20250130VEO to Staff 135-142.pdf

RECEIVED
Thursday, January 30, 2025
Preston N. Carter, ISB No. 8462 IDAHO PUBLIC
Morgan D. Goodin, ISB No. 11184 UTILITIES COMMISSION
Megann E. Meier, ISB No. 11948
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarterk ig venspursley.com
morgan og odin(akgivenspursley.com
memk ig venspursle
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 FIFTH PRODUCTION
REQUEST OF COMMISSION STAFF
)
)
Veolia Water Idaho, Inc. ("Veolia" or"Company")provides the following in response to
the Fifth Production Request of the Commission Staff dated January 9, 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. In addition, the sharefile site contains an
update to the response to Production Request No. 41.
Dated: January 30, 2025.
VEOLIA WATER IDAHO, INC.
Preston N. Carter
Attorney for Veolia Water Idaho, Inc.
RESPONSE TO STAFF's FIFTH PRODUCTION REQUEST PAGE I OF 2

CERTIFICATE OF SERVICE
I certify that on January 30, 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 FIFTH PRODUCTION REQUEST PAGE 2 OF 2

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Michaelson
REQUEST NO. 135:
Please provide an updated Company Exhibit No. 5 based on a Test Year using actuals through
December 31, 2024, by updating the Company's workpaper file "05-VEO-W-24-01 Revenue
Exhibits-Workpapers." Please provide in electronic format with formulas enabled and include
actual customer counts and customer consumption through December 31, 2024
RESPONSE NO. 135
Please refer to Data Request No 135 Attachment 1.
VEO-W-24-01
IPUC DR 135
Page I of I

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Hatch
REQUEST NO. 136:
Please provide an updated Company Cost of Service Study ("COSS")based on a Test Year using
actuals through December 31, 2024, by updating the Company's workpaper file"0 1-VEO-W-24-
01 Cost of Service Exhibits-Workpapers." Please provide in electronic format with formulas
enabled.
RESPONSE NO. 136:
Please see Data Request No. 136 Attachment 1, Exhibit 13 Cost of Service Exhibits Workpapers
Updated to reflect the information provided in response to Data Request No. 137.
VEO-W-24-01
IPUC DR 136
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Michaelson/Njuguna/ArpBucci/Wilson/Jacob
REQUEST NO. 137:
Please provide an update to the Company's revenue requirement model with actual expenses,
rate base, etc. through December 31, 2024.
RESPONSE NO. 137:
Please see the following Attachments for the updated Revenue Requirement model to December
31, 2024, and accompanying supporting Exhibits also updated through December 31, 2024.
Attachment 1 Exhibit No. 9-Revenue Requirement Workpapers
Attachment 2 Exhibit No. 10- O&M Expenses Workpapers
Attachment 3 Exhibit No.I 1-Rate Base Workpapers
Revenues-Please see Data Request No.135 Attachment 1
VEO-W-24-01
IPUC DR 137 CONFIDENTIAL
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Hatch
REQUEST NO. 138:
In Company Witness Hatch's Direct Testimony, page 9, it states, "based on currently available
data,there are not discernable factors that suggest Veolia Water Idaho's different customer classes
cause costs to be incurred by the Company differently,negating the need for separate rate classes,
and therefore different rate schedules."Please respond to the following:
a. Please explain and provide the currently available data that shows there are no
discernable factors that suggest Veolia Water Idaho's different customer classes cause
costs to be incurred differently by the Company; and
If this statement is referring to the customer classes (Residential, Commercial, Public Authority,
Private Fire) used in the COSS provided in this case, please explain why the Company believes
the Residential and Commercial Classes do not cause the Company to incur costs differently when
the results of the COSS suggests an increase of 24.7 percent for Residential and 16.9 percent for
Commercial
RESPONSE NO. 138:
The request does not accurately represent Company Witness Hatch's Direct testimony on page 9,
which states in full context:
"First, as discussed in more detail below, based on currently available data, there
are not discernable factors that suggest Veolia Water Idaho's different customer
classes cause costs to be incurred by the company differently,negating the need for
separate rate classes,and therefore different rate schedules. Currently available data
suggests that,at this juncture,meter size may be the best indicator of cost causation,
consistent with Veolia Water Idaho's General Service Metered rate,which includes
a meter charge that increases with meter size.'
As stated in the Direct Testimony of Company Witness Hatch, the Company examined:
• Advanced Metering Infrastructure ("AMI") data for the Veolia Water Idaho system, which
provides hourly consumption reads;
• billing data,which provides bi-monthly readings;
VEO-W-24-01
IPUC DR 138
Page 1 of 3

