20221209Micron 1-22 to Veolia.pdf

MICRON TECHNOLOGY, INC.’S
FIRST PRDUCTION REQUEST
TO VEOLIA -1-DECEMBER 9, 2022
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen
HOLLAND & HART LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF VEOLIA WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO
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CASE NO. VEO-W-22-02
MICRON’S FIRST SET OF
DISCOVERY REQUESTS TO
VEOLIA WATER IDAHO INC.
Micron Technology, Inc. (“Micron” or “Intervenor”), by and through its counsel, Holland
& Hart LLP, submits the attached interrogatories and requests for the production of documents to
Veolia Water Idaho Inc. (“Veolia”). The following response date, definitions, and instructions
apply to the enclosed interrogatories and requests for production of documents.
In addition to the written copies provided as responses to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
RESPONSE DATE, DEFINITIONS AND INSTRUCTIONS
Please respond to these interrogatories and requests for production of documents by
December 30, 2022.
DEFINITIONS
1.“Veolia Water Idaho Inc.,” “Veolia,” “VWID,” “the Company,” or “you” means Veolia
Water Idaho Inc. and the employees, officers, directors, agents, consultants, attorneys and
RECEIVED
2022 DEC -9 PM 2:51
IDAHO PUBLIC
UTILITIES COMMISSION

MICRON TECHNOLOGY, INC.’S
FIRST PRDUCTION REQUEST
TO VEOLIA -2- DECEMBER 9, 2022
all persons acting under contractual arrangement with or acting or purporting to act on
behalf of Veolia.

2. “Agreement” means any contract, written or oral, or any non-contractual understanding.

3. “And/Or” will be construed disjunctively or conjunctively as necessary so that the scope
of these interrogatories is as broad as possible and includes any information which might
be constructed to be outside their scope.

4. “Communication” should be interpreted as broadly as possible to include, but not be
limited to, all forms of communication, whether written, printed, oral, pictorial, electronic
or otherwise and by any means or type whatsoever.

5. “Date” shall mean the exact day, month, and year if ascertainable, or if not the best
approximation thereof in relation to other events.

6. “Document” and “documentation” should be interpreted as broadly as possible, including
the original or any copy, regardless of origin or location, of any book, pamphlet, periodical
publication, letter, scrapbook, diary, calendar, canceled check, photograph, form,
memorandum, schedule, tax return, telegram, telex, report, record, order or notice of
governmental action of any kind, study, minutes, logs, graph, index, tape, disc, internal
operating manual, data sheet or data processing card, or any other written, recorded,
transcribed, punched, taped, filmed, graphic or retrievable matter or data of any kind,
however produced or reproduced, to which you have or have had access. This definition
includes all documents which have been created and/or which reside in any type of
electronic format.

Any document that is not exactly identical to another document for any reason (such as
marginal notations or deletions) should be considered a separate document.

As to any document related to the matters addressed herein that is not currently in your
possession but that you know or believe such a document exists, you are requested to
identify and indicate to the best of your ability its present or last known location or
custodian.

7. To “describe, “detail,” or “state” shall mean to relate as completely as possible each and
every act, omission, incident, event, condition, circumstance, decision, and/or thing
relating directly or indirectly to the subject of the explanation including all pertinent dates.

8. To “explain” means to make known in detail, to make clear the cause or reason of any
account for each act, omission, incident, event, condition, circumstance, decision, and/or
thing relating directly or indirectly to the subject of the explanation including all pertinent
dates.

9. Any request to “identify” or “provide” should be interpreted to mean:

MICRON TECHNOLOGY, INC.’S
FIRST PRDUCTION REQUEST
TO VEOLIA -3- DECEMBER 9, 2022
a. With respect to a natural person, that person’s full name, title, job description, and
business and home address. Where the identification pertains to a past period, as
to each person identified who is still in your employ, or the employment of the
group with which such person is identified in response to any requests, provided,
in addition, that person’s title and job description as of the time of such past period.
Where the person is no longer in your employ or the employment of the group with
which such person is identified in response to any request, provide that person’s
affiliate, position, home and business address, if known, or if not known, such
person’s last known affiliation, position, home and business address, or portions
thereof as may be known.

b. With respect to an entity other than a natural person, that entity’s name, business,
type of entity, present status and present or last known address.

c. With respect to a document, that document’s title, date, author (and, if different, the
signer), addresses, recipients, or other persons who assisted in the preparation,
subject matter or general nature, and any amendments thereto, present location and
custodian, whether or not such document is in the respondent’s possession, custody
or control and whether or not the document is claimed to be privileged. The final
version and each draft of each document should be identified and produced
separately. Each original and each non-identical copy (bearing marks or notations
not found on the original) of each final version and draft of each document should
be identified and produced separately.

d. With respect to a physical facility, the location of the facility, the intended purpose
of the facility, the actual use of such facility, the operating dates of the facility, the
installation date of the facility, the date utilization of the facility terminated if
applicable, and whether the facility is subject to the jurisdiction of the Idaho Public
Utilities Commission, the Federal Energy Regulatory Commission, or any other
regulatory body.

