there are no E-Payment Convenience fees incurred.
In Case No. SUZ-W-19-01 the Company requested to waive customer (Western Union)
payment processing fees by paying the transaction fees on behalf of its customers, and including
this cost in future general rate cases. Order No. 34405 allowed discontinuing collecting
convenience fees from customers by its third-party vendor, Western Union, and (for Veolia) to
pay the transaction fees. The Order approved deferral of the (Western Union fees) costs until its
next rate case and recovery of the deferred amount over three years and that thereafter, the
processing fees would become a normal operating expense. When a customer utilizes another
third-party payment vendor, the convenience fees billed to customers are not paid by Veolia.
VEO-W-24-01
IPUC DR 75
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 76:
With reference to Exhibit No. 10, Schedule 1, Adjustment 16 - Vehicle Allocation, please provide
supporting documentation for the following transportation expenses. Please verify that the mechanic's
payroll has not been already included in the Payroll Adjustment.
a. Mechanic's payroll and benefits;
b. Lease Cost;
c. Fuel;
d. Material, Maintenance;
e. Auto Insurance; and
f. Other Costs.
RESPONSE NO. 76:
With reference to the pro forma Test Year Expense filed in Exhibit No 10, Schedule 1,Adjustment
16 -Vehicle Allocation, please see below for supporting documentation.
a. Mechanic payroll and benefits $110,407: The Test Year expense is based on the annual
salary of the mechanic as included in the total on Line 3 - Transmission and Distribution
labor in Exhibit No 11, Schedule 1, Adjustment 1 - Payroll. The annual salary of$80,184
is based on the rate of pay effective in the current Collective Bargaining Agreement,
annualized for 2080 standard hours and excludes any overtime. Additionally,Historic Test
Year Fringe Benefit Allocation as filed in Exhibit No 10, Schedule 1, Adjustment 8 of
37.69% is added for a total Test Year expense of $110,407. The mechanic payroll and
benefits are initially recorded to direct labor expense but through a monthly allocation
VEO-W-24-01
IPUC DR 76
Page 1 of 2

process, are transferred out to the vehicle allocation account 50645000. As a result, the
mechanic's payroll is transferred out and not included in the payroll adjustment.
b. Lease Cost$853,312: See attachment Data Request No 76 Attachment 1 Lease Cost for
journal entry details tying to Exhibit No 10, Schedule 1, Adjustment 16, Line 3.
c. Fuel$250,125: See attachment Data Request No 76 Attachment 2 Fuel Cost for journal
entry details tying to Exhibit No 10, Schedule 1, Adjustment 16, Line 4.
d. Material, Maintenance $302,009: See attachment Data Request No 76 Attachment 3
Material Maintenance Cost for journal entry details tying to Exhibit No 10, Schedule 1,
Adjustment 16, Line 4.
e. Auto Insurance -$2,362: See attachment Data Request No 76 Attachment 4 Auto
Insurance Cost for journal entry details tying to Exhibit No 10, Schedule 1, Adjustment
16,Line 6 and 7. Line 6 reflects auto insurance premiums only of$36,622. Line 7 excludes
Historic Test Year IBNR of $32,783 (incurred but not reported claims reserves) and
includes auto insurance adjustments recorded to vehicle allocation account 50645000 of-
$340,683 offset by insurance claims payments in account 262000000 of$301,700 for a net
Test Year amount of-$38,984.
f. Other Costs $260,949: See attachment Data Request No 76 Attachment 5 Other Costs
for journal entry details tying to Exhibit No 10, Schedule 1, Adjustment 16, Line 8.
VEO-W-24-01
IPUC DR 76
Page 2 of 2

