20250224Micron 1-35 to Veolia.pdf

RECEIVED
Monday, February 24, 2025
IDAHO PUBLIC
Austin Rueschhoff, ISB No. 10592 UTILITIES COMMISSION
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
Kristine A.K. Roach
HOLLAND&HART LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: [e-mail]
[e-mail]
a@ [e-mail]
[e-mail]
Attorneys for Micron Technology, 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. ) MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUESTS
TO VEOLIA WATER IDAHO, INC.
Micron Technology, Inc. ("Micron" or"Intervenor"), by and through its counsel, Holland
& Hart LLP, submits the attached interrogatories and requests for the production of documents to
Veolia Water Idaho, Inc. ("Veolia"). The following response date, definitions, and instructions
apply to the enclosed interrogatories and requests for production of documents.
In addition to the written copies provided as responses to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
RESPONSE DATE,DEFINITIONS AND INSTRUCTIONS
Please respond to these interrogatories and requests for production of documents by March
17, 2025.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -1- February 24, 2025

DEFINITIONS
1. "Veolia Water Idaho, Inc.," "Veolia," "VWID," "the Company," or "you" means Veolia
Water Idaho, Inc. and the employees, officers, directors, agents, consultants, attorneys and
all persons acting under contractual arrangement with or acting or purporting to act on
behalf of Veolia.
2. "Agreement"means any contract, written or oral, or any non-contractual understanding.
3. "And/Or" will be construed disjunctively or conjunctively as necessary so that the scope
of these interrogatories is as broad as possible and includes any information which might
be constructed to be outside their scope.
4. "Communication" should be interpreted as broadly as possible to include, but not be
limited to, all forms of communication, whether written, printed, oral, pictorial, electronic
or otherwise and by any means or type whatsoever.
5. "Date" shall mean the exact day, month, and year if ascertainable, or if not the best
approximation thereof in relation to other events.
6. "Document" and "documentation" should be interpreted as broadly as possible, including
the original or any copy,regardless of origin or location, of any book,pamphlet,periodical
publication, letter, scrapbook, diary, calendar, canceled check, photograph, form,
memorandum, schedule, tax return, telegram, telex, report, record, order or notice of
governmental action of any kind, study, minutes, logs, graph, index, tape, disc, internal
operating manual, data sheet or data processing card, or any other written, recorded,
transcribed, punched, taped, filmed, graphic or retrievable matter or data of any kind,
however produced or reproduced, to which you have or have had access. This definition
includes all documents which have been created and/or which reside in any type of
electronic format.
Any document that is not exactly identical to another document for any reason (such as
marginal notations or deletions) should be considered a separate document.
As to any document related to the matters addressed herein that is not currently in your
possession but that you know or believe such a document exists, you are requested to
identify and indicate to the best of your ability its present or last known location or
custodian.
7. To "describe, "detail," or "state" shall mean to relate as completely as possible each and
every act, omission, incident, event, condition, circumstance, decision, and/or thing
relating directly or indirectly to the subject of the explanation including all pertinent dates.
8. To "explain" means to make known in detail, to make clear the cause or reason of any
account for each act, omission, incident, event, condition, circumstance, decision, and/or
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -2- February 24, 2025

