20250213Staff 172-174 to VEO.pdf

RECEIVED
Thursday, February 13, 2025 12:19:18 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 ) TENTH 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
THURSDAY, FEBRUARY 27, 2025.1
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
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0314.
TENTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 1 FEBRUARY 13, 2025

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
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. 172: Please provide the date and time that on-call employees were
called out for emergencies during 2023 and 2024. Please provide your response in Excel format.
REQUEST NO. 173: Referring to the Company's response to Production Request No.
24, please provide the annual reconciliation of the money pool funds for 2021, 2022, 2023, and
2024 when available.
REQUEST NO. 174: Please provide copies of the power bills for each service point for
the following months:
a. February 2023;
b. May 2023;
c. December 2023;
d. March 2024;
e. July 2024; and
f. November 2024.
DATED at Boise, Idaho, this 131h day of February 2025.
tA,
Chris Burdin
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\VEO-W-24-01 PR#10.docx
TENTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO, INC. 2 FEBRUARY 13, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I DAY OF FEBRUARY 2025,
SERVED THE FOREGOING TENTH 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.njugunagveolia.com
E-MAIL: prestoncarter�k ig venspursley.com
morgan og odin(a ig venspursle.ccom
mem(k ig venspursley.com
stephaniewg ig_venspursle com
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: mrgrantkcityofboise.org
E-MAIL: darueschhoffkhollandhart.com boisecityattomeygcityofboise.org
tnelson(khollandhart.com
awj ensenghol l andhart.com
karoachkhollandhart.com
acleeka hollandhart.com
STEVEN HUBBLE
CLIMATE ACTION SENIOR MANGER
ROBIN LEE-BEUSAN
WATER RESOURCES PROGRAM
COORDINATOR
E-MAIL: shubble(a,cityofboise.org
rleebeusan&cityofboise.org
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE