HomeMy WebLinkAbout20221026Veolia to Staff 1-38.pdfPrestonN. Carter, ISB No. 8462
Morgan D. Goodig ISB No. 11184
Givens Pursley LLP
601 W. Bannock St.
Boise,ID 83702
Telephone: (208) 388-1200
Facsimile: (208) 388-1300
prestoncarter@ eivenspursley. com
morganeoodin@ eivenspursley. com
VsoLrA WerER IDAHo, INc.'s REspoNsEs ro FRsr PRoDUCTIoN
REeUEST oF THs CoMr\rrssroN Srerr
16433368_l.Docx (3G235)
i:TIi]EIVED
2f;?? OcT ?6 Pt{ 2: 18
, ,'\?i&:&Y'?&l8t,o*
Attomeys for Yeolia Water ldaho, Inc.
BEFORE THE IDAHO PT]BLIC UTILITIES COMI\flSSION
IN THE MATTER OF THE APPLICATION
OF VEOLIA WATER IDAHO, INC. FOR A
GENERAL RATE CASE
CaseNo. Vf;O-W-2z-02
Vnoua Wernn Ioenq INC.'s
Rsspousns ro FRsr PRoDUCTToN
REquesr or rrE CorrnatssroN $16p
Veolia Water Idaho, lnc. ("Veolia" or "Company''), in response to the First Production
Request of the Commission Staffto Veolia Water Idaho, Inc. dated October 5,2022, submits the
attached information. The requested documents will be provided under the temrs of the
Protective Agreernent.
Pecr I or3
DATED: October 26, 2022.
By:
VEoLTA WATER IDAHo, INC.'S RESPoNSES To FrRST PRoDUCTToN
REeUESToF rHs CouursstoN Stepr
16433368_l.mcx (30-235)
Preston N. Carter
Givens Pursley LLP
Attorneysfor Veolia Water ldaho, Inc.
PAGE 2 oF 3
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. I I184
Givens Pursley LLP
601 W. Bannock St.
Boise, D 83702
Telephone: (208) 388-1200
Facsimile: (208) 388-l 300
prestoncarter@ givenspursley. com
moreangoodin@ eivenspursley. com
Attorneys for Veolia Water ldaho, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF VEOLIA WATER IDAHO, INC. FOR A
GENERAL RATE CASE
Case No. YEO-W-22-02
Veoln Weren IolHo, INc.'s
RrspoNsBs ro FrRsr PRoDUCTToN
Rpeuesr oF THE ComarssroN $1ap
Veolia Water Idaho, Inc. ("Veolia" or "Company''), in response to the First Production
Request of the Commission Staff to Veolia Water Idaho, Inc. dated October 5,2022, submits the
attached information. The requested documents will be provided under the terms of the
Protective Agreement.
RFCEIVED
2022 jcr 26 Pt'A 2.18
IDAHO PUBLIC
UI II" IT IES COIMh/ISSION
Veoua W TER IDAHO, INC.,S RESPONSES TO FIRST PRODUCTIoN
Rrqursror tun Coutvttsstoti Srerr
16433368 l.Docx(30-235)
PAGE I oF 3
DATED: October 26, 2022.
By:
VEoLtA Wersn IDAHo, INC.'S RESroNSES To FIRSTPRoDUCTIoN
REeuESr oF rHs Courr,lssroN Srenr
16433368_l.mcx (30-235)
Preston N. Carter
Givens Pursley LLP
Attornqts for Veolia Water ldaho, Inc.
,,4-{ -
Pecs 2 on 3
CERTIHCATE OF SERVICE
I IIEREBY CERTIFY THAT on October 26,2022,I caused a tnre and correct copy of the
foregoing to be served upon the following parties as indicated below:
JanNoriyrki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 837 20-007 4
j an.noriyuki@.nuc. idaho. gov
secretarv@.puc. idaho. eov
xtr!tr
Email
U.S. Mail
Fax
Hand Delivery
,,A-->
PrestonN. Carter
Vpoln Wergn IDAHo, [Nc.'s RESPoNSES ro Fnsr PRopucnoN
REeuEsroF THe CoMMtssIoN Srerr
16433368_l.Docx (3G,235)
Pacr 3 or 3
YEOLTA WATER rDArrO, INC.
cAsE vEo-w-22-02
FIRST PRODUCTTON REQUEST OF TIrE COMMTSSTON STArr'
Preparer/Sponsoring Witness: Zerhouni
REOUEST 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.
