20250509Direct York.pdf

RECEIVED
May 9, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF VEOLIA WATER IDAHO, INC. FOR A ) CASE NO. VEO-W-24-01
GENERAL RATE CASE )
Testimony in Support of Settlement Stipulation
Jessica A. York
On behalf of
Micron Technology, Inc.
May 9, 2025

1 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A Jessica A. York. My business address is 16690 Swingley Ridge Road,
3 Suite 140, Chesterfield, Missouri 63017.
4 Q WHAT IS YOUR OCCUPATION?
5 A I am a consultant in the field of public utility regulation and a Principal with the
6 firm of Brubaker & Associates, Inc. ("BAI"), energy, economic and regulatory
7 consultants.
8 Q PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND
9 EXPERIENCE.
10 A This information is included in Appendix A to my testimony.
11 Q ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING?
12 A I am appearing on behalf of Micron Technology, Inc. ("Micron").
13 Q WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING?
14 A The purpose of my testimony is to support the unanimous Stipulation and
15 Settlement ("Stipulation") filed by Veolia Water Idaho, Inc. ("Veolia" or
16 "Company") and the other Parties' to this proceeding on April 21, 2025. The
17 Stipulation resolves all revenue requirement, class cost of service, and rate
18 design issues in this proceeding.
' Parties to the case include Veolia, Staff for the Idaho Public Utilities Commission, the City of
Boise, and Micron (collectively, "Parties" or"Settling Parties").
York, Di 1
Micron Technology, Inc.

1 Q DO YOU RECOMMEND APPROVAL OF THE STIPULATION?
2 A Yes. I recommend approval of the Stipulation. The Stipulation is a
3 comprehensive agreement that represents give and take among the parties and
4 resolves the revenue requirement, cost allocation, and rate design issues that
5 would have likely been raised by the Parties in this proceeding. The Stipulation
6 is the result of arms-length negotiations between the Settling Parties in order to
7 reach a comprehensive settlement. Notably, the Stipulation is within the range of
8 outcomes that likely would have resulted from a litigated case.
9 In sum, the Stipulation should be approved for the following reasons:
10 1. The stipulated overall revenue requirement will result in a level of revenue for
11 Veolia that is just and reasonable and will allow the utility a reasonable
12 opportunity to earn a fair return on its investments. The revenue requirement
13 adjustments contained in the Stipulation represent a compromise on the
14 issues that would have been contested in this case.
15 2. The stipulated revenue allocation reflects a compromise between the parties
16 to resolve the issues that would have been contested in this case and is
17 reasonably based on cost of service principles. The compromise revenue
18 allocation in the Stipulation is within the range of what would have likely been
19 the parties' litigated positions in this case.
20 3. The stipulated rate design for the various customer rates is fair, reasonable,
21 and in the public interest.
22 4. The Stipulation includes Veolia's commitment to participate in a series of
23 workshops with the Settling Parties to include topics such as weather
24 normalization methodology and a detailed load study. The outcome of these
25 workshops will result in better data in future water cases on which Veolia and
26 interested parties can propose more accurate revenue allocation and rate
27 design methodologies.
28 5. The Stipulation is likely to reduce the Idaho Public Utilities Commission's
29 ("Commission") administrative burden and save rate case expenses for all
30 parties.
York, Di 2
Micron Technology, Inc.

1 Q DID MICRON HAVE CONCERNS ABOUT ANY SPECIFIC COMPONENTS OF
2 THE COMPANY'S PROPOSED REVENUE REQUIREMENT?
3 A Yes. Micron had several concerns with the Company's originally proposed
4 revenue requirement, which are resolved by the compromise represented in the
5 Stipulation. First, Micron disagreed with the Company's proposed overall Rate of
6 Return ("ROR") of 7.47 percent, based on a requested Return on Equity ("ROE")
7 of 10.2 percent, and a common equity ratio of 52.78 percent. Micron was
8 concerned that Veolia's requested ROE was excessive based on current market
9 conditions. Micron conducted an independent analysis of Veolia's proposed
10 ROE and concluded that we would, in the context of a litigated case, advocate for
11 an ROE in the range of 9.3 percent. Further, we believe that a common equity
12 ratio closer to 50 percent is reasonable for a water utility. The Stipulation
13 provides for a reasonable compromise between these positions and
14 recommends the Commission approve an overall ROR of 7.05 percent.
15 In addition, Micron had several other concerns with the Company's
16 proposed revenue requirement including the Company's proposal to recover
17 portions of its Annual Incentive Plan ("AIP") that were previously disallowed by
18 the Commission and the Company's adjustment to test year revenues due to
19 declining use. In total, Micron estimated that its adjustments related to these
20 issues would have reduced the Company's claimed revenue deficiency by
21 approximately $4 million. The adjustments are, in many instances, incremental
22 to other adjustments that Micron understands that the Commission Staff ("Staff")
23 and other intervenors would have raised. The Stipulation addresses the most
24 significant of Micron's various revenue requirement adjustments and reflects a
25 reasonable compromise of the various issues presented in this proceeding and
26 the Parties' positions on those issues.
York, Di 3
Micron Technology, Inc.