• Ada County parcel data,which is maintained by the Ada County Assessor's office and
includes over two-hundred property descriptors.
Please refer to Exhibit No. 13, Schedule 7 for additional information about the data used in the
analysis.
The Company's analysis utilized data analytics to determine the explanatory power of the
data by performing regression analyses (linear and tree) and cluster analyses (simple and multi-16
dimensional). Please refer to Exhibit No. 13, Schedule 7 starting at page 23 of 35 for graphical
representations of the data outputs. The violin plots on pages 26-28 show certain asymmetric
properties that indicate currently available AMI data are not statistically representative of the
Company's billing data,which suggests that at this juncture,using AMI data,which is the only
available hourly interval data available for precise peaking measurements, is not necessarily
representative of the Company's larger system. In this instance,relying solely on AMI data would
likely lead to inaccurate conclusions about data correlations. Charts on pages 32 to 35 are cluster
charts that,based on currently available data, do not show any discernable clusters. If there were
strong relationships in the data, one would expect to see a few distinct clusters. Because there are no
distinctive clusters,there is little statistical relationship among a few or even many variables, i.e.,
usage,peaking behavior,home, or lot size, etc. Thus,because of the lack of clustering as can be seen
on page 29, and because there is somewhat even dispersion of usage and peaking behavior across
meter sizes,based on currently available data, it appears that meter size is currently the best indicator
of usage behavior.
With respect to the request regarding the increase of 24.7 percent for Residential and 16.9
percent for Commercial, it is unclear what the question is,particularly in the full context of Ms.
VEO-W-24-01
IPUC DR 138
Page 2 of 3

Hatch's testimony. The revenue increase percentages for each class are outcome of a multitude of
factors such as revenues; which are in turn dependent on a number of factors such as rate design,
usage, customer count, etc.; and the COSS which is also dependent on a multitude of factors and
assumptions, including customer classes, which as discussed above, are defined by the Company's
tariff and is based on data consistent with the Company's billing system. The Company does not
dispute that there will be differences in how customers cause the system to incur costs, and as
suggested by the Company's analysis on currently available data,meter size may be the best
indicator. Please refer to Exhibit 13, Schedule 6C to see the Company's breakout of meter sizes by
customer class.
VEO-W-24-01
IPUC DR 138
Page 3 of 3