RESPONSE NO. 1:
Please see the attachment for the monthly trial balances from January 2020 through
September 2022.
wo-w-22-02
IPUC DR I
Page I ofl
vEoLIA WAItsR rIrAHO, INC.
cAsE \IE(}.W-22-02
TIRSTT PROTIUCTTON nEQUEST OFTHE COMMISSION STATI'
PreearerlSponsoring Witness:
REOUEST NO.2r
Please provide a copy of the Company's Chart ofAccounts.
RESPIONSE NO.2:
Please soe tho attached file for a copy ofthe Company's Chart ofAooomts.
Zerhouni
vEo-w-22-02
IPUC DR2
Page l of I
VEOLIA WATER IDAHO INC.
CASE VEO-W-22-02
FIRST PRODUCTION REQUEST OF THE COMI\{ISSION STAFF
Preparer/Sponsoring Witness :Zerhouni
REOUEST NO.4:
Please provide the total amount that the Company spent on the following activities for
2021 and 2022 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.
RESPONSE NO.4:
Veolia Water M&S (Paramus) Inc. ("M&S") allocates shared expenses from
Corporate M&S and Regulated M&S to Veolia Water Idaho, Inc. ("VWID") and other
business units through the allocation of M&S fees based on the three - factor formula net of
capitalization as applicable to each department.
a. VWID's financial statements are not separately audited however, VWID financial
information is included in Veolia Utility Resources LLC ("VUR") annual audited
YEO-W-22-02
IPUC DR 4
Page I of4
financial statements. The total cost of VUR's audited consolidated financial
statements is allocated to VWID using the three-factor formula:
b. VWID is not separately rated. However, VUR is rated and such costs to ratings
agencies cost are allocated to VWID using the three-factor formula:
c. Software, information systems. and related costs incurred at M&S are allocated to
VWID using the three-factor formula for ratemaking purposes:
d. Board of Directors compensation, travel expenses and meeting expenses for the
Directors of VUR are paid by M&S and allocated to SWID using the three-factor
formula:
Jan-Dec 2021 Jan-Sept 2022
Activity Total YWID
Other
Business
Units Total VWID
Other
Business
Units
a.641,892 3s.790 606.102 508.374 29.965 478.409
Jan-Dec 2021 Jan-Seot 2022
Activitv Total VWID
Other
Business
Units Total VWID
Other
Business
Units
b.122.325 I 1,001 lll,324 99.325 9,449 89,876
Jan-Dec 2021 Jan-Sept 2022
Activitv Total YWID
0ther
Business
Units Total YWID
Other
Business
Units
c.29,268,065 1.514.175 26.7s3.890 21,128,372 l.103,304 20.025.069
Jan-Dec 2021 Jan-Sent 2022
Activitv Total VWID
Other
Business
Units Total VWID
Other
Business Units
d 35,000 1,952 33,048 35,000 2,064 32,936
vBo-w-22-02
IPUC DR4
Page 2 of 4
e. Travel and training for all shared executives is incurred at the M&S company and is
allocated to VWID using the three- factor formula:
f. Insurance costs for auto liability is based on the number of vehicles and worker's
compensation is based on payrollcosts of each business unit. In addition, general
liability and property insurance costs are allocated from M&S using the three-factor
formula.
I. Corporate M&S headquarters expenses including utilities, propefty taxes and security
services are allocated first among each M&S depaftment based on the headcount and
then to VWID and other business units r.rsing the three-factor forrnula:
Jan-Dec 2021 Jan-Sept 2022
Activitv Total VWID
Other
Business
Units Total VWID
Other
Business
Units
e.8,344 375 7,969 27,033 1,286 25,747
Jan-Dec 2021 Jan-Sept 2022
Activitv Total
Veolia
Water
Idaho. Inc.
Other
Business
Units Total
Veolia
Water
Idaho. Inc.