thing relating directly or indirectly to the subject of the explanation including all pertinent
dates.
9. Any request to "identify" or"provide" should be interpreted to mean:
a. With respect to a natural person, that person's full name, title,job description, and
business and home address. Where the identification pertains to a past period, as
to each person identified who is still in your employ, or the employment of the
group with which such person is identified in response to any requests, provided,
in addition,that person's title and job description as of the time of such past period.
Where the person is no longer in your employ or the employment of the group with
which such person is identified in response to any request, provide that person's
affiliate, position, home and business address, if known, or if not known, such
person's last known affiliation, position, home and business address, or portions
thereof as may be known.
b. With respect to an entity other than a natural person, that entity's name, business,
type of entity,present status and present or last known address.
C. With respect to a document,that document's title,date,author(and,if different,the
signer), addresses, recipients, or other persons who assisted in the preparation,
subject matter or general nature, and any amendments thereto,present location and
custodian,whether or not such document is in the respondent's possession,custody
or control and whether or not the document is claimed to be privileged. The final
version and each draft of each document should be identified and produced
separately. Each original and each non-identical copy(bearing marks or notations
not found on the original) of each final version and draft of each document should
be identified and produced separately.
d. With respect to a physical facility,the location of the facility,the intended purpose
of the facility, the actual use of such facility, the operating dates of the facility, the
installation date of the facility, the date utilization of the facility terminated if
applicable, and whether the facility is subject to the jurisdiction of the Idaho Public
Utilities Commission, the Federal Energy Regulatory Commission, or any other
regulatory body.
10. "Person or Entity" should be interpreted to denote, unless otherwise specified, any natural
person, firm, corporation, association, group, individual or organization of any type
whatsoever.
11. "PUC" or"Commission"means the Idaho Public Utilities Commission.
12. "Record" or "Records" includes any regulation, formal or informal, official or unofficial
memorandum, document or written preservation of any events, actions taken or rejects,
decisions and details thereof relating to the subject matter of the question and your response
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -3- February 24, 2025

including electronic data and e-mail. A copy of the original "record" is preferred; stating
the substance thereof will suffice where a copy cannot be made and is not available.
13. "Relating To" or "Related To" means pertaining to, presenting, discussing, commenting
on, analyzing, or mentioning in any way.
GENERAL INSTRUCTIONS
1. Interrogatories and requests for production must be answered with particularity and in
detail.
2. Interrogatories and requests for production must be answered separately and fully in
writing under oath within twenty-one (21) days after service in accordance with IDAPA
31.01.01.225.
3. Interrogatories and requests for production must be signed by the person upon whose
personal knowledge responses are based or who helped in any way in answering these
interrogatories and requests for production.
4. You must provide the names of any other persons upon whose personal knowledge
responses are based or who helped in any way in answering these interrogatories and
requests for production.
5. In making your answers,you must produce all relevant documents and data by attachment
or by identifying the documents which relate to your answers. You must also clearly
identify each interrogatory to which the document relates.
6. These interrogatories and requests for production are continuing in nature and in the event
any information provided in an answer is changed or supplemented by future developments
or other factors, you must file appropriate supplemental answers.
7. In answering these interrogatories and requests for production you should furnish all
information which is in your possession, custody or control including, but not limited to,
information from any files, records, or documents in the possession of your attorneys,
consultants, staff, accountants, experts, employees, former employees, and other agents.
8. These interrogatories and requests for production should be answered based on your
personal knowledge, the personal knowledge of your attorneys, consultants, staff,
accountants, experts, employees, former employees, and any other agents as appropriate or
available and with reference to the sources described above.
9. If the respondent is not a witness who has filed written direct testimony, please indicate
which of the company's witnesses will be prepared to answer these questions on the stand.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -4- February 24, 2025

