20221202Staff 42-147 to Veolia.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 98IO
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Street Address for Express Mail:
1I33I 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
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO VEOLIA WATER IDAHO,
INC.
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Chris Burdin, Deputy Attorney General, requests that Veolia Water Idaho, Inc. ("Veolia") provide
the following documents and information as soon as possible, but no later than FRIDAY,
DECEMBER 23, 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 identifi, the ntune, job title, location, and
telephone number of the record holder.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO
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CASE NO. VEO-W-22-02
I DECEMBERZ,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. 42: Please provide supporting workpaper(s), in Excel format with
formulae intact, for Management & Service ("M&S") Fee Adjustment No. 19. Please update
workpaper(s) with actual amounts as data become available.
REQUEST NO. 43: Please provide a copy of the Cost Allocation Manual ("CAM") in
Word and PDF format.
RXQUEST NO. 44: Please provide the following for each employee(s) that allocated
time to Veolia Water Idaho, Inc. that is included in M&S fees:
a. Offer letters
b. Number of hours spent on Veolia Water Idaho, Inc. directly
c. Percentage pay increase received per year since hired.
REQUEST NO. 45: Please provide detailed descriptions and the cost-benefit analysis
for each M&S Shared Services department.
REQUEST NO. 46: Please provide a description of the work that M&S Shared
Services, Legal, directly performed for Veolia Water Idaho, Inc.
REQUEST NO. 47: Please provide the Company's operating plans and capital budgets
for each year from 2022 tlrrough 2026. Please provide a breakdown for each year by category
(mains, services, hydrants, meters, etc.) and by specific project. Please indicate which projects the
Company would include within the first year in the Distribution System lmprovement Charge
("DSIC"), if it is approved.
REQUEST NO.48: Please describe the material, number of miles, size, and age for each
type of transmission and distribution pipe in the Company's system that will require replacement
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 2 DECEMBER2,2022
and/or rehabilitation within the next five years. Include why it needs replacing, when it needs to
be replaced, and the expected cost.
REQUEST NO. 49: Regarding Company witness Cagle's Direct Testimony at 3, please
explain the difference between replacement and rehabilitation.
REQUEST NO. 50: Please describe any other infrastructure in the system that currently
requires, or will require, replacement and/or rehabilitation within the next five years. Include why
it needs replacing, when it needs to be replaced, and the expected cost.
REQUEST NO. 5l: Please describe any investments the Company has made over the
last five years to reduce and minimize replacement and/or rehabilitation costs.
REQUEST NO. 52: Please demonstrate how Operation and Maintenance ("O&M")
costs will change if the DSIC is approved.
REQUEST NO. 53: Please provide an update through November 2022 to the
SUZ-W-19-01 Semi-Annual Deferred Convenience Fee Report filed in November 2021
REQUEST NO. 54: Please provide the following information related to the Agreement
for Replacement and Operation of Fire Hydrants with the City of Boise identified in Case No.
UWI-W-15-02:
a. A drawing detailing a typical new fire hydrant installation along with quantities
listing individual components necessary for the hydrant replacement installation.
b. Component specifications used for the installation.
c. A map reflecting the location of each fire hydrant replaced by the Company since
approval in Commission Order No. 33390. This map should identifu individual
hydrants at each location. Please provide this map in "pdf format" with adequate
resolution to easily identifr each hydrant location and its corresponding tag
number.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO J DECEMBER2,2022
d. A table listing each hydrant replaced since the agreement. Please provide this table
in Excel format. Within the table include the following information related to each
fire hydrant:
i. Tag number
ii. Location
iii. Basis of need for replacement (i.e., age, inoperability, reliability, leaking,
other)
iv. Date of replacement
v. Estimated cost
vi. Basis considered in determining least cost replacement
vii. Indication whether the work was completed by the Company or a
contractor. Also, provide the name of the contractor as applicable.
viii. Listing of replaced items for the hydrant replacement installation
ix. Itemized costs for the replacement installation
x. Items salvaged
xi. Items delivered to the City of Boise per the agreement.
REQUEST NO. 55: Please describe the Company's process for contracting services used
for the installation of the water transmission piping system, distribution piping system, and the
system fire hydrants.
REQUEST NO. 56: Please explain how the Company assures the cost of installation for
transmission plant, distribution plant, and fire hydrants is at least cost to the Company's ratepayers.
