20250224VEO to Staff 150_151_155_157_158_159_163.pdf

RECEIVED
Friday, February 21, 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 EIGHTH
PRODUCTION REQUEST OF
COMMISSION STAFF
)
Veolia Water Idaho, Inc. ("Veolia" or"Company")provides the following in response to
the Eighth Production Request of the Commission Staff dated January 31, 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
supplemental responses to Production Request Nos. 1, 80, and 126.
Dated: February 21, 2025.
VEOLIA WATER IDAHO,INC.
Preston N. Carter
Attorney for Veolia Water Idaho, Inc.
RESPONSE TO STAFF's EIGHTH PRODUCTION REQUEST PAGE 1 OF 2

CERTIFICATE OF SERVICE
I certify that on February 21, 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 EIGHTH PRODUCTION REQUEST PAGE 2 OF 2

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
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 10% overrun with
final project costs of$3,963,009.20 and a final approved budget of$3,899,774.81. Id at 61 e, Item
vii. Additionally,the initial approved budget for the project was $2,125,987.31.Id at 61 c, Item ii.
Please reconcile the difference between the initial approved budget and the final approved budget.
RESPONSE NO. 150:
The main differences between the initial budget and the final costs($3,964,852.87)were 1)paving
(Capital Paving invoices totaled approximately $1,094,516), and additional Miller's charges
(about $580,000), Veolia labor and benefits (the final balance was $145,586.99 of which some
portion was included in the initial estimate), and the fines charged by ACHD ($77,335).
VEO-W-24-01
IPUC DR 150
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Johns/Michaelson
REQUEST NO. 151:
Please answer the following regarding the number of private fire hydrants and test year revenue
from 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 from 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.
RESPONSE NO. 151:
a. In the Historic test year the Company served 2,967 private hydrants. At the end
of 2024, the Company served 2,978 private hydrants.
b. With respect to the difference between the number of private hydrants served
and billed by the Company, please see Data Response 151 Attachment 1, which
is a slide that was shared with PUC Staff on August 5, 2024. Please also refer to
Data Response No. 127. In the Historic Test Year, the Company billed the
equivalent of 162 private hydrants.
c. The $25,475 represents the actual revenue generated from Private Hydrant
customers during the Test Year as provided by the Company's Customer Care
and Billing (CC&B) system. The total revenue for rate 060-PVH for 12-month
ended August 31, 2024, was divided by the facility charge rate in effect and
further divided by 6 to account for bi-monthly billing to get to the equivalent
number of private hydrants billed in that period.
VEO-W-24-01
IPUC DR 151
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob/Cagle
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
b. Case number, or application number that outlines the depreciable lives approved.
RESPONSE NO. 155:
a. In rate proceedings before regulators in other states, recovery of depreciation expense for
shared assets is requested in the same manner as requested in this case. Depreciation
expense is allocated to the regulated entities based upon the Company's Cost Allocation
Manual as supported by the M&S affiliate agreement. Similar questions have been posed
by Staffs and intervening parties in at least some of those cases in conjunction with the
overall allocation of M&S costs. The depreciable lives of the M&S shared assets are not
specifically approved by other States as the M&S company provides services and access
to shared systems for all six of Veolia's regulated entities. The M&S company is required
to follow generally accepted accounting principles ("GAAP") in determining depreciation
rates applied to shared assets. The appropriate useful lives of the shared assets and the
assets are depreciated on a straight line basis and are based upon the asset life as GAAP
standards are applied.For example, costs related to implementation of software as a service
are capitalized in accordance with ASC 350 and are amortized over the term of the service
agreement. Another example relates to the M&S office for which leasehold improvements
are depreciated over the term of the office lease.
b. The vast majority of the Company's rate cases are settled without detail as to this specific
issue. As a result, the Company is unable to provide a specific case in which this was
discussed. Please also see the response to part a.
VEO-W-24-01
IPUC DR 155
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
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.
RESPONSE NO. 157:
Please see Attachment 1.
VEO-W-24-01
IPUC DR 157
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bucci
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.
RESPONSE NO. 158:
Please see the attachment for the workpaper supporting the Calculated Employer Healthcare
Costs.
VEO-W-24-01
IPUC DR 158
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bucci
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.
RESPONSE NO. 159:
Please refer to Data Request No. 88 Attachment 1 for the supporting documentation of the
Basin 63 rental pool.
VEO-W-24-01
IPUC DR 159
Page 1 of 1

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
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.
RESPONSE NO. 163:
Please note amounts do not include any accrual or other journal entries and are only the Accounts
Payable vouchers posted for the calendar year.
YEAR OPEX TOTAL CAPEX/DEFERRAL GRAND TOTAL
TOTAL
2019 $80,762 $369,694 $450,456
2020 $91,157 $337,266 $428,423
2021 $192,907 $346,596 $539,503
2022 $105,811 $192,339 $298,150
2023 $326,252 $356,199 $682,451
2024 $103,730 $219,659 $323,389
VEO-W-24-01
IPUC DR 163
Page 1 of 1