10. “Person or Entity” should be interpreted to denote, unless otherwise specified, any natural
person, firm, corporation, association, group, individual or organization of any type
whatsoever.

11. “PUC” or “Commission” means the Idaho Public Utilities Commission.

12. “Record” or “Records” includes any regulation, formal or informal, official or unofficial
memorandum, document or written preservation of any events, actions taken or rejects,
decisions and details thereof relating to the subject matter of the question and your response
including electronic data and e-mail. A copy of the original “record” is preferred; stating
the substance thereof will suffice where a copy cannot be made and is not available.

13. “Relating To” or “Related To” means pertaining to, presenting, discussing, commenting
on, analyzing, or mentioning in any way.

MICRON TECHNOLOGY, INC.’S
FIRST PRDUCTION REQUEST
TO VEOLIA -4- DECEMBER 9, 2022
GENERAL INSTRUCTIONS

1. Interrogatories and requests for production must be answered with particularity and in
detail.

2. Interrogatories and requests for production must be answered separately and fully in
writing under oath within twenty-one (21) days after service in accordance with IDAPA
31.01.01.225.

3. Interrogatories and requests for production must be signed by the person upon whose
personal knowledge responses are based or who helped in any way in answering these
interrogatories and requests for production.

4. You must provide the names of any other persons upon whose personal knowledge
responses are based or who helped in any way in answering these interrogatories and
requests for production.

5. In making your answers, you must produce all relevant documents and data by attachment
or by identifying the documents which relate to your answers. You must also clearly
identify each interrogatory to which the document relates.

6. These interrogatories and requests for production are continuing in nature and in the event
any information provided in an answer is changed or supplemented by future developments
or other factors, you must file appropriate supplemental answers.

7. In answering these interrogatories and requests for production you should furnish all
information which is in your possession, custody or control including, but not limited to,
information from any files, records, or documents in the possession of your attorneys,
consultants, staff, accountants, experts, employees, former employees, and other agents.

8. These interrogatories and requests for production should be answered based on your
personal knowledge, the personal knowledge of your attorneys, consultants, staff,
accountants, experts, employees, former employees, and any other agents as appropriate or
available and with reference to the sources described above.

9. If the respondent is not a witness who has filed written direct testimony, please indicate
which of the company's witnesses will be prepared to answer these questions on the stand.

10. In addition to a hard copy, please provide an electronic copy of your responses in Microsoft
Word. Where responses are prepared using spreadsheet software, please provide an
electronic copy in Microsoft Excel format.

11. If after exercising due diligence you are unable to answer any interrogatory or to produce
any document requested, you must explain your inability in detail.

MICRON TECHNOLOGY, INC.’S
FIRST PRDUCTION REQUEST
TO VEOLIA -5- DECEMBER 9, 2022
12. If you object to any interrogatory or request for production, you may serve written
objections on Micron as provided in IDAPA 31.01.01.225, identifying the subject matter
objected to and stating with particularity the reasons for the objections. In addition, the
objections and the answers must be contained in separate pleadings with each clearly
identified as an objection or answer. The service of an objection will not excuse you from
answering the remaining interrogatories or responding to the remaining requests for
production for which no objection is stated.

13. If any responses to these interrogatories or requests for production have already been
provided in prior discovery in this matter, please direct Micron to the specific discovery
request and response where such response can be found.

14. Copies of the responses and any and all documents produced should be provided to:

Thorvald A. Nelson
Austin Rueschhoff
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: Please provide copies of all data requests and responses issued to
Veolia Water Idaho, Inc. (“VWID”) by all parties in this case. This is an ongoing request.

REQUEST NO. 2: Please provide the exhibits of all witnesses who filed direct testimony
on behalf of VWID in electronic spreadsheet format with all formulas and links intact.

REQUEST NO. 3: Please provide the workpapers of all witnesses who filed direct
testimony on behalf of VWID in electronic spreadsheet format with all formulas and links intact.

REQUEST NO. 4: To the extent not provided in response to the above, please provide a copy
of the load study discussed in Appendix B to Ms. Bui’s testimony, along with all supporting
workpapers and resource material. Please provide the load study in electronic spreadsheet format
with all formulas and links intact.

REQUEST NO. 5: For the test year and resource planning year purposes, please provide
hourly water pumping data at:

MICRON TECHNOLOGY, INC.’S
FIRST PRDUCTION REQUEST
TO VEOLIA -6- DECEMBER 9, 2022
a. water treatment plant,

b. purchased water delivery to Veolia; and

c. water delivered via the transmission mains to the distribution mains.

Please acknowledge that the Company’s advanced metering devices are tracking this hourly
volume data for test year, and/or for resource planning purposes.