REQUEST NO. 57: Please identifu any procurement starting January 1,2021, through
September 30,2022, where the procurement was not compliant with the SUEZ North American
Inc. Procurement Policy (Revised JuJy 2020). In each case, please explain why it was not
compliant and provide all Company documentation used to justifr moving forward with the
procurement even though it was not compliant.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 4 DECEMBERZ,2022
REQUEST NO. 58: Please provide the Company's completed Procurement Review Form
("PRp") for all procurements up to $300,000 made between January 1,2021, and the current date.
REQUEST NO. 59: Please provide the following documentation for each capital project
with a budget amount of $300,000 or more that was initiated or completed between January l,
2021, and September 30, 2022. For the requested information not provided, please explain why it
was not provided, and how the Company assured that the construction of the project was completed
at least cost to ratepayers.
a. A full description of the work completed for each project
b. Analysis of Need - a justification of need for each project along with a cost/benefit
analysis comparison of the alternatives
c. Project Plan including:
i. Initial project scope
ii. Proposed budget
iii. Proposed schedule
d. Documentation supporting competitive bidding practices including:
i. Company's completed PRF
ii. Requests for proposals ("RFP") including:
l. Project requirements
2. Specifications
iii. Short list bidder scorecard
iv. RFP from winning bid
e. Project construction documentation including:
i. Construction contract
ii. Organizational chart
iii. Scope document
iv. Work breakdown structure
v. Baseline Schedule
vi. Monthly project status report(s)
vii. Project action items list(s)
viii. Contractors change order request(s)
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 5 DECEMBER2,2022
f. Company project completion analysis including:
i. Lessons learned
ii. Budget-to-actual comparisons for the overall project, by work breakdown
structure, and by year
iii. Baseline schedule-to-actual schedule comparison
iv. For any actual costs differing from the budget amount by plus or minus 5
percent during a particular year, please list and explain the reason(s) for the
budget amount difference.
REQUEST NO. 60: Please provide a yearly listing of all Company sourced water used to
meet customer demand during the past l0 years. Please include the source name, source type,
peak available capacity, annual available capacity, and any contractual limitations for utilizing the
water resource. Please state the year that the water resource was procured and its total initial andlor
annual costs. Please also state the average cost per delivered gallon for the resource.
REQUEST NO. 61: Please provide the following monthly information in Microsoft Excel
electronic format for each well pump and/or booster pump within the system over the past 5-years:
a. Electric energy consumed (kVfh)
b. Differential pressure between the pump suction and discharge (psi) Electric energy
consumed (kwh)
c. Amount of water pumped (gal).
REQUEST NO. 62: Please provide the following monthly information in Microsoft Excel
electronic format for each location where chemical treatment is introduced into the system over the
past S-years:
a. Location
b. Chemical treatment type and concentration
c. Amount of chemical treatment introduced into the system
d. Amount of water treated.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 6 DECEMBER2,2022
REQUEST NO.63: With reference to Company witness Cary's Direct Testimony, please
provide the following workpapers and source documents (invoices, emails, reports, etc.) for the
following adjustments, in native format with formulas intact:
Adjustment No. I - Payroll
Adjustment No. 2 - Workers Compensation
Adjustment No. 3 - Pension Cash Contributions
Adjustment No. 4 - Post-retirement Benefits Other than Pension (PBOP)
Adjustment No. 5 - Employee Healthcare
Adjustment No. 8 - Payroll Overheads (Fringe Benefits Allocation)
Adjustment No. l0 - Energy - Purchased Power and Other Utilities
Adjustment No. I I - Chemicals
Adjustment No. 12 - Subcontractors
Adjustment No. l3 - Customer Billing Expenses
Adjustment No. l7 - Offrce Expenses
Adjustment No. 20 - General Insurance
Adjustment No. 22 - Safety
Adjustment No. 29 - Adjustment to Variable Expenses Due to Volume Normalization.
REQUEST NO. 64: With reference to the Number of Positions on page 6 of Company
witness Cary's Direct Testimony, please provide job descriptions and pay scales for all current
positions.
REQUEST NO. 65: With reference to the increase in staffing from the Company's Test
Year levels described on page 6 of Company witness Cary's Direct Testimony, please provide the
job description for each position listed, as well as the proposed pay rates. For each new position
listed, please indicate whether the position has been filled, or the anticipated date that the position
will be filled. Please also include a description of why these positions are needed by the Company
and how they benefit the Idaho customers of Veolia.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 7 DECEMBER2,2022
REQUEST NO. 66: With reference to the Wage Adjustments on page 6 of Company
witness Cary's Direct Testimony, please provide a copy of the union contract showing the
contractually obligated pay increase for Bargaining Unit employees.
REQUEST NO. 67: With reference to the Wage Adjustments on pages 6 and 7 of
Company witness Cary's Direct Testimony, please provide the basis for the 4o/o pay change over
2022. Please include any and all studies used to justify the 4o/o wage adjustment.
REQUEST NO. 68: With reference to the Wage Adjustments on page 7 of Company
witness Cary's Direct Testimony, please provide supporting documentation for the test year ratio
of 66.17% of the opex payroll to gross payroll.
REQUEST NO. 69: With reference to Stand-by Pay, Shift Pay, and Overtime Pay on
pageT of Company witness Cary's Direct Testimony, please provide the policies goveming when
these pay rates are used. Please provide the supporting documentation and workpapers for
calculating the three-year average for overtime.
REQUEST NO. 70: With reference to the Incentive Programs on page 7 of Company
witness Cary's Direct Testimony, please provide a description of the Company's Short-Term
Incentive Plan, including the goal targets and criteria requirements. Please provide descriptions
and amounts of the target awards based upon the job/salary grade, including the personal goals
and Company goals.
REQUEST NO. 71: With reference to the Incentive Programs on page 7 of Company
witness Cary's Direct Testimony, please provide a description of the Non-Exempt Incentive
Program, including the basis for the incentive payments and the amount or percentage of the
incentive payment.
REQUEST NO. 72: With reference to Adjustment No. 2 - Workers Compensation on
page 8 of Company witness Cary's Direct Testimony, please provide the supporting
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 8 DECEMBER2,2022
documentation and workpapers for the adjustment, including the inputs for the three-year average
of workers compensation.
REQUEST NO. 73: With reference to Adjustment No. 3 - Pension Cash Contributions
on page 8 of Company witness Cary's Direct Testimony, please provide the Actuarial Reports for
years 2017 through 2022. Additionally, please include all correspondence, letters, and emails
between the Company and its actuaries for years 2017 through2022.
REQUEST NO. 74: With reference to Adjustment No. 4 - Post-retirement Benefits Other
than pension ("PBOP") on page 9 of Company witness Cary's Direct Testimony, please provide
the supporting documentation and workpapers contained in the Towers Watson actuarial valuation
for2022 with a service cost of $163,925 and interest component of ($687,681). In addition, please
provide the Towers Watson actuarial valuations anticipated in October 2022 once they are
available.
REQUEST NO. 75: With reference to Adjustment No. 5 - Employee Healthcare on page
9 of Company witness Cary's Direct Testimony, please provide documentation and workpapers
supporting the calculation of the adjustment. Please provide the updated 2023 benefit costs
anticipated in October 2022 once they are available.
REQUEST NO. 76: With reference to Adjustment No. 8 - Payroll Overheads on page 10
of Company witness Cary's Direct Testimony, please provide an overview of the fringe benefit
allocation method. Please provide the calculation for this adjustment, including the inputs used
and the source documents for the inputs.
REQUEST NO. 77: With reference to Adjustment No. 10 - Energy - Purchased Power
and Other Utilities on page 10 of Company witness Cary's Direct Testimony, please provide the
source documents for the items included in Test Year Other Power totaling $ 157,953, as shown in
Exhibit No. 10, Schedule l, Adjustment No. 10.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 9 DECEMBER2,2022
REQUEST NO. 78: With reference to Adjustment No. I I - Chemicals on page 12 of
Company witness Cary's Direct Testimony, please provide the transaction detail reports for
Chemicals, Account 50635, for the historical test year that ended June 30, 2022,in Excel format
with formulas intact.
REQUEST NO. 79: With reference to Adjustment No. 1l - Chemicals on page 12 of
Company witness Cary's Direct Testimony, please provide the source documents supporting the
pro forma prices.
REQUEST NO. 80: With reference to Adjustment No. 1l - Chemicals on page 12 of
Company witness Cary's Direct Testimony, please provide the source documents forthe additional
chemicals for the former Eagle Water service area.
REQUEST NO. 81: With reference to Adjustment No. 12 - Subcontractors on page 12
of Company witness Cary's Direct Testimony, please provide the transaction detail reports for
Subcontractors, Account 50400, for the historical test year ended June 30, 2022, in Excel format
with formulas intact.