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Hatch
REQUEST NO. 139:
On page 10 of Company Witness Hatch's Direct Testimony, it states, "Veolia Water Idaho's use
of a general service rate is consistent with water utility practices in other jurisdictions." Please
respond to the following:
a. Please provide a list of jurisdictions with similar characteristics as Company's service
area that use a single general service rate for all customers outside of Public Authority
and Private Fire; and
Please provide a list of jurisdictions with similar characteristics as the Company's service area that
use different rate structures other than a single general service rate for all customers outside of
Public Authority and Private Fire.
RESPONSE NO. 139
The request as written is very broad and requests legal research which has not been performed.
For clarification, the term "jurisdiction" is used in Ms. Hatch's direct testimony to describe the
legal jurisdiction of various state public utility commissions. However, examples of state public
utility commissions which have approved general service rates for other of Veolia's utilities are
the New Jersey Board of Public Utilities, and the Delaware Public Service Commission.
Notwithstanding augmentations for acquired systems that have legacy rates and have not yet come
into rate harmonization, general service rates can be found in the tariff of Veolia Water, New
Jersey,Inc. and Veolia Water,Delaware,Inc. An example of a water utility that utilizes something
other than general service rates may be found in the tariff of Veolia Water,New York, Inc.
VEO-W-24-01
IPUC DR 139
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Michaelson
REQUEST NO. 140:
In his Direct Testimony, pages 6-7, Company Witness Michaelson discusses modeling customer
usage based on Commission's suggested improvements in Case No. VEO-W-22-02. Please
explain and provide all workpapers, models, and data used by the Company to create the models
using these suggestions. Please include in native format with all formulas enabled.
RESPONSE NO. 140:
The Company prepared various consumption normalization regression scenarios utilizing monthly
Palmer Z readings,Idaho unemployment rate,national unemployment rate,national average wage
index and national consumer price index percentage changes. Results utilizing monthly Palmer Z
readings for Residential customers are shown on IPUC DR 140 Attachment 1. Results utilizing
monthly Palmer Z readings for Commercial customers are shown on IPUC DR 140 Attachment 2.
Many of the results utilizing monthly Palmer Z readings show very low R-squared values. Results
utilizing the other variables are shown on IPUC DR 140 Attachment 3. In many cases the
regression calculations indicated a lower R-squared value,higher P value, or both,which suggests
lower statistical relevance. Because of the wide array of results using these other variables, the
Company selected the methodology (using Palmer Z only) utilized in the past several rate cases,
in the instant case. As mentioned in Direct Testimony, the Company is open to meeting with
IDPUC Staff periodically before the next rate case filing to explore strategies to further refine the
calculation.
VEO-W-24-01
IPUC DR 140
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REQUEST NO. 141:
Please provide all property tax assessments and bills for 2024.
Please also include any property tax settlements with the Idaho State Tax Commission
RESPONSE NO. 141:
Please see attachment DR No 1412024 Property Tax Assessments.pdf for the 2024 property tax
assessments and bills. Additionally, see attachment DR No 141 2024 Veolia Water Idaho
Property Tax Assessment Valuation.pdf for the 2024 Idaho State Tax Commission Property Tax
Assessment Valuation is provided. There are no recent or pending property tax settlements.
VEO-W-24-01
IPUC DR 141
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Hatch
REQUEST NO. 142:
Please refer to Exhibit No. 13, Schedule 1,provided in the Direct Testimony of Company Witness
Hatch.
a. Please explain the criteria and characteristics that the Company uses to classify
customers into the Residential, Commercial, Public Authority, and Private Fire
classes; and
Please explain if the Company has evaluated different rate schedules for the different customer
classes identified in Exhibit No. 13, Schedule 1.
RESPONSE NO. 142:
As stated in the Direct Testimony of Company Witness Hatch, the customer classes used in the
Cost of Service Study (COSS) are consistent with the billing system of Veolia Water Idaho, Inc.
(Company). Criteria and characteristics utilized in the Company's billing system, and therefore
the customer classifications in the COSS found in Exhibit No. 13, Schedule 1, are provided for in
the Tariff of Veolia Water Idaho, Inc. (Company). Please refer to Sheet.Nos. 37-38 of Exhibit No
2, Schedule 1, as well as Sheet Nos. 36-37 of Exhibit No. 2, Schedule 2.
As stated in the Direct Testimony of Company Witness Hatch, a COSS utilizes groups, or
classes of customers, with similar water-use characteristics for cost allocations because it is not
practical, nor often possible due to the nature of utility costs, to determine cost responsibility or
rates for each individual customer. As further explained in her testimony, based on currently
available data, there are not discernable factors that suggest Veolia Water Idaho's different
customer classes cause costs to be incurred by the company differently, negating the need for
separate rate classes, and therefore different rate schedules. Currently available data suggests that,
VEO-W-24-01
IPUC DR 142
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at this juncture,meter size may be the best indicator of cost causation,consistent with Veolia Water
Idaho's General Service Metered rate, which includes a meter charge that increases with meter
size. Regardless of data outcomes, should alternative customer classifications, and therefore
different rate schedules,be considered, additional considerations such as those outlined in,but not
limited to, Exhibit No. 13, Schedule 7 should be weighed.
VEO-W-24-01
IPUC DR 142
Page 2 of 2