10. In addition to a hard copy,please provide an electronic copy of your responses in Microsoft
Word. Where responses are prepared using spreadsheet software, please provide an
electronic copy in Microsoft Excel format.
11. If after exercising due diligence you are unable to answer any interrogatory or to produce
any document requested, you must explain your inability in detail.
12. If you object to any interrogatory or request for production, you may serve written
objections on Micron as provided in IDAPA 31.01.01.225, identifying the subject matter
objected to and stating with particularity the reasons for the objections. In addition, the
objections and the answers must be contained in separate pleadings with each clearly
identified as an objection or answer. The service of an objection will not excuse you from
answering the remaining interrogatories or responding to the remaining requests for
production for which no objection is stated.
13. If any responses to these interrogatories or requests for production have already been
provided in prior discovery in this matter, please direct Micron to the specific discovery
request and response where such response can be found.
14. Copies of the responses and any and all documents produced should be provided to:
Thorvald A. Nelson
Austin Rueschhoff
Austin W. Jensen
Kristine A.K. Rocah
Holland&Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: tnelson(d),hollandhart.com
darueschhoff khollandhart.com
awj ensen(ahollandhart.com
karoachkhollandhart.com
aclee(khollandhart.com
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: Please refer to the Direct Testimony of Maryanne Hatch at 5:6-7.
a. Please provide a copy or link to the "Principles of Water Rates, Fees, and
Charges, Manual of Water Supply Practices ("M1 Manual").
REQUEST NO. 2: Please refer to the Direct Testimony of Harold Walker, III. Please
provide copies of the documents cited in: footnote 10 on page 12,footnote 13 on page 23,footnotes
14 and 15 on page 23, footnote 16 on page 24, footnote 19 on page 25, footnote 20 on page 26,
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -5- February 24, 2025

footnotes 23 and 24 on page 29, footnotes 25 and 26 at page 32, footnote 27 at page 33, footnotes
28 and 29 at page 34, footnote 30 at page 35, footnote 31 at page 36, .
REQUEST NO. 3: Please provide the exhibits of all witnesses who filed direct testimony
on behalf of Veolia Water Idaho, Inc. ("VWID" or "Company") in electronic spreadsheet format
with all formulas and links intact.
REQUEST NO. 4: Please provide the workpapers of all witnesses who filed direct
testimony on behalf of VWID in electronic spreadsheet format with all formulas and links intact.
REQUEST NO. 5: Please update the Company's exhibits and schedules which include
forecasted data for the four-month adjustment period ending December 31, 2024,with actual data
for the four-month period ending December 31, 2024. Alternatively, please state when the
Company intends to true-up forecasted data with actual data.
REQUEST NO. 6: Please refer to page 3 of Michael Wilson's direct testimony which
states the test year payroll data is subject to true-up. Please provide the actual payroll data for the
test year in the categories Mr. Wilson describes on pages 3-5 of his direct testimony.
REQUEST NO. 7: Please refer to page 5 of Michael Wilson's direct testimony where he
discusses VWID's Annual Incentive Plan ("AIP"). Please provide the total amount of incentive
pay in the test year by goal or metric,the amount removed from the test year's cost of service, and
the remaining amount included in VWID's revenue requirement in this case.
REQUEST NO. 8: Please provide VWID's actual payouts and budgeted amounts of
incentive pay,by plan and by goal or metric, for the past five years. Please describe any variances
between actual and budgeted amounts.
REQUEST NO. 9: Please refer to page 12 of the Idaho Public Utilities Commission's
("Commission") Order in VWID's prior rate case, Case No. VEO-22-02, which reads, "Based
upon the record before it, the Commission cannot find that the amount the Company expended on
employee incentive pay in this case is reasonable. The Commission has no basis to quantify how
Veolia Values directly translates to customer benefits, nor the extent to which an employee's
personal goals and objectives improve the service provided to customers. When Veolia can
demonstrate that the metrics and criteria of its Incentive Program are transparent and readily able
to be reviewed, and provide a discernible customer benefit, the Commission will consider
including incentive payments for recovery in rates." Please explain how the Company has satisfied
the Commission's requirements around incentive pay in this proceeding.
REQUEST NO. 10: Please provide workpapers, in an electronic format with all formulas
and links intact, supporting witness Timothy Michaelson's 30-year regression analyses.
REQUEST NO. 11:Please provide copies of all publications and credit reports considered
by witness Harold Walker, III. This is an ongoing request for all subsequent testimonies filed by
this witness.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -6- February 24, 2025