REQUEST NO. 82: With reference to Adjustment No. l2 - Subcontractors on page 12
of Company witness Cary's Direct Testimony, please provide the source documents and invoices
supporting the new costs related to Itron Temetra's meter reading software, and supporting the
increase in fees from GeoSCADA, and the costs for the well cleaning and tank inspections not
reflected in the historic test year.
REQUEST NO.83: With reference to AdjustmentNo. 13 - Customer Billing Expenses
on page 13 of Company witness Cary's Direct Testimony, please provide source documents and
other supporting documentation for the bill generation vendor increase of $8,144. Please provide
the source documents and other supporting documentation for the anticipated lYo customer
growth adjustment, and the calculation supporting the postage increase.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO l0 DECEMBER2,2022
REQUEST NO. 84: With reference to Adjustment No. 17 - Office Expenses, on page 13
of Company witness Cary's Direct Testimony, please provide additional details ofthe "Cityworks"
license mentioned. In the response, please include:
a. an itemization of the annual costs required for the "Cityworks" licensing costs.
b. the number of current licenses and new licenses that will be obtained.
c. an explanation why additional licenses are required for new employees and an
identification of which new employees will require licenses.
d. a copy of the contract reflecting the increase in licensing cost with "Cityworks."
REQUEST NO. 85: With reference to Adjustment No. 17 - Office Expenses, on page 14
of Company witness Cary's Direct Testimony, please provide additional details of the $821
increase in the first-class postage cost of 3.45%. Please include the calculation and supporting
documentation for this adjustment, including a description of the types and number of mail pieces.
REQUEST NO. 86: With reference to Adjustment No. 17 - Office Expenses, on page 14
of Company witness Cary's Direct Testimony, please provide a description of the Right Systems
maintenance support fee for the Company's UPS backup system cost. Please provide a copy of
the invoice and supporting documentation for the increase.
REQUEST NO. 87: With reference to Adjustment No. 22 - Safety, please explain the
increase in the Safety Expense account for the test year expense. Please provide the source
documentation supporting the budgeted amounts or prior costs. Please include any invoices and
calculations that support the increase in costs. Additionally, please provide the actual expenses,
by item and category, for the years 2019 through202l.
REQUEST NO. 88: With reference to Adjustment 9 - Purchased Water, on page 5 of
Company witness Wilson's Direct Testimony, please provide the source documentation such as
contracts and invoices for the following items:
a. Shares Leased in Canals
b. Contract Storage
c. State Water Bank (Natural Flow)
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 1l DECEMBER2,2022
d. Basin 63 Rental Pool
e. Additional Rental Pool
f. Garden City Water Purchase
g. New York Inigation Canal.
REQUEST NO. 89: With reference to Adjustment 9 - Purchased Water, on page 5 of
Company witness Wilson's Direct Testimony, please provide the transaction detail report for
the purchased water, Account 50605, for the historical test year that ended June 30. 2022, in
Excel format with formulas intact.
REQUEST NO. 90: With reference to Adjustment 14 - Bad Debt on pages 5 and 6 of
Company witness Wilson's Direct Testimony, please provide the transaction detail reports for
Bad Debt Reserve, Account 90405 and Bad Debt, Account 90400 from March2020 through
the historical test year that ended June 30, 2022, in Excel format with formulas intact.
REQUEST NO. 91: With reference to Adjustment 15 - Materials on page 6 of Company
witness Wilson's Direct Testimony, please provide the transaction detail report for Materials,
Account 50300 for the historical test year that ended June 30. 2022, in Excel format with
formulas intact.
REQUEST NO. 92: With reference to Exhibit No 10, Schedule 1, Adjustment 16 -
Vehicle Allocation, please provide supporting documentation for the following transportation
expenses as shown in Company witness Wilson's Direct Testimony beginning on page 6. In the
response, please identifu any additional costs necessary for future employees that have been
included as a pro forma adjustment to the Company's revenue requirement. Also, please verify
that the mechanic payroll has not been already included in the Payroll Adjustment.
a. Mechanic payroll and benefits
b. Lease Cost & GPS fees
c. Fuel
d. Material,Maintenance
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO t2 DECEMBER2,2022
e. Insurance
f. Other Costs
g. Depreciation
h. Tax
i. VA Allowance.
REQUEST NO. 93: Please provide a schedule showing the year, make, and model of the
Company's current fleet of vehicles. For each vehicle, please state whether it is leased or owned
by the Company, along with the purchase price and net book value.
REQUEST NO.94: Please provide a copy of the Company's vehicle replacement policy
and any studies the Company has performed in the last five years relating to vehicle replacement.
REQUEST NO. 95: Please provide the source documents and calculations related to the
projected fuel prices reflected in the Test Year at $4.68 per gallon for gasoline and $5.19 per gallon
for diesel. In addition, please provide the calculations supporting the fuel consumption.
REQUEST NO. 96: Please provide the source documents and calculations that support
the increase in costs of $70,176 for the insurance and vehicle maintenance costs mentioned on
page 8 of Company witness Wilson's Direct Testimony. Please include the invoices, insurance
policies, and other source documents to support this increase.
REQUEST NO. 97: Please state whether the Company has performed a cost-benefit
analysis to show that leasing the vehicles is the least-cost alternative to owning its own fleet.
Please provide a copy of any cost-benefit analysis and explain how leasing the vehicles benefits
customers.
REQUEST NO. 98: Please state the last time the Company had a competitive request for
proposal for the vehicle fleet. Please provide the source documents related to the most recent
competitive bidding process for its fleet management.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 13 DECEMBER2,2022
REQUEST NO. 99: With reference to Adjustment l8 - Advertising, on page 8 of
Company witness Wilson's Direct Testimony, please provide the transaction detail report for
the Advertising, Account 50651, for the historical test year that ended June 30, 2022, in Excel
format with formulas intact.
REQUEST NO. 100: With reference to Adjustment 18 - Advertising, on page 8 of
Company witness Wilson's Direct Testimony, please provide:
a. the analysis that determined that the Consumer Confidence Report ("CCR") needs
to be mailed to each customer.
b. the analysis that shows that customers have read and will continue to read the
paper copy. Please include in your response the number of telephone or email
contacts the Company received pertaining to the CCR, for the last 3 years that the
CCR was mailed to customers.
c. the statutory and regulatory requirement that the CCR be mailed to customers.
d. the feedback received from customers when the CCR was mailed.
REQUEST NO. 101: With reference to Adjustment 18 - Advertising, on page 8 of
Company witness Wilson's Direct Testimony, please state whether customers receive a message
on their digital bill prompting them to read the CCR.
REQUEST NO. 102: With reference to Adjustment 23 - Amortization Expenses -
Deferred Rate Case on page 4 of Staff witness Zerhouni's Direct Testimony, please provide a
schedule showing actual rate case costs incurred to date, including the entity paid and the service
that entity provided. Please supplement this response each month as additional costs are incurred.
REQUEST NO. 103: With reference Adjustment No. 25 - Amortization Expense -
Deferred Tank Painting, as shown on page 5 of Company witness Zerhouni's Direct Testimony,
please provide additional details for the Tank Painting mentioned. In the response, please include:
a. the size and type of tank for the Broken Hom, Columbia, and Hidden Hollow tanks.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO t4 DECEMBER2,2022
b. an explanation why painting of the Broken Horn tank, Columbia tank, and Hidden
Hollow interior painting projects were required.
c. anitemization of the costs for painting the Broken Horn tank, Columbia tank, and
Hidden Hollow interior painting projects.
d. the budgeted and actual expense for the Broken Horn tank, Columbia tank, and
Hidden Hollow interior painting projects.
e. all quotes received for the Broken Horn tank, Columbia tank, and Hidden Hollow
interior painting proj ects.
f. the expected number of years before the Broken Horn tank, Columbia tank, and
Hidden Hollow interior painting projects will need to be painted again.
REQUEST NO. 104: Please provide a copy of the Company credit card and
purchase card policy.
REQUEST NO. 105: Please provide the transaction detail reports for the following
accounts, for the historical test year that ended June 30, 2022, in Excel format with formulas
intact:
a. 50650 - Include all sub accounts - Off,rce Expense
b. 50655 - Include all sub accounts - Miscellaneous Expense
c. 91860- Include all sub accounts - Other Awards
d. 92300930 Bank Charges - A&G Ops Miscellaneous General
e. 92600920 through 92600932 -OtherG&A Exp.