0ther
Business
Units
f. - Auto
Liability &
Workerrs
Compensation
f. - General
Liability &
Propertv
616,799
2.s73.924
69,276
143,515
547,503
2.430.409
568,845
2.s86,s9s
75,053
152,565
493,792
2,434,030
Jan-Dec 2021 Jan-Sept 2022
Activitv Total VWID
Other
Business
Units Total vwII)
Other
Business
Units
s.3,149.0s7 127,264 3,021,793 2.396.481 105,266 2,291.2t6
vBo-w-22-02
IPUC DR4
Page 3 of4
h. The remainder ofthe shared oosts are allocated to VWID and other business using the
three-factor formula:
48.155.395 2.t82.432 45.972.9U 33.140.970 t.698.t24 3t.44224sh.
VEG,W-22-02
IPUCDR4
Page 4 of4
vEoLIA WATER IDAHO, INC.
cAsE vBo-w-22-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
REOUEST NO.5:
Please provide a matrix identifing the major capital expenditure approval levels that
includes the dollar level of authorization by employee title, division, and company. Please
include within your response the dollar level at which the individual capital expenditures
require approval by the Board of Directors.
RESPONSE NO.5:
The following table shows the capital expenditure approval levels.
YEO-W-22-02
IPUC DR 5
Page I ofl
Al Projects up to
$100,000 VP/General lVhnager Veolia Water ldaho, lnc.Veolia Water ldaho, lnc.
$250,000 VF Capitallnvestments
Planning and Delivery LJtility DMsion Veolia Water ttI&S
(Paramus), lnc.
$500,000 tXility CFO utili$ Division Veolia Water ltI&S
(Paramus), lnc.
$1,250,000 tJtility Chief Operating Officer utility Division Veolia Water ltI&S
(Paramus),lnc.
$2,500,000 Corporate tvl&S CFO itunicipalWater Veolia Water ttl&S
(Paramus),lnc.
$5,000,000 IttunicipalWater CEO ItfunicipalWater Veolia l.lorth funerica, lnc
$10,000,000 Veolia l.lorth America CEO Veolia North Anerica Veolia Mrth America, lnc
Note: Board of Directors approves the overall capital plan for the upcominq vear
Approval Amount Approver Division Company
vEoLIA WATER TDAHO, rNC.
cAsE vEo-w-22-02
FrRST PRODUCTTON REQTIEST OF TIIE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
REOUEST 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,andestimated
depreciable life.
RESPONSE NO.6:
Please see the attached file with the information requested.
The depreciation schedule is provided on a separate tab in the attachment for each
depreciation group.
YEO-W-22-02
IPUC DR 6
Page I of1
vEoLrA WATER rDArrO, rNC.
cAsE vEo-w-22-02
FIRST PRODUCTION REQTIEST OF TIIE COMN{ISSION STAIT'
Preparer/Sponsoring Witness: Cooper
REOTIEST NO.7:
Please provide all joumal entries related to additions and retirements to Plant-in-Service
since January 1,2020.
RESPONSE NO.7:
Please see the attachment showing journal entries related to additions and retirements to
Plant-in-Service from January 1,2020 to September 30,2022.
vEo-w-22-02
IPUC DR 7
Page I ofl
YEOLIA WATER IDAHO, INC.
cAsE vEo-w-22-02
FrRST PRODUCTION REQUEST OF TrrE COMMTSSTON STAIT'
Preparer/Sponsoring Witness: Cooper
REOUEST NO.8:
Please provide an analysis ofany sales ofland and/orplant forthe years 2020 -2022to
date if any. Please show gains, losses, and supporting documentation including accounting
entries for removal of items from rate base.
RESPONSE NO.8:
There was one parcel of land sold during the time period. The Lancaster Tank land was
a small parcel, which was sold to a nearby homeowner. The land was sold for $2,000 and had a
book value of $7,602. The book loss on the sale of the land is not included for recovery.
Dr. Cash $2,000.
Cr. Land $7,602
Dr. Gain- Disposition of Property $5,602
Please see the attachment, which also includes salvage proceeds.
YEO-W-22-02
IPUC DR 8
Page I ofl
vEoLIA WATER IDAHO, INC.
cAsE vEo-w-22-02
FrRST PRODUCTTON REQTTEST OF TIrE COMMTSSTON STArr
Preparer/Sponsoring Witness: Cooper
REOUEST NO. 9:
Please provide details of any planned sales of land and/or plant forthe remainder
of 2022 and 2023. Please include within your response the estimated date of these sales
and the planned accounting treatment.
