20221005Staff 1-38 to Veolia.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 98IO
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
VEOLIA WATER IDAHO,INC. FOR A
GENERAL RATE CASE
CASE NO. VEO-W-22-02
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO VEOLIA WATER IDAHO,
INC.
The Staff of the ldaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attomey General, requests that Veolia Water ldaho, Inc. provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
ocToBER 26, 2022.
This Production Request is to be considered as continuing, and Veolia 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
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO
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1 OCTOBER 5,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide copies of the monthly trial balances from January 1,
2020, through the most current month available. Please supplement your response when
additional months become available throughout 2022.
REQUEST NO. 2: Please provide a copy of the Company's Chart of Accounts.
REQUEST NO.3: Please provide a list of all extemal attorneys who performed services
for the Company or who were paid by the Company for services during 2021 and2022 to date.
Please list the amounts paid, accounts charged, and date of payment. Please also provide a brief
summary of the services performed. If services were performed in support of a docketed
federal/state court or regulatory action, please identifu the case name, case number, and
jurisdiction.
REQUEST NO. 4: Please provide the total amount that the Company spent on the
following activities for 2021 and2022 to date, and show how the Company allocated the
amounts between its operating division and the rest of the Company and its subsidiaries:
a. The Company's annual report;
b. Rating agencies;
c. All software or information system-related issues;
d. Board of Directors compensation, travel expenses, and meeting expenses;
e. Travel and training for all shared executives of Veolia North America and affiliates;
f. Insurance coverage;
g. Overhead items including utilities, property taxes, security services, and other
corporate headquarter expenses; and
h. All other allocated or shared expenses.
REQUEST NO. 5: Please provide a matrix identifuing the major capital expenditure
approval levels that includes the dollar level of authorization by employee title, division, and
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 2 OCTOBER 5,2022
company. Please include within your response the dollar level at which the individual capital
expenditures require approval by the Board of Directors.
REQUEST NO. 6: Please provide a schedule of all additions and retirements to Plant-
in-Service since January 1,2020, including installation date, account, installed cost, and
estimated depreciable life.
REQUEST NO. 7: Please provide all joumal entries related to additions and retirements
to Plant-in-Service since January 1,2020.
REQUEST NO. 8: Please provide an analysis of any sales of land and/or plant for the
years2020 -2022 to date if any. Please show gains, losses, and supporting documentation
including accounting entries for removal of items from rate base.
REQUEST NO. 9: Please provide details of any planned sales of land and/or plant for
the remainder of 2022 and2023. Please include within your response the estimated date of these
sales and the planned accounting treatment.
REQUEST NO. 10: Please provide a list of "out-of-period adjustments" and
"extraordinary items" for the years2020 -2022 to date.
REQUEST NO. l1: Please provide a schedule showing injuries and damages claims for
the years 2021 and2022 to date. Please include within your response the description of each
item, the amount for each item, and the account charged.
REQUEST NO. 12: Please provide a listing of all organizations the Company
participates in and the costs of participating in those organizations (e.g. NAWC, IACI, R&I
Alliance, etc.). If the costs are allocated from a parent company, please illustrate how the
amounts were allocated to Veolia Water Idaho.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 3 OCTOBER 5,2022
REQUEST NO. 13: Please provide a list of all advertising expenses recorded above the
line, including account and subaccounts, where posted, dates posted, vendor names,
explanations, and amounts posted during 2021 and2022.
REQUEST NO. 14: Please provide copies of all advertisements used during 2021 and
2022 and correlate the advertisement with the specific detail provided in the Company's
response to Request No. 13.
REQUEST NO. 15: Please provide copies of all billing inserts for 2021 and2022 and
indicate the date they were sent. Please also provide a schedule showing the amount and account
numbers charged for all costs to produce, print, and distribute the inserts.
REQUEST NO. 16: Please provide copies of the monthly, quarterly, and annual
comparison of operating and capital budget to actual expenditures for 2019 -2022to date.
Please include within your response a narrative explanation for budget variations. This should
include, but not be limited to, written operating and capital budget variance reports and
explanations used by Company officers and managers to monitor and control budgets under their
responsibility. Please supplement your response as additional information becomes available
throughout 2022.
REQUEST NO. l7: Please provide a list of all leased items in 2021 and2022 to date
Please separate capital leases from operating leases and show the dates, terms, amounts, and
accounts used for each lease.