REQUEST NO. 106: Following up on Production Request No. 3, please provide the
amount of outside legal expense included in the Company's test year and proposed for
recovery in this case. Please reconcile the outside legal expenses provided in the Company's
response to Production Request No. 3 to the actual test year amount for outside legal
expense.
REQUEST NO. 107: Please provide a list of all workman's compensation insurance
claims that Veolia paid for the test year.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 15 DECEMBERZ,2022
REQUEST NO. 108: Please answer the following for the 15 newly hired positions:
a. Are they going to provide a mitigation of overtime?
b. What gaps, including service or overtime, will be filled with these positions?
REQUEST NO. 109: Please answer the following for the incentive program:
a. How are the employees' personal goals and the Company goals set for the Short-
Term Incentive Plan ("STIP")?
b. What are the required criteria for both exempt and non-exempt employees that
allow them to qualiff for the STIP?
REQUEST NO. 110: Please provide copies of the Health, Vision, and Dental Insurance
Plans Veolia provided to its employees, with cost breakdowns for employee, spouse, and family.
REQUEST NO. 111: Please provide answers to the following questions regarding Payroll:
a. How is payroll processed, especially time sheets?
b. How do employees track and submit their hours?
REQUEST NO. 112: Please provide a copy of Veolia's Cityworks contract. Also please
itemize
a. licensing cost per employee.
b. the cost of additional licenses needed for new employees
REQUEST NO. 113: Please provide all business insurance claims affecting liability and
property coverage for the test year.
REQUEST NO. 114: Please provide an itemized list of all necessary training and safety-
related costs for the test year for each of the following:
THTRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO l6 DECEMBER2,2022
a. Uniform costs, Arc Flash personal protective equipment (PPE) rental costs, fire
suppression system inspectionslalarm monitoring, OSHA standards and safety
equipment costs
b. Hearing tests for the 75 Bargaining Unit employees
c. ArcFlash, Confined Space, Trenching and Excavation training programs and
d. Industrial Hygienist Respirator/chemical/asbestos program assessment and
exposure monitoring.
REQUEST NO. 115: Please provide supporting documentation for the pro forma
adjustment made to the miscellaneous equipment account for December 2022. Please include any
cost/benefit analysis and approvals for projects included in the adjustment.
REQUEST NO. 116: Please provide the Company's policy for purchasing and retiring
fleet vehicles.
REQUEST NO. 117: Please explain and provide supporting documentation for the "File
Relocation Plan," found on the list of pro forma capital projects. Please include any cost benefit
analysis and approvals for the project.
REQUEST NO. 118: Please explain and provide supporting documentation for the
"Computer Refresh," found on the list of pro forma capital projects. Please include any cost benefit
analysis and approvals for the project.
REQUEST NO. 119: Please provide updated actual plant-in-service additions and
retirement amounts for July 2022 through the most recent period.
REQUEST NO. 120: Please provide receipts for the credit card transactions listed in
Attachment A, and identifu where the costs are included in the Application.
REQUEST NO. 121: Please identifu the number of disconnections for non-payment on a
monthly basis for calendar years2020,2021, and2022 to date. For comparison, please include
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO t7 DECEMBER2,2022
the number of customers for those same timeframes, and the number of disconnections as a
percentage of total residential customers for the same time period.
REQUEST NO. 122: Please provide the number and total dollar amount of deposits the
Company is currently holding for residential and commercial accounts. Please report the numbers
based on the reason the deposit was requested (termination of service, misrepresentation of
identity, damages, unauthorized service, failure to pass credit screen, indebted household, new
commercial customer, bankruptcy, etc.) and the customer's rate schedule.
REQUEST NO. 123: Please provide the following details for the Company's leak
adjustment program by year for 2020,202I, and2022 to date.
a. What are the audit parameters that prompt the Company to send a notice to the
customer because of high usage?
b. How many customers have received an adjustment of their water bill after
providing evidence of repairs?
c. Does the Company have an arrangement with all waste-water system operators to
adjust sewer rates if there was a leak and subsequent repair?
d. When and how does the Company notifu the respective waste-water authority of
the adjustment?
REQUEST NO. 124: For residential accounts identified as having been disconnected for
non-payment in the previous request, please provide the number of accounts that received Veolia
Cares benefits by month for calendar years 2020, 2021, afi 2022 to date. How many of those
customers were subsequently disconnected for nonpayment during the following two months?
