20221107Veolia to Staff 41.pdf

VEOLIA WATER IDAHO, INC.’S RESPONSES TO SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 1 OF 3
16453904_1.DOCX (30-235)
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Veolia Water Idaho, 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. VEO-W-22-02

VEOLIA WATER IDAHO, INC.’S
RESPONSES TO SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF
Veolia Water Idaho, Inc. (“Veolia” or “Company”), in response to the Second Production
Request of the Commission Staff to Veolia Water Idaho, Inc. dated October 19, 2022, submits
the information below. The requested documents will be provided under the terms of the
Protective Agreement.

RECEIVED
2022 November 7, PM 12:30
IDAHO PUBLIC
UTILITIES COMMISSION
VEOLIA WATER IDAHO, INC.’S RESPONSES TO SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 3
16453904_1.DOCX (30-235)
DATED: November 7, 2022.

By:_____________________________
Preston N. Carter
Givens Pursley LLP
Attorneys for Veolia Water Idaho, Inc.

VEOLIA WATER IDAHO, INC.’S RESPONSES TO SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 3 OF 3
16453904_1.DOCX (30-235)

CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT on November 7, 2022, I caused a true and correct copy of
the foregoing to be served upon the following parties as indicated below:

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
[e-mail]
[e-mail]

Email
U.S. Mail
Fax
Hand Delivery

Preston N. Carter

VEO-W-22-02
IPUC DR 41
Page 1 of 2
VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bui
REQUEST NO. 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.
RESPONSE NO. 41:
Three electronic files are provided that contain the main set of calculations for
estimating peak factors by customer class, and these are further described below. The source
data supporting this project was extensive: over half a billion raw AMI data records (individual
hourly meter readings) were stored on a Snowflake data cloud and accessed by Black & Veatch
analysts. Raw data was loaded, cleaned, and transformed in an SQL server and then exported to
other databases and business intelligence tools for analysis and data visualization and used in
the three files listed below.
Attachment 1: HourlyProductionSummary.xlsx. This file contains hourly production
volumes and reservoir storage volume changes for the VWID system and is used to
identify system max day and max hour timeframes.
Attachment 2: UsageSummaries v2.xlsm. This file uses a data query from the billing
database to establish typical average and seasonal usage values by customer class. The data
is then joined with available AMI meter information to identify which customers have AMI
meters and to compare usage metrics for customers on AMI accounts against usage metrics
for all customers by customer class.
VEO-W-22-02
IPUC DR 41
Page 2 of 2
Attachment 3: VWID Load Study Results.xlsx. This file uses the representative AMI
accounts identified in File 2 to construct hourly estimates of usage by each customer class
for the maximum day and hour periods identified for the study and determination of
coincident and non-coincident peaking factors.