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 79:
Regarding vehicle replacement, please provide a copy of the Company's vehicle replacement policy
and any studies the Company has carried out since the last general rate case.
RESPONSE NO. 79:
Please see the attachment to this response for the procedures outlined regarding vehicle
replacement. To my knowledge, no studies have been carried out since the last general rate case
with reference to this topic.
VEO-W-24-01
IPUC DR 79
Page I of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 81:
Please provide a copy of the Company credit card and purchase card policy
RESPONSE NO. 81:
Please see the following two attachments:
Data Request No 81 Attachment I- Travel Expense Credit Card Policy
Data Request No 81 Attachment 2 - Purchase Card Policy
VEO-W-24-01
IPUC DR 81
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 83:
Please provide the transaction detail reports for the following Cost Element Category accounts for
Office Expense Account No. 50650, for the historical test year that ended August 31, 2024, in
Excel format with formulas intact:
a. 701016—Other Office Expense (Cityworks, Technology);
b. 701005 —Dues and Subscriptions (NAWC, AWWA, etc.);
c. 701014—Hotel and Lodging; and
d. 701006—Licenses and Fees.
RESPONSE NO. 83:
a. Please see response to production Request No 73 - item H for Office Expenses worksheet
50650 JE for GL account 50650 Historical Test Year journal entries by cost element. (Data
Request No 73 Attachment H Adjustment 17 Office Expenses b/c/d. Purchase card
transaction details and employee expense report reimbursements details ("EXA"journal
entries) were provided in response to Production Request No 25. (Data Request No 25
Response Confidential).
VEO-W-24-01
IPUC DR 83
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 84:
Please provide the transaction detail reports for the following accounts, for the historical test year
that ended August 31, 2024, in Excel format with formulas intact:
a. 150-151 et al—Materials and Supplies Inventory;
b. 162-165 et al—Prepaid Expenses—Other(Prepayments);
c. 90400&90405—Bad Debt&Bad Debt Reserve;
d. 92300—Bank Charges; and
e. 92450—Severance Plan.
RESPONSE NO. 84:
Please see the response in the following attachments:
a. Data Request No 84 Attachment 1- Inventory
b. Data Request No 84 Attachment 2 -Prepaid
c, d, and e. Data Request No 84 Attachment 3 -Bad Debt, Bank Fees, Severance
VEO-W-24-01
IPUC DR 84
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bucci
REQUEST NO. 85:
With reference to Adjustment 18 - Advertising, please provide the transaction detail report for
Advertising Account 50651,for the historical test year that ended August 31,2024,in Excel format
with formulas intact.
RESPONSE NO. 85:
Please see the attachment for the transaction detail report for Account 50651 for the historical test
year ended August 31, 2024. Please note that this is a subset of the same information as provided
in Data Request No. 10 Attachment.
VEO-W-24-01
IPUC DR 85
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 86:
Please provide a list of all worker's compensation insurance claims that Veolia paid for the test
year.
RESPONSE NO. 86:
Workers' Compensation claims from 9/1/23 - 12/31/24 with payments. Note: A third party
Workers Compensation insurance vendor makes the payments on our behalf but since all of these
claims were within the deductible, these costs were charged back to us.
Claim# Date Cost
196113956-001 10/23/2023 $31.14
190249962-001 1/11/2024 $837.18
190282055-001 1/22/2024 $1,569.33
19028118-001 3/1/2024 $1,418.31
190320218-001 4/9/2024 $2,561.78
190320248-001 4/11/2024 $603.50
VEO-W-24-01
IPUC DR 86
Pagel of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob
REQUEST NO. 87:
For Company Exhibit No. 10. Page 23,Amortization Expense-Deferred Rate Case,please provide
an itemized list of Miscellaneous & Other Costs in excel format.
RESPONSE NO. 87:
Miscellaneous & Other Costs category is a contingency for other costs for which there is a
likelihood of assorted costs being incurred that do not fit neatly into the other pre-defined
classifications. Such costs could include costs incurred for other outside services required for
hearing preparations or to prepare production request responses which are not specifically
includable in the other deferred rate case expense categories. For example, in a previous VWID
rate case, over the course of the proceeding, the Company incurred charges to produce certain
reports related to pensions to adequately respond to production requests. The Company foresees
the potential incurrence of such costs in the processing of the rate case but will base its amortization
of rate case expense on actual deferred costs incurred in this rate case proceeding.
VEO-W-24-01
IPUC DR 87
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Johns
REQUEST NO. 89:
In reference to Company Witness David Johns testimony, Page 7, Lines 1 — 16, regarding
community engagement, conservation, and customer outreach, please provide total costs spent
year-to-date, amount included in the Application, and the line number the expense can be found in
Exhibit No. 10.
RESPONSE NO. 89:
The amount included in the Application for these events is $2,919.39 in total detailed below.
Event Cost Exhibit 10 Line No
1. City of Boise Earth Day Celebration, April 2024
$52.06 Total
After work hours event, food, mileage, supplies
50650 - Office Expenses $37.47 Line No 17
50651 -Advertising $14.59 Line No 18
1. Truck a Palooza at Ada Community Library, Victory
Branch, June 2024
50100 & 50105 -Payroll $565.71 Line No 1
2. Eagle Fun Days, July 2024 $908.74 Total
Setup &tear down estimate based on 3.8 hours for 3
employees
50100 & 50105 —Payroll, Supplies, food $460.00 Line No 1
50650 - Office Expenses $448.74 Line No 17
3. National Night Out, Central Bench, August 2024
After hours event $0 N/A
4. Boise Pride Festival, September 2024
Setup &tear down estimate based on 3.8 hours for 3
employees
50100 & 50105 -Payroll $460.00 Line No 1
5. Open Streets Initiative in The Bench (Boise Goathead
Festival), September 2024 $524.17 Total
Setup &tear down estimate based on 3.8 hours for 3
employees
50100 & 50105 -Payroll $460.00 Line No 1
Food& other
50650 - Office Expenses $64.17 Line No 17
VEO-W-24-01
IPUC DR 89
Page 1 of 2

