20260731Application.pdf

Preston N. Carter, ISB No. 8462
GIVENS PURSLEY LLP
601 West Bannock Street RECEIVED
P.O. Box 2720 JULY 31, 2026
Boise, Idaho 83701-2720 IDAHO PUBLIC
Office: [phone] UTILITIES COMMISSION
Fax: [phone]
[e-mail]
Attorneys for Veolia Water Idaho, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF VEOLIA WATER Case No. VEO-W-26-02
IDAHO, INC.'S APPLICATION FOR AN
ACCOUNTING ORDER FOR COSTS APPLICATION FOR ACCOUNTING ORDER
ASSOCIATED WITH LOAD STUDY
Veolia Water Idaho, Inc. ("Veolia" or "Company"), pursuant to Idaho Code sections 61-
502 and section 503, Idaho Code §§ 61-502 and 61-503, and the Idaho Public Utility Commission
("Commission")Rule of Procedure 52, IDAPA 31.01.01.052,respectfully submits this Application
for Accounting Order seeking deferred accounting treatment for the incremental costs associated
with a required load study.
Please address communications regarding this Application to:
Preston N. Carter Brandon J. Pierce
Givens Pursley LLP Senior Counsel
601 W. Bannock St. Regulated Water
Boise, Idaho 83702 Veolia North America
[e-mail] [e-mail]
[e-mail]
1. INTRODUCTION
I. As part of the Stipulation and Settlement of the most recent Application of Veolia
Water Idaho, Inc. for a General Rate Case, Case No. VEO-W-24-01 ("Settlement"), the parties to
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that Settlement ("Parties") agreed to hold, at least on a semi-annual basis, workshops to discuss
several issues, including a load study. The discussions were intended to set forth the framework for
a contemplated load study including: the study goal; definitions; appropriate criteria to use in a load
study; the availability and sufficiency of AMI data to support an accurate and reliable load study;
the possibility of using sampling techniques to support a load study; the potential classes to be
included in a load study; costs associated with gathering additional data and potential necessary
meter deployments; and other relevant topics.
2. The Parties intended to discuss in good faith with the goal of having an agreed-upon
framework for the load study within twelve months of the Commission's approval of the Settlement.
3. The Settlement commits the Company to conduct the load study in accordance with
the agreed-upon framework by June 2028. However, the Parties also recognized that this schedule
is dependent upon, and subject to, agreement upon an acceptable framework; the availability of
sufficient data; capital expenditures associated with additional data needs; and related items.
4. The Commission approved the Settlement by Final Order No. 36624, dated May 30,
2025.
5. As of the date of this Application filing, the Parties have held two semi-annual
workshops, in which the Parties discussed various load study items, as outlined above. The Parties
continue to collaborate on developing the load study framework consistent with the Settlement.
6. To fulfill this commitment, Veolia has expended significant internal time and
resources. Additionally, to ensure necessary resources, appropriate subject matter expertise, and
analytical rigor, the Company has retained an outside consultant to provide specialized guidance
and inform ongoing discussions regarding the framework and perform the load study in whatever
form is ultimately required. To date,the Company has incurred$22,355 in outside consulting costs
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to successfully meet the terms and spirit of the settlement. The Company anticipates additional
costs will be associated with subsequent workshops as the framework continues to be developed
through the collaborative process, as well as with the load study itself The ultimate scope and cost
of the load study will depend on the framework agreed upon by the Parties and any additional
analysis or data requirements identified through that process. None of these costs were included in
the revenue requirement established in the Company's most recent general rate case.
7. To ensure these costs are appropriately tracked and preserved for future ratemaking
consideration,Veolia respectfully requests an accounting order authorizing the Company to record
these specific load study costs in a deferred account, rather than expensing them as incurred.
II.REQUEST FOR ACCOUNTING ORDER
8. Veolia requests an accounting order authorizing the Company to establish a
regulatory asset (deferred account) to record the incremental costs associated with development of
the load study framework and completion of the comprehensive load study required under the
Commission-approved Settlement in Case No. VEO-W-24-01.