REQUEST NO. 12: Please provide copies of all credit reports published by Standard &
Poor's ("S&P"), Moody's, and Fitch Ratings for VWID and Veolia Utility Resources LLC
("VUR"), issued over the last two years. This is an ongoing request.
REQUEST NO. 13: Please provide complete copies of credit reports issued by S&P,
Moody's, and Fitch Ratings over the last two years that discuss the current regulated utility
industry as reviewed by any VWID witness. If VWID witnesses have not reviewed the material,
please so state. This is an ongoing request.
REQUEST NO. 14: Please provide copies of all correspondence, presentations, and all
other materials that VWID, VUR, or its parent company provided to credit and equity analysts
over the last two years. This is an ongoing request.
REQUEST NO. 15: Please provide a projection of VWID's capital expenditures out over
the next five years, and an estimate of the sources of cash available to fund these capital
expenditures broken out by external debt markets, external equity infusions from its parent
company, retained earnings, depreciation expense, deferred taxes, and other sources (explain).
Please also include in this response the funding planned for debt maturity, retirements and/or
refinancing over this same time period.
REQUEST NO. 16: In electronic format with all formulas intact, please provide the
monthly average balances for construction work in progress and short-term debt for the most recent
13-month period and the test period. Please identify the amount of short-term debt included in the
regulatory capital structure, if any.
REQUEST NO. 17: Please provide the amount of capitalized interest estimated to be paid
during the test year related to construction projects.
REQUEST NO. 18: In electronic format with all formulas and links intact,please provide
VWID and VUR's five-year projected and five-year historical capital structure, capital
expenditures and capital funding. Please include a breakdown of all sources of equity capital
including retained earnings, paid-in capital, and debt capital, both long-term and short-term debt,
etc.
REQUEST NO. 19: If not already provided, in electronic spreadsheet format with all
formulas and links intact, please provide the calculations of all ratios included on page 2 of
Schedule 10. Please provide all financial statements used to derive these ratios.
REQUEST NO.20: In electronic format with all formulas and links intact,please identify
the Commission's approved capital structure,cost of capital and rate of return in VWID's last three
regulatory proceedings. Please identify the docket and order numbers.
REQUEST NO. 21: Please describe how VWID accesses external capital. If the
Company's external capital is provided by its parent company under a credit agreement, please
describe the terms of the credit agreement and the associated service fees.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -7- February 24, 2025

REQUEST NO. 22: Please provide the most recent senior secured, unsecured, and
corporate credit ratings of VWID and VUR, assigned by S&P, Moody's, and Fitch. Also, please
provide VWID's S&P business and financial risk profiles and identify the benchmark volatility
table (standard, medial or low) used by S&P and the benchmark risk grid (standard or low) used
by Moody's.
REQUEST NO. 23: To the extent not already provided, please provide in electronic
format with all formulas and links intact, VWID's and VUR's credit metric calculations relied on
by S&P and Moody's for the last five years and near-term projections if available. Please include
all financial statements used to derive these credit metrics. In addition, please provide S&P and
Moody's benchmark ranges for the credit metrics.
REQUEST NO. 24: Please state whether VWID's and VUR's regulated retail operations
have any goodwill asset on its balance sheet over the period 2019-2024. If affirmative, please
describe the merger and/or acquisition, and any impairment charges the companies have incurred
in the past.
REQUEST NO. 25: Please state whether VWID's and VUR's regulated retail operations
have any off-balance sheet debt such as purchased power agreements and operating leases. If the
answer is "yes," provide the amount of each off-balance sheet debt item and estimate the related
imputed interest and amortization expense associated with these off-balance sheet debt equivalents
specific to VWID's jurisdictional regulated retail water operations.
REQUEST NO. 26: Do any of VWID's outstanding long-term debt issues have call
provisions? If the answer is "yes,"please provide a list of the callable issues with the following:
a. Outstanding balance,
b. Issuance date,
C. Maturity date,
d. Coupon payment percent,
e. Annual interest expense, and
f. Call price (as a percent of par).
REQUEST NO. 27: Has VWID performed any debt refinancing feasibility studies on its
outstanding debt issues? If the answer is "yes,"please provide the following:
a. A detailed description of the results from the study,
b. A detailed description of the conclusion(s) made by VWID based on the
results of the study, and
C. All debt refinancing feasibility studies in electronic format with all formulas
and links intact.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -8- February 24, 2025

