20250128VEO to Staff 127_129-134.pdf

RECEIVED
Tuesday, January 28, 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]
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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 FOURTH
PRODUCTION REQUEST OF
COMMISSION STAFF
)
Veolia Water Idaho, Inc. ("Veolia" or"Company")provides the following in response to
the Fourth Production Request of the Commission Staff dated January 7, 2025. 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 28, 2025.
VEOLIA WATER IDAHO,INC.
Preston N. Carter
Attorney for Veolia Water Idaho, Inc.
RESPONSE TO STAFF's FOURTH PRODUCTION REQUEST PAGE I OF 2

CERTIFICATE OF SERVICE
I certify that on January 28, 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
Micron Technology, Inc.
Austin Rueschhoff [e-mail]
Thorvald A. Nelson [e-mail]
Austin W. Jensen [e-mail]
Kristine A.K. Roach [e-mail]
Holland& Hart, LLP [e-mail]
555 17t' Street, Suite 3200
Denver, CO 80202
City of Boise
Mary R. Grant [e-mail]
Deputy City Attorney [e-mail]
Boise City Attorney's Office
150 N. Capitol Blvd.
Boise, ID 83701
Steven Hubble [e-mail]
Climate Action Senior Manager [e-mail]
Robin Lee-Beusan
Water Resources Program Coordinator
/
Preston N. Carter
RESPONSE TO STAFF'S FOURTH PRODUCTION REQUEST PAGE 2 OF 2

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Johns
REQUEST NO. 127:
While the Application indicates that the Company would like to remove the Private Fire Hydrant
charges from the Tariff,the intended benefit and purpose of this change is unclear. Please provide
clarification on the intent of this request and if this proposed change will reclassify the Private Fire
Hydrant to a Public Fire Hydrant upon completion of installation.
RESPONSE NO. 127
The Company is proposing to add a definition of Private Fire Hydrants to its Rules &Regulations
(paragraphs 45 and 46) and request Commission approval to remove charges for Private Fire
Hydrants by eliminating the existing tariff Schedule No. 4-Private Fire Hydrants(PFH rate). The
intent of this request is to better define ownership and obligations of the Company and property
owners with respect to private fire hydrants, as there is not currently a common definition of
private fire hydrants in the tariff. The requests also alleviates billing challenges identified by the
Company and improves broader public safety by providing clarity about certain fire suppression
obligations. Removing the PFH rate will not change the Private Fire Hydrant ownership status,
change hydrant classification from private to public, or change the property owner's obligations
for private hydrant maintenance.
While working with the City of Boise and Whitney Fire District to transfer ownership of public
Hydrants to the Company (as approved by the Commission in Case No UWI-W-15-02, VEO-W-
23-04), challenges were identified including lack of definition of Private Fire Hydrants, and
therefore historic classification of hydrants, various installation scenarios (e.g. with or without
backflow prevention, on the Company's main or on a private main, etc.), and as a result, not all
Private Hydrants were being billed in accordance with the tariff.
The Company believes that consistent rate treatment across fire hydrant service, both public and
private, is appropriate as all customers are contributing equally to public safety through base rates
VEO-W-24-01
IPUC DR 127
Page 1 of 2

rather than including a separate charge for customers that happen to have a hydrant on their
property rather than in the public right of way.
As discussed in testimony, the proposed definitions are the fruit of a collaborative effort with the
intention of enhancing public safety as a common definition is provided, property owners will be
on notices with respect to responsibilities for private fire hydrants located on their property
regarding operation and maintained at the owner's expense.
The cost to install, relocate, maintain, and operate (Private) hydrants located on private property
will continue to be borne by the property owner. The cost to install,relocate,maintain,and operate
(Public) hydrants located in rights of way, for hydrants owned by the Company for public fire
protection, will continue to be borne by the Company and recovered from all customers. The
Company will continue to maintain hydrants owned by the Company and located in the right of
way and the Company's obligation as it relates to (Private)hydrants located on private property is
to ensure adequate reliable water supply.
VEO-W-24-01
IPUC DR 127
Page 2 of 2