RESPONSE NO. 9:
No sale of land or plant is currently planned during the remainder of 2022 and2023.
vBo-w-22-02
IPUC DR 9
Page I ofl
yEoLIA WATER TDAHO, INC.
cAsE vEo-w-22-02
FIRST PRODUCTION REQUEST OF TIIE COMI\flSSION STATT'
Preparer/Sponsoring Witness: J. Cary
REOUEST NO. 10:
Please provide a list of "out-of-period adjustments" and "extraordinary items" for
the years 2020 - 2022to date.
RESPONSE NO. 10:
Veolia Water Idaho Inc.'s financial information is subject to the annual audit by
the independent auditors in connection with the annual audit of its parent Veolia Utility
Resources LLC. For the three years ended December 31,2019,2020 and202l, there were
no significant out of period adjustments or extraordinary items identified and recorded.
For the year ending December 31, 2022, the annual audit is in progress, and there were
no significant out of period adjustments or extraordinary items identified as of the date of
this response.
YEO-W-22-02
IPUC DR IO
Page I ofl
vEoLIA WATER TDAHO, rNC.
cAsE vEo-w-22-02
FIRST PRODUCTION T OF TITT' COMMISSION STATT'
Preparer/Sponsoring Witness: Cary
REOTIEST NO.lI:
Please provide a schedule showing injuries and damages claims for the years 2021 and
2022 to date. Please include within your response the description of each item, the amount for
each item, and the account charged.
RESPONSE NO. 11:
Please see the attached file, which details all injuries and damage claims and workers
compensation claims from202l to September 2022 from the Company's insurance providers.
Injury & Damage claims are recorded to the Insurance Reserve Liability Account 26200.
Automobile insurance costs are charged to Transportation expense account 50645, Injury &
Damage premiums are charged to Liability Insurance expense account 91400, while Worker
Compensation expenses are recorded in account 91460. Prior to 2020, General Liability claims
were recorded in M&S Fees Account 90850. The timing of claim payment expense will also
differ from the date of loss or incident.
YEO-W-22-02
IPUC DR I1
Attachment
Page I of1
vEoLIA WATER IDAHO, INC.
cAsE vrco-w-22-02
FIRST PRODUCTION T OF THE COMIVIISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST 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&l Alliance, etc.). If the costs are
allocated from a parent company, please illustrate how the amounts were allocated to Veolia
Water ldaho.
RESPONSE NO. 12:
The Company includes in its Operating Expenses AWWA American Water Works
Association fees (individual membership dues for participating employees), Idaho Ground Water
Appropriators, ISLE Inc. TAG Services, IWUA Idaho Water Users Association, and the non-
lobbying fee portion of NAWC National Association of Water Companies dues.
ParticipatingOrganization costs not requested for recovery in rates include Chamber dues,
Boise Valley Economic Partnership, IACI Idaho Association of Commerce and Industry and the
lobbying fee portion of NAWC National Association of Water Companies dues.
vBo-w-22-02
IPUC DR 12
Page I of2
Organization Operating
ExDense
Non-Recoverable
Expense
AWWA American Water Works Association $2.000
Boise Metro Chamber of Commerce $5,038
Boise Valley Economic Partnership $5,290
Eagle Chamber of Commerce s474
IACI Idaho Association of Commerce & Industry $r2.200
IGWA Idaho Ground Water Appropriators $5.000
ISLE Inc. TAG Services $15,000
IWUA Idaho Water Users Association $s00
NAWC National Association of Water Companies $37.1 l0 $s.s45
Veolia Water M&S @aramus), Ino. ('M&S') also allocates shared expenses from
Corporate M&S and Regulated M&S to Veolia Water Idaho, Inc. ('VWID') and other business
units through the allocation of M&S fees based on the three- factor Formula net of capitalization
as applicable to each deparfinent.
The Company's membership fee of The Water Research Foundation and Amerioan Water
Works Association is allocated to VWID using the thrpe-f,actor formula.