REQUEST NO. 28: Please refer to the Class Cost of Service Study("CCOSS")provided
in Exhibit No. 13, to Maryanne Hatch's direct testimony at Schedule 2, pages 1-3.
a. Please explain why Source of Supply expenses have not been allocated to
the Public Fire class.
b. Please explain why Water Treatment costs have not been allocated to the
Public Fire class.
C. Please confirm that potable water is used to serve the Public Fire class. If
not confirmed, please provide a detailed explanation supporting the
response.
d. Please explain why Source of Supply expenses have not been allocated to
the Private Fire class.
e. Please explain why Water Treatment costs have not been allocated to the
Private Fire class.
f. Please confirm that potable water is used to serve the Private Fire class. If
not confirmed, please provide a detailed explanation supporting the
response.
REQUEST NO. 29: Please refer to the CCOSS provided in Exhibit No. 13, to Maryanne
Hatch's direct testimony at Schedule 2, page 2.
a. Please identify the electric utilities from which the Company purchases
electricity.
b. For each electric utility identified in part a,please identify the tariff used to
provide service to the Company. For any applicable electric tariff that is
not publicly available,please provide a copy.
REQUEST NO. 30: Please refer to Exhibit No. 13, Schedule 6A,page 1.
a. Please confirm that Factor 3 is used to allocate costs associated with
Transmission and Distribution mains in the CCOSS. If not confirmed,
please provide a detailed explanation supporting the response.
b. Please confirm that Factor 3 does not include a maximum-hour
extra-capacity component. If not confirmed, please provide a detailed
explanation supporting the response.
REQUEST NO. 31: Please refer to Exhibit No. 13, Schedule 613,page 2.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -9- February 24, 2025

a. Please identify the diameters of mains included in the Transmission Mains
category on line 43.
b. Please provide all documents and analyses relied on to develop the length
of Transmission Mains shown on line 43.
C. To the extent not provided in response to part b., please provide the
calculation of the length of Transmission Mains identified on line 43.
Please provide the calculations in electronic spreadsheet format with all
formulas and links intact.
d. Please identify the diameters of mains included in the Distribution Mains
category on line 44.
e. Please provide all documents and analyses relied on to develop the length
of Distribution Mains shown on line 44.
f. To the extent not provided in response to part e., please provide the
calculation of the length of Distribution Mains identified on line 44. Please
provide the calculations in electronic spreadsheet format with all formulas
and links intact.
g. Please confirm that the length of mains identified on lines 43 and 44 are
stated in feet. If not confirmed,please identify the correct unit.
h. Please describe the Company's meter installation protocols in terms of
specifying the size of a main that is needed to connect a specific meter size
to its transmission system.
i. Please describe the Company's meter installation protocols in terms of
specifying the size of a main that is needed to connect a specific meter size
to its distribution system.
j. Please provide documentation describing the Company's meter installation
policies, including descriptions of the sizes of mains that can be used to
provide service safely and reliably to various meter sizes.
k. Please explain how the Company distinguishes between transmission and
distribution mains. For example, please describe how the function of a
transmission main differs from the function of a distribution main.
REQUEST NO. 32: Regarding the Commercial class:
a. Please explain whether any customers in the Commercial class are directly
served from a transmission main and are not served from distribution mains,
as those terms are defined in response to Data Request No. 31.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -10- February 24, 2025

