The URL can be used to link to this page

Home My WebLink About20250131Staff 148-163 (Redacted).pdf RECEIVED Friday, January 31, 2025 3:34:15 PM IDAHO PUBLIC UTILITIES COMMISSION CHRIS BURDIN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 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 ) REDACTED EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO VEOLIA WATER IDAHO, INC. Staff of the Idaho Public Utilities Commission ("Staff'), 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 FRIDAY, FEBRUARY 21, 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. REDACTED EIGHTH PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. I JANUARY 31, 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. 148: Please provide the gross annual pay as of 12/31/2022, for each employee number listed in the response provided to Production Request No. 44. If that employee's employment began after 12/31/2022, please provide their gross annual pay at the time of employment with the date employment began. REQUEST NO. 149: In reference to Attachment 3 of Company's confidential response to Staff Production Request No. 61e, the task order identified as had a "not tc exceed amount" of. and a total invoiced amount. Please provide documentation granting the contractor advanced approval to exceed the contract amount. REQUEST NO. 150: In reference to Company's confidential response to Staff Production Request No. 61, the response indicates that there were no change orders for this project as there is less than a-overilin with final project costs of and a final approved budget of Id at 61 e, Item vii. Additionally, the initial approved budget for the project was Id at 61 c, Item ii. Please reconcile the difference between the initial approved budget and the final approved budget. REQUEST NO. 151: Please answer the following regarding the number of private fire hydrants and test year revenue fi-om tariff Schedule No. 4, Private Fire Hydrant Bi-Monthly and Monthly charges. a. Please provide the number of private fire hydrants that are served by the Company's system. b. Please provide the number of private hydrants that are billed by the Company. If different fi-om part a. above, please explain why. c. Please provide all calculations, including workpapers, showing how the test year private fire hydrant revenue of$25,475 shown on Company Exhibit 5, Schedule 3 VWID, was collected. REDACTED EIGHTH PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 2 JANUARY 31, 2025 REQUEST NO. 152: The Company's response to Staff Production Request No. 57 states that the project incurred cost overruns of$378,792 due to "increased traffic control and temporary paving to keep the road open until the Ada County Highway District("ACHD") contractor began their portion of the project." Please provide a more detailed explanation of what transpired, including answers to the following questions: a. Please clarify if the Company incurred the expenses directly with in-house labor and materials, or if the contractor incurred the expenses and executed change orders with the Company. b. Please clarify why ACHD was not responsible to pay the expenses caused by its delay. c. Please provide documentary evidence showing a breakdown of the extra expenses and the dates of occurrence. REQUEST NO. 153: Please provide the Company's water storage tank maintenance plan. The plan should include the following information at a minimum: a. A list of all the water storage tanks and reservoirs, including their nominal storage volume, date placed in service, and type of construction. b. The month and year of the most recent preservation work performed on the interior and exterior of each tank, and the cost for that work. c. The planned year for the next preservation work for the interior and exterior of each tank, and the estimated cost for that work. REQUEST NO. 154: In reference to Company's response to Staff Production Request No. 22,please provide the Company's actual expenditures for processing the general rate case as of the date of this request. Also,please consider this an on-going request and update this response as expenses become known. REQUEST NO. 155: Regarding the Management and Services shared assets depreciable lives,please explain if the depreciable lives that are requested have been approved by other States. If so, please provide the following: a. State(s)that approved the depreciable lives; and REDACTED EIGHTH PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 3 JANUARY 31, 2025 b. Case number, or application number that outlines the depreciable lives approved. REQUEST NO. 156: In reference to Company's response to Staff Production Request No. 24,please provide the following: a. A copy of the money pooling agreement; b. A copy of the Company's cost savings analysis for consolidating bank accounts with the parent company; and c. The location where Idaho customer deposits held. REQUEST NO. 157: In reference to Company Adjustment No. 8 -Payroll Overheads, please provide supporting workpapers in Excel format for the Company's calculation of overtime pay and stand-by pay for the test year and calendar years 2022, 2023 and 2024. REQUEST NO. 158: In reference to Company Adjustment No. 5 -Healthcare,please provide supporting workpapers in Excel format for the Calculated Employer Healthcare Costs on line no. 8 in Company Exhibit No. 10, Schedule 1. REQUEST NO. 159: In reference to Company Adjustment No. 9, please provide supporting documentation for the Basin 63 rental pool found in Company Exhibit No. 10, Schedule 1. REQUEST NO. 160: In reference to the Company's response to Production Request No. 3,please provide invoice and other supporting documents for Staff s selected samples of legal expenses found in"Attachment 1 Sample Legal Expenses." REQUEST NO. 161: In reference to the Company's response to Production Request No. 8,please provide invoice and other supporting documents for Staffs selected samples of injury and damage claims found in"Attachment 2 Sample Injuries & Damages." REDACTED EIGHTH PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 4 JANUARY 31, 2025 REQUEST NO. 162: In reference to the Company's response to Production Request No. 25, please provide invoices, receipts and other supporting documents f'or Staff s selected P- card charges found in"Attachment 3 Sample P-Card Charges." REQUEST NO. 163: Please provide the annual amount of legal expenses paid to outside counsel for Veolia Water Idaho for the years 2019 through 2024. DATED at Boise, Idaho, this 3 1" day of January 2025. Chris Burdin Deputy Attorney General I:\Utility\UMISC\PRDREQ\VEO-W-24-0I PR#8(Redacted)docx REDACTED EIGHTH PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 5 JANUARY 31, 2025 CERTIFICATE OF SERVICE D SO I HEREBY CERTIFY THAT I HAVE THIS � DAY OF JANUARY 2025, SERVED THE FOREGOING EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO VEOLIA WATER, IDAHO, INC. (REDACTED)W/O CONFIDENTIAL ATTACHMENTS, 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.njugunakveolia.com E-MAIL: prestoncarterg ivenspursle. mor an og odink ig venspursle memk i� venspursle. stephaniewg ivenspursle. AUSTIN RUESCHHOFF MARY R. GRANT THORVALD A NELSON DEPUTY CITY ATTORNEY AUSTIN W JENSEN BOISE CITY ATTORNEY'S OFFICE KRISTINE A.K. ROACH 150 N. CAPITOL BLVD. HOLLAND & HART LLP PO BOX 500 555 17TH ST STE 3200 BOISE, ID 83701-0500 DENVER CO 80202 E-MAIL: mr rg antgcityofboise.org E-MAIL: darueschhoffkhollandhart.com boisecityattomeykcityotboise.org tnelson e,hollandhart.com awj ensenghol l andhart.com karoachghollandhart.com acleegholl andhart.com STEVEN HUBBLE CLIMATE ACTION SENIOR MANGER ROBIN LEE-BEUSAN WATER RESOURCES PROGRAM COORDINATOR E-MAIL: shubble =,cityofboise.org rleebeusangcityof6oise.org PATRICIA JORDA N , SECRETARY CERTIFICATE OF SERVICE