YEO-W-22-02
IPUC DR 12
Page2 of 2
$163,582
$45.890
$133,829
$0
$7,888
$0
$125,940
$o
Water Researoh
Foundation
American Water
Works
Association
$t7324r
$48"600 $2,710
$9,659
VEOLIA WATER IDAIIO, INC.
CASE YEO-W-22-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REOUEST NO. 13:
Please provide a list ofall advertising expenses recorded above the line, including
account and subaccounts, where posted, dates posted, vendor names, explanations, and
amounts posted during 2021 and2022.
RESPONSE NO. 13:
See the affachment for a list of all advertising expenses posted to account 50651660 -
Advertising Expense for the period requested. Expense lines that begin "EXACC" in the Joumal
ID column are purchase card expenses. The associated Supplier Name and description, listed in
column "Voucher Line Descr", are included for further detail.
The following expenses were excluded in the Test Year Advertising Expense filed in
Adjustment No. l8 and highlighted on the attachment.
$2000.00 - Red Sky Inc. Voucher ID 00127836 - Removed one month of Red Sky Inc.
service to reflect only l2 months in the Historic Test Year.
$8000.00 - Donahoe Pace Voucher ID 00122919 ($4000.00) and Voucher ID 0012330
($4000.00) - Removed 2021 customer education Conservation costs due to costs doubled up in
Historic Test Year due to timing of campaigns.
$2,686.88 - Hilton Garden Inn Journal ID EXACC49896 - Removed Eagle Water
Company customer town hall costs as they are non-recurring.
$6715.00 - Draper Associates Inc. Voucher ID 00125800 - Removed Rules &
Regulations insert from February 2022 as it was reprinted in June 2022 to reflect May 1,2022
rate change per SUZ-W-20-01 rate case.
YEO-W-22-02
IPUC DR 13
Page I of I
vEoLrA WATER IDAHO, rNC.
cAsE YEO-W-22-02
FrRST PRODUCTTON REQUEST OF TrrE COMI{TSSTON STATT',
Preparer/Sponsoring Witness: Wilson
REOUEST NO. 14:
Please provide copies of all advertisements used during 2021 and2022 and comelate
the advertisement with the specific detail provided in the Company's response to Request
No. 13.
RESPONSE NO. 14:
Please see attachments of all advertisements used during 2021 and2022. The files are
labeled'SUPPLIERNAME - VOUCHER ID - DESCRIPTION'. Please referto the attachment
provided in response to Request No. 13. Refer to Column AI for Voucher ID and column AP for
SupplierName to correlate the attachment with associated expense detail.
YEO-W-22-02
IPUC DR 14
Page I of 1
VEOLIA WATER IDAHO, INC.
cAsE YEO-WA2-02
rIRsT PRODUCTION REQUEST OF THE COMMSSION STAIT'
Preparer/Sponsoring Witness: Wilson
REOUEST NO. 15:
Please provide copies of all billing inserts for 2021 and 2022 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.
RESPONSE NO. 15:
Please see Attachment I schedules for details on billing inserts provided to customers
during the requested time period. Invoice 12437 dated ll28l22 is not included as it was removed
from the Test Year Advertising Expense because it was later reprinted in June 2022to reflect the
May I rate change per SUEZ-W-20-02 rate case. Attachment 2 includes the billing inserts
referenced in Attachment l.
vBo-w-22-02
IPUC DR I5
Page I ofl
vEoLIA WATER IDAHO, INC.
cAsE vEo-w-22-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAIT'
Preparer/Sponsoring Witness: Wilson
REOUEST NO. 16:
Please provide copies of the monthly, quarterly, and annualcomparison of operating and
capital budget to actual expenditures for 2019 - 2022 to 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.
RESPONSE NO. 16:
Please see attached files for Operating expense and Capital budget variances and
explanations. The following monthly variance files are not available and are supplemented with
financial Income Statements showing the variance to budget and Year to Date variance analysis
in subsequent months - Operating Variances: April20l9, and May 2019.
Request No l6 Attachment I -Capex Variances - containing capex budget variances from January
2019 through September 2022.
Request No l6 Attachment 2 - containing operating expense budget variances from
January 2019 through September 2022.
Request No l6 Attachment 3 - containing the income statement and variances from
budget for months: April 2019 and May 2019.
