20221019Staff 39-41 to Veolia.pdf

CHRIS BURDIN NED
DEPUTY ATTORNEY GENERAL PM 4:i 4IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )CASE NO.VEO-W-22-02
VEOLIA WATER IDAHO,INC.FOR A )GENERAL RATE CASE )
)SECOND PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO VEOLIA WATER IDAHO,
)INC.
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy Attorney General,requests that Veolia Water Idaho,Inc.provide the
following documents and information as soon as possible,but no later than WEDNESDAY,
NOVEMBER 9,2022.
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 identify the name,job title,location,and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 1 OCTOBER 19,2022
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.
REQUESTNO.39:Please provide a list of all capital investment projects that the
Company is requesting recovery of in this case.Within this list,please provide the following
information:
a.Project in-service date.
b.Work order or project number.
c.Project title.
d.Project description.
e.Project budgeted cost.
f.Project actual cost.
g.Total Company capital investment.
h.Was an analysis of need completed?
i.Was a Cost/Benefit analysis completed?
j.Was the project primarily completed using contractor(s)?Please explain.
k.If contractors were used,was a Request for Proposal issued for the project?
l.Were Company Resources used to primarily complete the project?Please explain.
REQUESTNO.40:Please provide the Company's "construction program"referenced in
Walker's Direct Testimony at 5.
REQUESTNO.41:In reference to the Black &Veatch's Customer Class Load Study
discussed in Bui's Direct Testimony at 7;please provide all workpapers in electronic format with
formulas enabled supporting the Load Study.
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 2 OCTOBER 19,2022
DATED at Boise,Idaho,this day of October 2022.
:Chris Burdin
Deputy AttorneyGeneral
i:umise:prodreq/veow22 2cbkis prod req 2
SECOND PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 3 OCTOBER 19,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF OCTOBER 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO VEOLIA WATER IDAHO,INC.,IN CASE NO.
VEO-W-22-02,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
PRESTON N CARTER DAVID NJUGUNA
MORGAN GOODIN MGR-REGULATORY BUSINESS
GIVENS PURSLEY LLP VEOLIA WATER M&S INC
PO BOX 2720 461 FROM ROAD STE 400
BOISE ID 83701-2720 PARAMUA NJ 07052
E-MAIL:[e-mail] E-MAIL:[e-mail]
morgangoodin givenspurslev.com
stephaniew eivensourslev.com
SECRETA
1
CERTIFICATE OF SERVICE