1 Q PLEASE DESCRIBE THE STIPULATION'S RESOLUTION OF THE
2 COMPANY'S REVENUE REQUIREMENT IN THIS PROCEEDING.
3 A The Stipulation resolves the revenue requirement issues that would have been
4 raised by parties in this rate case.
5 The Company's original filing in this docket proposed to increase base
6 rate revenues by $11 million, or a system average increase of 19.84 percent.
7 Under the Stipulation, the increase in total revenue was reduced to $7 million, or
8 a system average increase of 12.4 percent.
9 The Stipulation reflects several adjustments to the Company's originally
10 filed revenue requirement, some of which are summarized on pages 2 through 4
11 of the Stipulation. The Staff and intervenors, including Micron, provided a
12 thorough and detailed assessment of the Company's cost of service in the
13 settlement negotiations. Staff's and the other intervenors' review and input was
14 very useful in identifying and reaching an agreement on the revenue requirement
15 adjustments included in the Stipulation.
16 Q DID THE SETTLING PARTIES REACH AN AGREEMENT ON THE REVENUE
17 ALLOCATION?
18 A Yes. The Settling Parties agreed to accept the class revenue apportionment
19 proposed by the Company, and Stipulation Exhibit No. 1 identifies the settlement
20 rates agreed to by all Settling Parties.
21 The settlement reflects an equal percent increase of 12.4 percent across
22 the Residential, Commercial, and Public Authority rate classes. While the
23 Company's class cost of service study shows that Commercial customers should
24 receive an increase below the system average, Micron has accepted an
25 across-the-board increase for purposes of this case, for reasons described in
York, Di 4
Micron Technology, Inc.

1 greater detail below, including Veolia's commitment to conduct a load study
2 which will improve its class cost of service methodology and allow for more
3 accurate revenue allocation proposals in future rate cases.
4 Q DID THE SETTLING PARTIES AGREE UPON A PARTICULAR COST OF
5 SERVICE STUDY?
6 A No. The Settling Parties did not agree on any particular class cost of service
7 methodology. Instead, the Settling Parties accepted the Company's proposed
8 revenue allocation to adjust rates and charges for each customer class.
9 Micron believes certain refinements to the class cost of service study are
10 necessary to improve its accuracy. For example, the Company has not allocated
11 Source of Supply or Water Treatment costs to the Public or Private Fire classes.
12 To the extent that potable water is used to serve these classes, then they should
13 receive an allocation of these costs. In addition, Micron identified that the
14 depreciation expense for Transmission and Distribution ("T&D") mains should be
15 allocated using Factor 6 (which includes base, maximum day, and maximum
16 hour extra-capacity demands), rather than Factor 3 as used by the Company
17 (which includes only base and maximum day extra-capacity demand). The same
18 correction would apply to T&D mains rate base.
19 Regarding rate design, the Company applies a single rate structure to its
20 Residential, Commercial, and Public Authority classes. Therefore, it is
21 challenging to tie rates for each class to the respective class cost of service.
22 Micron believes it would be reasonable for the Company to explore class-specific
23 rates to resolve this issue.
24 The Settling Parties agreed to hold workshops to address certain issues,
25 such as a framework for conducting a load study, which could provide useful
York, Di 5
Micron Technology, Inc.

1 information to inform future refinements to the Company's class cost of service
2 study and rate design. As a result, Micron has set aside its concerns about class
3 cost of service and rate design for the purposes of this case in order to reach a
4 settlement that includes Veolia's commitment to conduct a load study to improve
5 its class cost of service methodology in future rate cases so that Commission
6 Staff and interested parties have additional data on which to base revenue
7 allocation and rate design proposals.
8 Q IN YOUR OPINION, IS THE STIPULATION REASONABLE AND IN THE
9 PUBLIC INTEREST?
10 A Yes. The Settling Parties compromised on their various positions in order to
11 reach a stipulation that economically and efficiently resolves what would have
12 been contested issues in this case. The Stipulation provides the Company with
13 updated rates to better reflect current costs and the ability to economically
14 finance new investments in infrastructure while maintaining just and reasonable
15 rates for its customers. Furthermore, approving the Stipulation will result in
16 efficiencies for the Commission and Parties, and reduced rate case expenses to
17 the benefit of all Veolia customers.
18 Q DOES THIS CONCLUDE YOUR TESTIMONY IN SUPPORT OF THE
19 SETTLEMENT STIPULATION?
20 A Yes, it does.
York, Di 6
Micron Technology, Inc.