9. The Company intends to utilize this deferred account to capture all relevant costs
associated with the development and completion of the load study. Such costs are expected to
include, but are not limited to, consultant costs associated with participation in the semi-annual
workshops, development of the load study framework, performance of the load study, and other
related activities necessary to comply with the Settlement requirements.
10. The costs associated with the semi-annual workshops, load study framework
development, and load study itself were not known, and therefore,were not reflected in the revenue
requirement established in the Company's most recent general rate case. These costs arise directly
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from implementation of the Commission-approved Settlement and are being incurred subsequent
to the test year used to establish current rates.
11. The load study is expected to provide benefits extending beyond the period in which
the costs are incurred by supporting future cost-of-service analyses and rate development.
Accordingly, recording these costs as a regulatory asset more appropriately matches the costs with
the future periods in which the benefits of the study will be realized.
12. Veolia does not request a determination that the deferred costs are recoverable in
rates. Rather, the Company requests only authority to defer and separately track these costs. Any
future request for recovery, including the amount, prudence, and appropriate amortization, would
be subject to Commission review and approval in a future base rate case proceeding.
13. The requested accounting order will not affect current customer rates. Authorization
to defer these costs is solely an accounting mechanism to preserve the costs for potential future
consideration and will not result in recovery from customers absent a subsequent Commission
order.
14. The costs of the load study are extraordinary, non-recurring, and to some extent,
outside of Veolia's control because the load study framework is still being developed.
15. The costs associated with the framework and load study are mandated by the
Commission-approved Settlement.
16. Granting the requested accounting order serves the public interest by facilitating
completion of the comprehensive load study contemplated by the Settlement. The resulting study
will assist the Commission, Staff, and interested parties in evaluating future cost allocation and rate
design issues using improved data and analytical support, thereby promoting fair, transparent, and
cost-based rates.
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17. This accounting treatment will ensure that these non-recurring costs are
appropriately identified and tracked pending future ratemaking review,rather than being recognized
entirely in the period incurred despite providing benefits extending into future rate making
proceedings.
18. Upon authorization, Veolia will track these incremental costs separate from
operating expenses, maintaining detailed records to support any future request for recovery in a
subsequent general rate case.
19. The requested accounting treatment is consistent with sound regulatory accounting
principles because it preserves for future review the incremental costs incurred to satisfy obligations
established through the Commission-approved Settlement while maintaining the Commission's full
authority to determine the appropriate ratemaking treatment of those costs in a subsequent
proceeding.
III.MODIFIED PROCEDURE
20. Veolia believes that a hearing is not necessary to consider the issues presented herein
and respectfully requests that this Application be processed under Modified Procedure, i.e., by
written submissions rather than by hearing, pursuant to IDAPA 31.01.01.201 et seq. If, however,
the Commission determines that a technical hearing is required, the Company stands ready to
support the Application.
IV.CONCLUSION
21. For the reasons set forth above, Veolia Water Idaho, Inc. respectfully requests that
the Commission issue an order:
a. Scheduling this case to be processed by modified procedure;
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b. Authorizing the Company to establish a deferred account to track the incremental
costs associated with the required load study; and
C. Any other relief it deems appropriate or necessary.
Dated: July 31, 2026
GIVENS PURSLEY LLP
By Is/Preston N. Carter
Preston N. Carter
Givens Pursley LLP
Attorneys for Veolia Water Idaho, Inc.
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CERTIFICATE OF SERVICE
I hereby certify that on July 31, 2026, I caused to be served a true and correct copy of the
foregoing document to the person(s) listed below by the method indicated:
Commission Staff Via Electronic Mail
Monica Barrios-Sanchez, Commission Secretary [e-mail]
Idaho Public Utilities Commission [e-mail]
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Preston N. Carter
Preston N. Carter
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