YEO-W-22-02
IPUC DR 16
Page I of I
vEoLrA WATER IDAIIO, INC.
cAsE vEo-w-22-02
FrRST PRODUCTION REQUEST OF TIIE COMMISSTON STAIT'
Preparer/Sponsoring Wifiess: Cary
REOUEST NO. 17:
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.
RESPONSE NO. 17:
The Company's leases for 2021 and2022 to date are reflected in the attachment to this
response. These operating leases include office equipment, building space, communication
tower leases, annual water right agreements, company vehicles and heavy equipment.
YE,O-W-22-02
IPUC DR 17
Page I of I
vEoLIA WATER IDAHO, INC.
cAsE vBo-w-22-02
FrRST PRODUCTION REQUEST OF THE COMI\{ISSION STAFF
Preparer/Sponsoring Witness: Wilson
REOUEST NO. 18:
Please provide a schedule of prepaid items for 2021 and 2022 to date showing amounts
posted, vendor names, 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 in 2022 and2023.
RESPONSE NO. 18:
Account 16599 reflects the prepaid balance of Azteca Systems LLC - Cityworks
subscription license costs that are invoiced and paid in September for the ensuing year.
Cityworks is the work order management program which allows the Company to schedule and
track employee work and activities performed in the freld. The number of authorized users
utilizing the software has changed over time as the program was deployed in various phases
which required additional Cityworks employee licenses. The monthly expense is recorded to
account 50650.
The 2020 Cityworks expense was $ 168,405 for 103 licenses and covers the period
October 15,2020 through October 14,2021. The 2021 invoice expense was $183,561 for 103
licenses and covers the period October 15,2021through October 14,2022. the increase coming
from a 9%o contractual obligation. The planned expense covering the period October 15,2022
through October 14,2023 is$222,562 for I l8 licenses.
vBo-w-22-02
IPUC DR 18
Page I of2
Additionally, in December 2021, the Company prepaid an invoice to the Bureau of
Reclamation for 1000 acre-feet of storage in Anderson Ranch Reservoir on the Boise River
System. The leased storage was for the2022 calendar year. This is an annual payment and is
typically made in the same calendar year as the leased water is made available. In order to align
the cost with the leased water usage, a monthly amortization of $2030.00 was setup to record the
expense in2022 to account 50605 (Purchased Water). We do not anticipate prepaying this
expense in the future.
YEO-W-22-02
IPUC DR I8
Page2 of 2
vEoLIA WATER IDAHO, rNC.
cAsE vEo-w-22-02
nRsT PRODUCTION REQTTEST OF TrrE COMMISSTON STAIT'
Preparer/Sponsoring Wifiress: Thompson
REOUEST 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
for2022 -2023.
RESPONSE NO.20:
The company has not initiated any workforce reduction plans in the past 5 years, and has
no plans to reduce its workforce in the time period from2022 -2023.
I/Eo-w-22-02
IPUC DR 20
Page I ofl
vEoLIA WATER IDAHO, INC.
cAsE \rEo-w-22-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST NO.2I:
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.
RESPONSE NO.21:
Please see below and attached summary benefit and retirement plan descriptions:
Request No 2l Attachment I Retirement Plan (Pension Plan)
Request No 2l Attachment 2 40lkPlan
Request No 2l Attachment 3 40lk Bargaining Plan
Request No 2l Attachment 4 Amendments to 40lk Plans
RequestNo 2l Attachment 5 Amendment to Retirement Plan
Request No 2l Attachment 6 Over 65 Retiree Plan
Request No 2l Attachment 7 Pre 65 Retiree Plan
The following changes to benefit plans have occurred in the past five years:
401(k) Plans
. Record keeper change from Vanguard to Fidelity November l, 2018
. Automatic enrollment feature added November l, 2018
. BiPartisan Budget Act effective lll/2020 - required plan amendment regarding
the
hardship withdrawals - withdrawal should not exceed the financial need including
any taxes or penalties. Hardships will be allowed if funds are not reasonably
available by any other withdrawal or distributions available under the plan or
other
YEO-W-22-02
IPUC DR 2I
Page I of3
plans maintained by the employer and the participant demonsffates that they have
insufficient funds to satisfu the need.