Appendix A - Qualifications of Jessica A. York
1 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A Jessica A. York. My business address is 16690 Swingley Ridge Road, Suite 140,
3 Chesterfield, MO 63017.
4 Q PLEASE STATE YOUR OCCUPATION.
5 A I am a consultant in the field of public utility regulation and a Principal with the firm of
6 BAI, energy, economic and regulatory consultants.
7 Q PLEASE IDENTIFY THE JURISDICTIONS IN WHICH YOU HAVE PREVIOUSLY
8 SPONSORED TESTIMONY.
9 A I have sponsored expert testimony in front of the Idaho Public Utilities Commission,
10 the Illinois Commerce Commission, Indiana Utility Regulatory Commission, the Iowa
11 Utilities Commission, the Kansas Corporation Commission, the Michigan Public
12 Service Commission, the Minnesota Public Utilities Commission, the Missouri Public
13 Service Commission, the Public Utilities Commission of Nevada, the Oklahoma
14 Corporation Commission, the Virginia State Corporation Commission, and the Public
15 Service Commission of Wisconsin.
16 Q PLEASE STATE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL
17 EMPLOYMENT EXPERIENCE.
18 A I graduated from Truman State University in 2008 where I received my Bachelor of
19 Science Degree in Mathematics with minors in Statistics and Actuarial Science. 1
20 earned my Master of Business Administration Degree with a concentration in Finance
21 from the University of Missouri-St. Louis in 2014.
Appendix A
York, Di 1
Micron Technology, Inc.

1 1 joined BAI in 2011 as an analyst. Then, in March 2015, 1 joined the
2 consulting team of BAI.
3 1 have worked in various electric, natural gas, and water and wastewater
4 regulatory proceedings addressing cost of capital, sales revenue forecasts, revenue
5 requirement assessments, class cost of service studies, rate design, and various
6 policy issues. I have also conducted competitive power and natural gas solicitations
7 on behalf of large electric and natural gas users, have assisted those large power and
8 natural gas users in developing procurement plans and strategies, assisted in
9 competitive contract negotiations, and power and natural gas contract supply
10 administration. In the regulated arena, I have evaluated cost of service studies and
11 rate designs proffered by other parties in cases for various utilities, including in Idaho,
12 Illinois, Indiana, Kansas, Wisconsin, and others. I have conducted bill audits, rate
13 forecasts and tariff rate optimization studies.
14 1 have also provided support to clients with facilities in deregulated markets,
15 including drafting supply requests for proposals, evaluating supply bids, and auditing
16 competitive supply bills. I have also prepared and presented to clients reports that
17 monitor the electric market and recommend strategic hedging transactions.
18 BAI was formed in April 1995. BAI and its predecessor firm have participated
19 in more than 700 regulatory proceedings in forty states and Canada.
20 BAI provides consulting services in the economic, technical, accounting, and
21 financial aspects of public utility rates and in the acquisition of utility and energy
22 services through RFPs and negotiations, in both regulated and unregulated markets.
23 Our clients include large industrial and institutional customers, some utilities and, on
24 occasion, state regulatory agencies. We also prepare special studies and reports,
25 forecasts, surveys and siting studies, and present seminars on utility-related issues.
Appendix A
York, Di 2
Micron Technology, Inc.

1 In general, we are engaged in energy and regulatory consulting, economic
2 analysis, and contract negotiation.
3 In addition to our main office in St. Louis, the firm also has branch offices in
4 Corpus Christi, Texas; Louisville, Kentucky; and Phoenix, Arizona.
Appendix A
York, Di 3
Micron Technology, Inc.

I DECLARATION OF JESSICA A. YORK
2 I, Jessica A. York, declare under penalty of perjury under the laws of the state of
3 Idaho:
4 1. My name is Jessica A.York.I am employed by Brubaker&Associates,Inc.
5 (`BAI") as a Principal and consultant in the field of public utility regulation.
6 2. On behalf of Micron Technology, Inc., I present this pre-filed testimony in
7 support of the settlement stipulation in this matter.
8 3. To the best of my knowledge, my pre-filed testimony in support of the
9 settlement stipulation is true and accurate.
10 I hereby declare that the above statement is true to the best of my knowledge and
11 belief, and that I understand it is made for use as evidence before the Idaho Public Utilities
12 Commission and is subject to penalty for perjury.
13 SIGNED this 9th day of May 2025, at Chesterfield, Missouri.
14 Signed:
15
16
17 34801779_v1
Declaration
York, Di 1
Micron Technology, Inc.

CERTIFICATE OF SERVICE
I hereby certify that on May 9, 2025, a true and correct copy of the within and foregoing
TESTIMONY IN SUPPORT OF SETTLEMENT STIPULATION OF JESSICA A. YORK ON
BEHALF OF MICRON TECHNOLOGY, INC. IN CASE NO. VEO-W-24-01 was served in the
manner shown to:
Electronic Mail
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.njuguna(kveolia.com
prestoncarterk ig venspursle,
morgangoodin(i i_ venspursley.com
memk ig venspursle,
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.burdinkpuc.idaho.gov Denver, CO 80202
secretary(apuc.idaho.gov darueschhoff(&�hollandhart.com
tnelson(&,hollandhart.com
awj ens en(chollandhart.com
karoachkhollandhart.com
aclee(d,hollandhart.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 shubble(a-,cityofboise.org
Boise, ID 83701-0500 rleebeusankcityofboise.org
mr rg ant(kcityofboise.org
boisecityattorney(&,cityofboi se.org
s/Adele Lee