Event Cost Exhibit 10 Line No
6. City of Eagle Night of a Thousand Pumpkins, October
2024 $264.89 Total
After hours event, Supplies and food, Mileage
reimbursement
50650 - Office Expenses $234.91 Line No 17
50651 -Advertising $29.97 Line No 18
7. Idaho Veterans Parade, November 2024
After hours event, Supplies and food
50650 - Office Expenses $143.83 Line No 17
VEO-W-24-01
IPUC DR 89
Page 2 of 2

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Johns
REQUEST NO. 90:
In reference to Company Witness David Johns' testimony, Page 12,Lines 8-22,please provide the
Idaho Department of Environmental Quality's Improved Lead and Copper Rule regulatory
requirements and specifically include where it requires an annual voluntary postcard campaign to
determine customer's unknown service line material.
RESPONSE NO. 90:
The Idaho Department of Environment Quality's Lead and Copper regulatory requirements can be
found in IDAPA 58.01.08,rule 350,which incorporates 40 CFR 141 Subpart I by reference. Please
see 40 CFR 141.85(e)(1) and 40 CFR 141.85(e)(2) attached for referenced EPA regulation
requiring annual customer communication on unknown service line material.
VEO-W-24-01
IPUC DR 90
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Johns
REQUEST NO. 91:
Please explain the rate that a customer currently receiving the discounted Eagle Water rate would
pay if they moved to another service address within the area formerly serviced by Eagle Water
Company.
RESPONSE NO. 91:
Existing customers residing in the area formerly serviced by Eagle Water Company as of January
1,2022(Eagle Water Company Acquisition date)are eligible for existing customer phased-in tariff
Eagle Water Service Area rates when they reside in the area formerly serviced by Eagle Water
Company.
If an existing customer who was part of the Eagle Water Company acquisition as of January 1,
2022 relocates to another address within the area formerly serviced by Eagle Water Company,then
the same phased-in existing customer tariff Eagle Water Service Area rates will apply ie. Schedule
No 1 General Metered Service Eagle Water Service Area Sheets No. 4 - 7.
If however, an existing customer who was part of the acquisition as of January 1, 2022 relocates
to an address outside of the area formerly serviced by Eagle Water Company, then full Veolia bi-
monthly billed tariff rates will apply ie. Schedule No 1 General Metered Service Sheet No. 3.
New customers after January 1, 2022 to the area formerly serviced by Eagle Water Company,will
have the Veolia full-monthly rates apply for new customers ie. Schedule 1 General Metered
Service Eagle Water Service Area. Sheet No. 8.
VEO-W-24-01
IPUC DR 91
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Michaelson
REQUEST NO. 93:
Please explain if the Company currently provides service to any customers under Schedule No.
113, Flat Rate Service. If so, please provide the Company Exhibit and Schedule that includes the
number of bills and revenue from these customers.
RESPONSE NO. 93:
The Company does not currently provide service to any customers under Schedule No. 1B, Flat
Rate Service.
VEO-W-24-01
IPUC DR 93
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Michaelson
REQUEST NO. 94:
Please refer to the Testimony of Timothy Michaelson, Exhibit 5, Schedule No. 3 — Eagle Exist, and
Schedule No. 3 —Eagle New. Please explain why the rows under"Summer Usage"are labeled"Up to
3 CCF" and"Over 3 CCF"when the volume charge for these customers changes at 1.5 CCF.
RESPONSE NO. 94:
The rows under "Summer Usage" are labeled incorrectly. They should be labeled, "Up to 1.5
CCF" and"Over 1.5 CCF." The data provided coincides with the 1.5 CCF over/under threshold.
VEO-W-24-01
IPUC DR 94
Page I of I

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Michaelson
REQUEST NO. 95:
Please provide updates to all Exhibits and workpapers that are affected by the rate change that goes
into effect on January 1, 2025, to existing customers taking service in the area formerly serviced
by Eagle Water Company as of January 1, 2022.
RESPONSE NO. 95:
Please refer to Data Request No. 95 Attachment. Excel workpapers are being provided with the
response.
The Company would note that the Test Year ends on December 31, 2024, which is the point in
time for which Rate Base and Expenses are included. Including the rate change associated with
"Existing" Eagle customers beyond that date, creates a mismatch with the other elements of the
filing. If the higher rates associated with the January 1, 2025, increase are included for
consideration by the Commission in this case, the Company believes that other costs and
investments made which are beyond the test year should also be considered.
VEO-W-24-01
IPUC DR 95
Page 1 of 1