. CARES Act - effective April 2020 - plan will allow distributions up to $50,000
for
COVID-19 related expenses (participant has to self-certify). Plan will also allow
deferral of loan repayments for COVID-I9 related reasons (participant must self-
certify). Loan repayments will begin again l/112021.
. 2nd amendment - rollovers into the plan must be made within 60 days of the
distribution from a prior retirement plan
o 3rd amendment - Plan Sponsor name change to SUEZ Water Resources LLC,
clarification of earnings used in the Age Based calculator, and adoption of the
required minimum distribution age moving fro 70.5 to 72 (SECURE Act)
. 4th amendment - clarification of the Hoboken location / matching contributions
for Lynn, MA location
Retirement Pension Plans
. Definition of Disability Retirement - participant has to be on LTD and have at
least
l0 years of service to qualify for disability retirement
. Pension administration outsourced to Willis Towers Watson, September 6,2018
. 3rd amendment - Plan sponsor name change to SUEZ Water Resources LLC,
required minimum distribution age moving from 70.5 to 72 (SECURE Act),
o Lump sum window offered in Q4 2020 to vested terms in the SWR Retirement
Plan.
. Hoboken amendment
There were no changes to the plan designs for either the pre-65 or post 65 retiree medical
plans. Only changes are the premium rates (pre-65) and the Health Reimbursement Account rate
(post-65).
YEO-W-22-02
IPUC DR 2I
Page 2 of3
Please see the following files for plan amendments:
Request No 21 401(k) Plan Auachment 8 - 2nd Amendment (rollover)
Request No 21 401(k) Plan Attachment 9 - 3rd Amendment (Name)
Request No 21 401(k) Plan Attachment l0 - 4th Amendment (Hoboken)
RequestNo 2l Barg 401(k) Plan Attachment I I - 2nd Amendment (rollover)
Request No 21 Barg 401(k) Plan Attachment 12- 3rd Amendments (Name)
RequestNo 21 Retirement Plan Attachment 13 - Amendment (Hoboken)
RequestNo 2l Retirement Plan Attachment 14- Amendment (Lump Sum Window)
RequestNo 2l Retirement Plan Attachment 15- 3rd Amendment (Name)
YEO-W-22-02
IPUC DR 2I
Page 3 of3
VEOLIA WATER IDAHO, INC.
cAsE vEo-w-22-02
FrRST PRODUCTTON REQUEST OF THE COMMSSTON STAFF
Preparer/Sponsoring Witress: Cary
REOUEST NO.22:
Please provide copies of the Company's pension and actuarial reports for the years
2020 - 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.
RESPONSE NO.22:
Attachment I 2020 Pension Actuarial Report
Attachment 2 2021 Pension Actuarial Report
T\e 2022 Pension Actuarial Report is not available at this time. It should be available in
the first quarter of 2023.
vEo-w-22-02
IPUC DR 22
Page I ofl
vEoLIA WATER IDArrO, INC.
cAsE vEo-w-22-02
FrRST PRODUCTTON REQUEST OF TrrE COMMISSION STAIT'
Preparer/Sponsoring Witness: Njuguna
REOUEST NO.25:
Please provide a schedule showing the estimated extemal rate case expenses the
Company expects to incur for the preparation and processing of this case.
RESPONSE NO.25:
Please see Exhibit No. 10, Schedule I (Adjusfrnent No.23) which outlines the estimated
external rate case expenses.
YEO-W-22-02
IPUC DR 25
Page I ofl
vEoLIA WATER IDAHO, INC.
cAsE YEO-WA2-02
FIRST PRODUCTTON REQUEST OF TrrE COMIflSSTON STAIT'
Preparer/Sponsoring Witness: Cary
REOUEST NO.26:
Please provide a copy of the Company's property tax bills for 2021 and2022.
RESPONSE NO.26:
The Company expects to receive the2022 Property Tax bills in November for
Ada County, Boise Kuna lrrigation District, Nampa Meridian lrrigation District, and New
York lrrigation District.
The Company's Irrigation District property tax invoice payments are administered
directly by the Altus Group.
Please see attached files:
Attachment 1-Ada County Property Tax Bill 2020 a portion was paid in202l.
Attachment 2-Ada County Property Tax Bill 2021.
Attachment 3-Boise Kuna Nampa Meridian Irrigation Property Tax Bill 2021.