REQUEST NO. 18: Please provide a schedule of prepaid items for 2021 and2022to
date showing amounts posted, vendor niunes, explanations, and accounts to which these items
were booked. Please include within your response any significant changes to prepaid items
occurring or planned to occur in2022 and2023.
REQUEST NO. 19: Please provide the following direct labor related information as
recorded for the twelve months ended December 31,2020, December 31,2021, and the six
FIRST PRODUCTTON REQUEST
TO VEOLIA WATER IDAHO 4 OCTOBER 5,2022
months ended June 30, 2022. Information, where applicable, should be listed by O&M expense,
other expense, construction, and other account groups. The response should include wages and
salaries for each employee category (officer, exempt, non-exempt, and union), paid time-off,
overtime, bonuses, incentive pay, and overheads for pension, benefits, and payroll taxes. Please
also include average and year-end number of employees by employee category. Include part-
time and temporary employees as full-time equivalents.
REQUEST NO.20: Please provide the quantifiable savings from any cost/workforce
reduction programs during the past five years. Please provide any additional workforce
reduction programs planned for 2022 -2023.
REQUEST NO. 21: Please summarize all benefit and retirement plans provided to
Company employees of all classifications. Please also include any changes that have occurred to
the benefits/accruals during the past five years.
REQUEST NO. 22: Please provide copies of the Company's pension and actuarial
reports for the years2020 -2022. Also, please provide any actuarial calculations and
documentation that shows the development of FAS 87 expenses (ASC 715 Compensation -
Retirement Benefits as codified), Company contributions, balances, and assumptions.
REQUEST NO.23: Please provide access to copies of all studies used to determine
employee compensation, including executive compensation, and explanations of how the
Company applied them in the years 2020 - 2022 to date.
REQUEST NO.24: Please provide the yearly percentage pay rate increase by employee
and position since the last general rate case in2020. Please provide in an excel spreadsheet with
formulas intact.
REQUEST NO.25: Please provide a schedule showing the estimated external rate case
expenses the Company expects to incur for the preparation and processing of this case.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 5 OCTOBER 5,2022
REQUEST NO. 26: Please provide a copy of the Company's property tax bills for 2021
and2022.
REQUEST NO. 27: Please provide all Company bank statements for 2021 and2022.
REQUEST NO. 28: Please provide statements for any Company credit cards that
include spending during 2021 and2022to date.
REQUEST NO. 29: Please provide a list of all property that the Company leases to
others. Please include lease revenue and provide copies ofall lease contracts.
REQUEST NO. 30: Please list all the Company's long-term debt issuances. Please
include the following: dates of issuance and expiration, amounts, premiums or discounts, interest
rates, dates of pre-payment, and payment schedules for each issuance.
REQUEST NO.31: Please provide a list of all contractors used in 2020,2021 and2022
to date. Please include with this response the contract amount, project name, project location,
and completion date.
REQUEST NO.32: Please provide a current hydraulic model of the Company's water
system
REQUEST NO.33: Please provide the most recent version of the Company's Drinking
Water Facilities Capital Plan.
REQUEST NO.34: Please provide a copy of the Company's policy for water main
extensrons
REQUEST NO.35: For each of the Company's wells, please provide the quantity
(gallons) pumped for each month between January 2020 and2022 to date.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 6 OCTOBER 5,2022
REQUEST NO.36: Please provide the Idaho Department of Water Resources unique
identifier (e.g. Well TagtD-TagNumber) for each of the Company's wells.
REQUEST NO.37: Please provide the following for each meter size for each month
from January 2020 through2022 to date:
a. Number of Billed Customer Charges;
b. Gallons of water provided to customers at no charge as part of the Minimum
Charge; and
c. Gallons sold to customers in excess of the maximum gallons allowed in the
Minimum Charge.
REQUEST NO.38: Please describe the Company's methodology for developing,
managing, executing, and completing Capital Projects in a least cost manner. Please provide a
copy of all Company policies and procedures documenting the process.
DATED at Boise,Idaho, lrtis *l day of October2022.
Chris Burdin
Deputy Attorney General
i:umisc:prodreq/veow22.2cbjt prod req I
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 7 OCTOBER 5,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY oF oCToBER}O2z,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STArF TO VEOLIA WATER IDAHO, INC., IN CASE NO.
VEO.W-22-02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
PRESTON N CARTER
MORGAN GOODIN
GTVENS PURSLEY LLP
PO BOX2720
BOrSE tD 83701-2720
E-MAIL: [e-mail]
morganeoodin@ givenspursley.com
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SECRETAN.u/--
CERTIFICATE OF SERVICE