REQUEST NO. 125: Without revealing customer identities or other confidential
information, please provide a spreadsheet showing the average monthly consumption of all
customers receiving assistance through the Veolia Cares program for calendar years 2020,2021,
and2022 to date.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO l8 DECEMBER2,2022
REQUEST NO. 126z Please provide an update on the Veolia Cares program. Please
explain any changes to the program since 2020. Please include monthly and annual data for
calendar year 2020,2021, and2022 to date by Company contributions, customer contributions,
total dollar amount awarded to customers, total number of customers assisted, and total amount
provided to El-Ada for administration.
REQUEST NO. 127: Please state whether all costs associated with the Veolia Cares
program are covered by shareholders. Please explain.
REQUEST NO. 128: Please provide the number of incoming calls handled by the
customer service representatives by month for calendar years 2020,2021, and 2022 to date. Are
all incoming calls handled within the Boise office? [f not, how are incoming calls handled?
REQUEST NO. 129: Please provide a breakdown of the number of incoming calls and
emails from customers to the Company by category (e.g., payment arrangements, starVstop
service, high bills, disconnections, etc.). Please include all calls, including those calls routed to
another department. Please provide the information by months for the years2020,2021, and2022
to date.
REQUEST NO. 130: Please provide the number of incoming calls handled by the
customer service representatives by month, about discolored water and the corresponding flushing
credit, on the East First Bench for calendar years 2020,2021, and 2022 to date.
REQUEST NO. 131: Please describe the customer self-help tasks that can be handled by
the lnteractive Voice Response ("IVR") or online, (e.g., bill payment, payment arrangements, etc.).
REQUEST NO. 132: Please provide the Company's performance objectives for handling
incoming calls; include objectives for both IVR and customer service representative ("CSR")
handled calls. What steps does the Company take if it fails to meet its performance objectives?
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO t9 DECEMBER2,2022
REQUEST NO. 133: Please provide the average speed of answer for CSR-handled calls
by month of the calendar years2020,202l,and2022 to date.
REQUEST NO. 134: Please provide a detailed explanation of the Company policy for
handling calls after hours whether for reconnection after a disconnection, for non-payment, or for
emergency shut-off because of leaks. The Company's office hours are listed as 8:00 am to 4:30
pm and the reconnection is offered at a higher charge between 4:31 pm and 6:30 pm.
a. Does the Company offer reconnect or emergency shut-off after the listed hours or
on weekends or holidays?
b. How does the Company provide support to fire and police emergencies after
hours?
REQUEST NO. 135: Do the CSRs have access to the status of the customer's certification
(if required under the Company program?). If not, how does a customer obtain that information?
REQUEST NO. 136: Please provide the number of complaints made directly to the utility
in 2020, 2021, and 2022 to date, pursuant to Rules 401 and 402 of the Commissions Utility
Customer Relations Rules. For each complaint, please describe the general nature of their subject
matter, how it was received (in person, by letter, telephone, or email), and whether a Commission
review was conducted. Did the Company change its practices in response to its analysis of those
complaints? If so, please explain the changes and/or modifications made.
REQUEST NO. 137: Please provide the number of 3/o-inch and l-inch residential meters
installed for new accounts for the years 2020,2021, and 2022 to date. Were the meters installed
all AMI meters? Please explain.
REQUEST NO. 138: Please provide the number of customers who have requested the
Company install an AMI meter to replace an older functioning non-AMI meter for 2020,2021,
and2022 to date. Please identify the size of the meter installed and whether the customers were
residential or commercial.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 20 DECEMBER2,2022
REQUEST NO. 139: Please provide the audit parameters the Company uses to detect
slowing or stopped meters. How often are reports reviewed, and within what time frame are field
investigations conducted and corrective action taken if necessary? Please provide the number of
meters replaced in 2020,2021, and 2022 to date, because of age or malfunction. How does the
Company determine whether to rebill the customer for usage when a meter malfunctions?
REQUEST NO. 140: Please provide a copy of the most recent Company Cross
Connection Control Program as required by the Idaho Department of Environmental Quality.
a. Please provide copies of the Company's annual and long-term Cross Connection
Control Program work plans.
b. Please explain how the Company is notified when an existing residential customer
installs a cross connection assembly or device. Is the notif,rcation process the
same regardless of whether or not the customer is located within a municipality?
c. Does a Certificate of Occupancy require the Company to inspect and sign off on
cross connections?
d. Please explain how the Company is notified when an existing customer. of any
type, has an existing cross connection assembly or device tested. How does
the Company confirm that the person performing the testing has adequate
certification and/or expertise?
e. Please provide examples of notices sent to customers regarding backflow assembly
testing, including'Notice to Test Your Irrigation/Fire Backflow Assembly."