Attachment 4-New York lrrigation Properly Tax Bill 2021.
YEO-W-22-02
IPUC DR 26
Attachment 4
Page I ofl
YEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST NO.31:
Please provide a list of all contractors used in 2020,2021 and 2022 to date. Please
include with this response the contract amount, project name, project location, and completion
date.
RESPONSE NO.31:
The attached file includes information for field contractors used in2020 through September
2022 on capital expenditure and tank painting projects. The project locations are generally
described in the project and work order definitions if there was a specific site for the work. Work
on projects such as "Replacement Customer Meters" happened in various locations around the
Veolia Water Idaho service area.
We have not included items on the list such as testing at Analytical Laboratories, our third
party safety inspector groups, professional services such as engineering consultants and attorney
services, or vendors that we purchase only supplies from.
Please note that there are no "in-serviceo' dates for Preliminary ("M") projects, when the
preliminary work is complete, those dollars are moved to "execute" projects. Blanket projects
(such as meters, service lines, etc.) are put in-service on a monthly basis.
vBo-w-22-02
IPUC DR 3I
Page I of I
YEOLTA WATER rDArIO, INC.
cAsE vEo-w-22-02
FIRST PRODUCTTON REQUEST OF THE COMnIISSTON STArr'
Preparer/Sponsoring Witness: Cooper
REOUEST NO.34:
Please provide a copy of the Company's policy for water main exensions.
RESPONSE NO.34:
The Company's policy for water main extensions can be found in the approved Suez
Water Idaho Inc. Tariffs (the name on the tariff has not yet been changed to Veolia Water
Idaho) approved by the Idaho Public Utilities Commission. The section entitled "Rules and
Regulations Governing Water Main Extensions" begins on Sheet 37 of the approved tariff
document, and ends on Sheet 41.
Please see the attachment showing the section from the Company's approved tariff
indicating the "Rules and Regulations Governing Water Main Extensions".
VEOLIA WATER IDAHO, INC.
cAsE vEo-w-22-02
nRsT PRODUCTION REQUEST OF TrrE COMMTSSTON STAFF
Preparer/Sponsoring Witness: Cooper
REOUEST NO.35:
For each of the Company's wells, please provide the quantity (gallons) pumped for each
month between January 2020 and2022to date.
RESPONSE NO.35:
The attachment shows the quantity pumped from the Company's wells by month.
YEO-W-22-02
IPUC DR 35
Page I ofl
vEoLIA WATER IDAHO, rNC.
cAsE vEo-w-22-02
FIRST PRODUCTION REQUEST OF THE COMIVISSION STATT'
Preparer/Sponsoring Witness: Cooper
REOUEST NO.36:
Please provide the Idaho Department of Water Resources unique identifier (e.g. Well
Tag/D-TagNumber) for each of the Company's wells.
RESPONSE NO.36:
The Company's wells have identifiers assigned by Idaho Department of Water
Resources (IDWR) and/or Idaho Department of Environmental Quality (IDEQ). IDWR
assigns several different identifiers, somewhat dependent on when the well was drilled.
These include:
IDWR Well ID No: Number assigned to wells on file by IDWR.
IDWR Permit ID No: IDWR drilling permit number.
IDWR Well Tag No: Number on the metal tag required by IDWR starting in the mid
to late 1990's.
ldentifiers assigned to Veolia wells are provided in the attached file.
YEO-W-22-02
IPUC DR 36
Attachment
Page I of I
YEOLIA WATER TDAHO, INC.
cAsE vEo-w-22-02
FIRST PRODUCTTON REQUEST OF THE COMl\drSSrON STAIT'
Preparer/Sponsoring Witness: Cary
REOI]EST NO.37:
Please provide the following foreach meter size for each month from January
2020 through2022 to date:
a. Number ofBilled Customer Charges;
b. Gallons ofwater provided to customers at no charge as part ofthe
Minimum Charge; and
c. Gallons sold to customers in excess of the maximum gallons allowed
inthe Minimum Charge.
RESPONSE NO.37:
a. Please refer to Request No. 37 Attachment.
b. There is no water provided to customers as part of a minimum charge.
c. There is no water provided to customers as part of a minimum charge.
vEo-w-22-02
IPUC DR 37
Page I ofl