b. If the response to part a. is affirmative, please identify the test year water
consumption associated with the customers served directly from
transmission mains.
REQUEST NO. 33: Regarding the Residential and Public Authority classes:
a. Please explain whether any customers in the Public Authority class are
directly served from a transmission main and are not served from
distribution mains, as those terms are defined in response to Data Request
No. 31.
b. If the response to part a. is affirmative, please identify the test year water
consumption associated with the Public Authority customers served directly
from transmission mains.
C. Please explain whether any customers in the Residential class are directly
served from a transmission main and are not served from distribution mains,
as those terms are defined in response to Data Request No. 31.
d. If the response to part a. is affirmative, please identify the test year water
consumption associated with the Residential customers served directly from
transmission mains.
REQUEST NO. 34: Please refer to Exhibit 13, Schedule 6D.
a. Please confirm the Company's CCOSS relies on a system maximum day
demand ratio based on an average of multiple years. If not confirmed,
please provide a detailed explanation supporting the response.
b. Does the Company agree that water systems are designed to meet the
highest water demand on the system, during the life of the system? Please
provide a detailed explanation supporting the response.
C. Does the Company agree that extra-capacity needed to meet the highest
system demand is driven by weather-sensitive customers? If the Company
does not agree, please provide a detailed explanation supporting the
response.
REQUEST NO. 35: Regarding rate design:
a. Please confirm that a single rate structure currently applies to all
Residential, Commercial, and Public Authority customers. If not
confirmed, please provide a detailed explanation supporting the response.
b. Does the Company agree that by using a single rate structure for all classes,
it is difficult to tie rates for each class to the results of the CCOSS. Please
provide a detailed explanation supporting the response.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -11- February 24, 2025

C. Has the Company considered implementing class-specific rates? If so,
please explain why the Company has chosen not to implement class-specific
rates. If the Company has not considered class-specific rates,please explain
why not.
d. Has the Company considered options other than an inclining block
volumetric rate structure? If so, please explain why the Company has
chosen not to implement another rate structure. If the Company has not
considered other rate structure options, please explain why not.
Respectfully submitted February 24, 2025.
HOLLAND & HART, LLP
By: 1). zjjjj,
ustin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen,ISB No. 11947
Kristine A.K. Roach
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -12- February 24, 2025

CERTIFICATE OF SERVICE
I hereby certify that on February 24, 2025, a true and correct copy of the within and
foregoing FIRST PRODUCTION REQUESTS OF MICRON TECHNOLOGY, INC. TO
VEOLIA WATER IDAHO, INC. was served in the manner shown to:
Veolia Water Idaho, Inc.
Preston N. Carter David Njuguna
Morgan D. Goodin Director-Regulatory Business
Megann E. Meier Veolia Water M&S (Paramus), Inc.
Givens Pursley LLP 461 From Road, Suite 400
601 W. Bannock St. Paramus,NJ 07052
Boise, ID 83702 david.njugunakveolia.com
prestoncarter(ib ig venspursle.
morgan og odink ig venspursle,
mem(k ivgenspursley.com
Commission Staff Micron Technology, Inc.
Chris Burdin Austin Rueschhoff
Monica Barrios-Sanchez Thorvald A. Nelson
Idaho Public Utilities Commission Austin W. Jensen
11331 W. Chinden Blvd., Building 8, Kristine A.K. Roach
Suite 201-A Holland& Hart, LLP
Boise, ID 83714 555 17th Street, Suite 3200
chris.burdin(2,puc.idaho.gov Denver, CO 80202
secretaryApuc.idaho.gov darueschhoff(a�hollandhart.com
tnelson(a,hollandhart.com
awj ens ennhollandhart.com
karoachkhollandhart.com
aclee(ahollandhart.com
City of Boise
Mary R. Grant Steven Hubble
Deputy City Attorney Climate Action Senior Manager
Boise City Attorney's Office Robin Lee-Beusan
150 N. Capitol Blvd. Water Resources Program Coordinator
PO Box 500 shubblencityofboise.org
Boise, ID 83701-0500 rleebeusan(d),cityofboise.org
mr rg ant(ae,cityofboise.org
boisecityattorney(a),cityofboise.org
s/Adele Lee
33939134_vl
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO VEOLIA -13- February 24, 2025