REQUEST NO. l4l: Please provide a current copy of the Company's database for its
Cross Connection Control Program.
REQUEST NO. 142: For calendar years2020,2021, and2022 to date, please provide:
a. the number of customers who the Company has identified as having a cross
connection control device interconnected with their potable water service
connection. Please indicate whether the customer is a commercial customer or a
residential customer
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 2l DECEMBER2,2022
b. the number of customers who were sent a notice regarding their cross-connection
control device and the reason for the notice (i.e., missing or expired test certificate,
improper device or installation, or other failure to comply with the Company's cross
connection control program, etc.)
c. the number of customers that provided the required test certificates.
d. the number of customers disconnected for failure to provide remedy.
REQUEST NO. 143: Please provide the average time between initial notification by
the Company of non-compliance, and final customer compliance with the Company's Cross
Connection Control Program for systems with year-round use for the following:
a. Testing of backflow assemblies and devices
b. A lack of backflow protection
c. An improper backflow protection assembly or device.
REQUEST NO. 144: Please provide a copy of the Summary of Rules provided to
customers. Please provide an explanation of how and when it is sent.
REQUEST NO. 145: Please provide a copy of the Explanation of Rate Schedules
provided to customers. Please provide an explanation as to how and when it is sent.
REQUEST NO. 146: Please provide copies of the following Company documents:
a. Initial Notice to Terminate
b. Final Notice of Intent to Terminate Service
c. Notice of Procedure for Reconnecting Service left at the premises following
disconnection of service (door tag or notice, if used).
REQUEST NO. 147: Please provide a sample copy of a billing statement currently sent
to customers who have:
a. no past due balance owing.
b. apast due balance.
c. a monthly payment arrangement.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 22 DECEMBER2,2022
DATED at Boise,Idaho, U, LJ day of Dece mM2022.
i:umbcprodrcqfucon22.2cMsrnho* prod rcq 3
THIRD PRODUCTION RE.QUEST
TO VEOLIA WATERIDAHO
Chris Burdin
Doputy Attorney General
23 DECEMBER 2,2022
ATTACHME,NTA
TO
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF DECEMBER 2022,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO VEOLIA WATER IDArrO, INC., IN CASE NO.
YEO-W-22-02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
PRESTON N CARTER
MORGAN GOODIN
GIVENS PURSLEY LLP
PO BOX 2720
BOrSE tD 8370t-2720
E-MAIL: [e-mail]
rnorqanqoodi nf@ gi venspursley.com
stephaniew@ g ivenspursl e),.com
LORNA K. JORGENSEN
MEG WADDEL
ADA COTINTY PROSECUTING
ATTORNEY'S
OFFICE / CIVI DIVISION
2OO W. FRONT STREET, ROOM 3I9I
BOISE,ID 83702
E-MAIL : civilpafi les@adacount,v-. id. gov
JIM SWIER
MICRON TECHNOLOGY,INC
8OOO SOUTH FEDERAL WAY
BOISE, ID 83707
E-MAIL : j [e-mail]
MARY R. GRANT
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
105 N. CAPITOL BLVD.
PO BOX 500
BOISE,ID 83701-0500
E-MAIL : mrgrant@cit.v.'otboise.orq
boisec itvattorney(@citr"ofboise.org
DAVID NJUGUNA
MGR-REGULATORY BUSINESS
VEOLIA WATER M&S INC
46I FROM ROAD STE 4OO
PARAMUA NJ 07052
E-MAIL : David.ni ucuna(D,veolia.com
SHARON M. ULLMAN, PRO SE
599I E. BLACK GOLD STREET
BOISE,ID 83716
E-MAIL: sharonu2O I [e-mail]
AUSTIN RUESCHHOFF
THORVALD A. NELSON
AUSTIN W. JENSEN
HOLLAND & HART, LLP
555 17TH STREET SUITE 32OO
DENVER, CO 80202
E-MAIL : [e-mail]
tneI [e-mail]
awj ensen(@hol I andhart. corn
ac [e-mail]
kdspri g gs[Dhol landhart.corn
SECRETAR
CERTIFICATE OF SERVICE