20250115Staff 144-146 to VEO.pdf

RECEIVED
Wednesday, January 15, 2025 12.40:41 PM
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 ) SIXTH 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
WEDNESDAY, FEBRUARY 5, 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.
SIXTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 1 JANUARY 15, 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. 144: With reference to the Company's response to Staff s Production
Request No. 09, please explain the associated benefits of the Company's membership with the
National Association of Water Companies. Please include in your response any cost-benefit
analysis conducted, fee structure (flat fee, variable fee), and the number of years of participation.
REQUEST NO. 145: Please provide detailed information regarding tuition
reimbursement expenses. Include the total amount incurred for tuition expenses and specify the
employees who received such benefits during 2023 and 2024. Additionally, provide supporting
documentation, such as invoices, receipts, or internal policy documents, to substantiate these
expenses.
REQUEST NO. 146: Please provide a list of all fines and/or penalties levied against the
Company in 2023 and 2024. Please include the dollar amount, a description of each, the
associated capital project or work order, and the account number the costs were booked to. This
list should include any fines and/or penalties that were levied against any general or
subcontractors while acting on behalf of the Company, and if those costs were passed on to the
Company.
DATED at Boise, Idaho, this 15th day of January 2025.
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\VEO-W-24-01 PR#6.docx
SIXTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 2 JANUARY 15, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF JANUARY 2025,
SERVED THE FOREGOING SIXTH 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.niugunagveolia.com
E-MAIL: prestoncarternggivenspursle
morgangooding ig venspursle
memg ig_venspursle com
stgphaniewg ivenspursley com
AUSTIN RUESCHHOFF
THORVALD A NELSON
AUSTIN W JENSEN
KRISTINE A.K. ROACH
HOLLAND & HART LLP
555 17TH ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoffkhollandhart.com
tnelson(a,hollandhart.com
aw'en� senghollandhart.com
karoachkhollandhart.com
acleeghollandhart.com
PAT ICIA JORDAN SECRETARY
CERTIFICATE OF SERVICE