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
REQUEST NO. 129:
Please provide a copy of the Company's overhead calculation in Excel format with formulas intact.
RESPONSE NO. 129
Please see Attachment to this response.
VEO-W-24-01
IPUC DR 129
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob
REQUEST NO. 130:
Please provide the supporting documentation for rate case expenses provided on lines 4-9 in
Adjustment No. 23.
RESPONSE NO. 130
As stated in the testimony of Company Witness Jacob,the Company seeks recovery of the current
rate case costs, which are estimated. Please also refer to the response provided in IPUC Request
No. 80 (which is being supplemented monthly with actual rate case costs incurred to date).
Estimates were developed based on the Company's previous rate case experience. Further
explanation of each line item is provided below.
Rate case expenses constitute the cost of Legal Services, Outside Expert Services, Intervenor
Costs, Mailing Notifications, and Other Miscellaneous Services.
Legal services costs are based on estimates from the prior Veolia Water Idaho Rate Case which
assumes a fully litigated rate case.
Outside Expert services costs are made up of the cost of consulting services provided for the Rate
of Return Study and the Lead Lag Study and includes their respective cost of planning, analysis,
data collection, development of the studies,minimum filing requirements and testimony. Included
is also an estimate of post filing work, responding to interrogatories, and hearing preparations.
Intervenor costs are estimated based on past proceedings to accommodate the request of
intervenors for reimbursement of costs incurred as parties to the rate case filing.
Cost of mailing customer notifications as required by the Commission was estimated based on the
cost of mailing the customer flyer to the approximately 107,000 customers in our service territory.
VEO-W-24-01
IPUC DR 130
Page 1 of 2

Miscellaneous & Other Costs category is a contingency for other costs that might be incurred and
does not fit neatly into the other pre-defined classifications. The Company foresees the incurrence
of the above costs in the processing of the rate case but will base its amortization of rate case
expense based on actual deferred costs incurred in this rate case proceeding.
VEO-W-24-01
IPUC DR 130
Page 2 of 2

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob
REQUEST NO. 131:
Please provide the supporting documentation for the deferred power calculation. (Adjustment No.
27).
RESPONSE NO. 131
Please refer to Attachment 1 for the calculation of deferred power. Additionally, Attachment 2
shows the calculation updated for actuals through December 31, 2024.
VEO-W-24-01
IPUC DR 131
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 132:
Please provide the supporting documentation of the historic and repricing of power expense as
provided in Line Nos. 2-5 and 8-11 of Adjustment No. 10.
ESPONSE NO. 132
Please see response Request No. 73 Attachment D Adjustment 10 Energy-Confidential
The historic test year Idaho Power Invoice details are on the first worksheet of the attachment -
TY Power Bill Details CONFIDEN,cells AT2614 through AT2635.The journal entries supporting
these amounts for Adjustment 10 Line No. 2-5, are found on the second worksheet of the
attachment-POWER Opex JEs 50610 50620,by filtering Column AW for"Idaho Power Invoice".
The repricing calculation totals for Line No. 8-11 are located at the bottom of the first sheet - TY
Power Bill Details CONFIDEN, cells AT2649 through AT2661.
VEO-W-24-01
IPUC DR 132
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 133:
Please provide the supporting documentation for the anticipated demand response rebate in
Adjustment No. 10.
RESPONSE NO. 133
The anticipated power response rebate was based on the Historic Test Year amount of$72,812.
Please see Attachment I for the journal entry supporting this amount, Attachment 2, and
Attachment 3 for Idaho Power's supporting documentation for the rebate amount.
VEO-W-24-01
IPUC DR 133
Page I of I

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 134:
Please provide the supporting documentation for Line No. 18 in the Adjustment No. 10.
RESPONSE NO. 134
Please see response Request No. 73 Attachment D Adjustment 10 Energy-Confidential
The historic test year Idaho Power Invoice details are located on the first worksheet - TY Power
Bill Details CONFIDEN of the attachment,with totals for Adjustment No. 10 Line No. 2-5 located
on cells AT2614 through AT2635.
The repricing calculation totals for Line No. 8-11 are located at the bottom of the sheet-TY Power
Bill Details CONFIDEN, cells AT2614 through AT2661.
The second worksheet of the attachment - POWER Opex JEs 50610 50620, will show Historic
Test Year journal entry amounts to support Adjustment 10 Line No. 2-5 Idaho Power Invoices by
filtering Column AW for "Idaho Power Invoice", Line No 14 - Diesel fuel for emergency
generators by filtering Column AW for"Generator",Line No 15 -Idaho Power Demand Response
program by filtering Column AW for "Rebate", and Line No 16 - Natural Gas, Other Utilities,
Accrual by filtering Column L for account"50620" and column AY for"Other Power".
VEO-W-24-01
IPUC DR 134
Page 1 of 1