REQUEST NO. 6: Please refer to Bui, Appendix B at page 8. Paragraph 1.1 states that
the current tariff includes an Industrial classification; however, no active customers are in this
class. Please provide VWID’s definition of an Industrial customer, along with documentation
supporting the response.

REQUEST NO. 7: Please identify any water customers that meet the following load
characteristics: served on meter size 8 inches and larger, have ratios of extra capacity volumes
relative to base volumes that are lower than the system average, and are served directly from a
transmission main of 8 inches or larger.

REQUEST NO. 8: Please refer to Bui, Appendix B at page 11. Paragraph 2.2 states that
the period of 6/1/2021 – 8/31/2021 would define the analytical window and would contain the MD
and MH values for the system and customer classes. Please confirm that there were no water usage
restrictions in place during this time. If not confirmed, please identify the dates in which
restrictions on water usage were in place.

REQUEST NO. 9: Please provide VWID’s definition of a Residential customer. Please
include documentation supporting the response.

REQUEST NO. 10: Please provide VWID’s definition of a Commercial customer. Please
include documentation supporting the response.

REQUEST NO. 11: Please provide VWID’s definition of a Public Authority Customer.
Please include documentation supporting the response.

REQUEST NO. 12: Please provide VWID’s definition of Private Fire Customer. Please
include documentation supporting the response.

REQUEST NO. 13: Please refer to Bui, Appendix B at 15, Section 3.3.1. In electronic
spreadsheet format with all formulas and links intact, please provide the workpapers that were
used to develop an average hourly usage profile for each customer class, as described in Section
3.3.1.

REQUEST NO. 14: Please refer to Bui, Appendix B at Table 4-1 and Table 4-3.

MICRON TECHNOLOGY, INC.’S
FIRST PRDUCTION REQUEST
TO VEOLIA -7- DECEMBER 9, 2022
a. These tables show that the coincident peak demand and the non-coincident peak
demand for the Commercial class are the same (i.e., 3,681,223 cubic feet). Please
confirm that this is correct.

b. In electronic spreadsheet format with all formulas and links intact, please provide
the workpapers supporting the development of these tables.

REQUEST NO. 15: Please refer to Bui, Appendix B at page 22, which states, “although
total rainfall for July 2021 was unusually high, over 90% of the entire volume recorded for July
occurred in one day (July 31st, 2021), meaning it was generally also a typically dry month.” In
electronic spreadsheet format with all formulas and links intact, please provide the workpaper
supporting the quoted statement.

REQUEST NO. 16: Please refer to Bui, Appendix B, at page 5. Regarding the subset of
14,245 AMI meters that were used to develop the customer class MD and MH demand ratios in
the load study, please provide the monthly billed water consumption for calendar year 2021 for
each AMI meter in the subset. Please provide the data by customer class, in electronic spreadsheet
format, with formulas and links intact.

REQUEST NO. 17: Regarding transmission mains:

a. Please identify all sizes (in diameter) of transmission mains installed on the
Company’s transmission system.

b. For each main size identified in part a., above, please provide the total length of
main installed on the Company’s transmission system.

c. Please describe the Company’s meter installation protocols in terms of specifying
the size of a main that is needed to connect a specific meter size to its transmission
system.

REQUEST NO. 18: Regarding distribution mains:

a. Please identify all sizes (in diameter) of distribution mains installed on the
Company’s distribution system.

b. For each main size identified in part a., above, please provide the total length of
main installed on the Company’s distribution system.

c. Please describe the Company’s meter installation protocols in terms of specifying
the size of a main that is needed to connect a specific meter size to its distribution
system.

REQUEST NO. 19: Please identify the number of meters, the size of the meters, and the
sizes of mains that serve Residential customers.

MICRON TECHNOLOGY, INC.’S
FIRST PRDUCTION REQUEST
TO VEOLIA -8- DECEMBER 9, 2022
REQUEST NO. 20: Please identify the number of meters, the size of the meters, and the
sizes of mains that serve Commercial customers.

REQUEST NO. 21: Please identify the number of meters, the size of the meters, and the
sizes of mains that serve Other Public Authority customers.

REQUEST NO. 22: Please provide documentation describing VWID’s meter installation
policies, including descriptions of the sizes of mains that can be used to safely and reliably provide
service to various meter sizes.

Respectfully submitted December 9, 2022.
HOLLAND & HART, LLP

By:
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

Attorneys for Micron Technology, Inc.

MICRON TECHNOLOGY, INC.’S
FIRST PRDUCTION REQUEST
TO VEOLIA -9- DECEMBER 9, 2022
CERTIFICATE OF SERVICE
I hereby certify that on December 9, 2022, a true and correct copy of the within and
foregoing FIRST PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO VEOLIA
WATER IDAHO INC. was served in the manner shown to:

Idaho Public Utilities Commission

Chris Burdin
Dayn Hardie
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
P.O. Box 83720
Boise ID 83720
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Ada County

Lorna Jorgensen
Meg Waddel
Ada County Prosecuting Attorney’s Office
Civil Division
200 W. Front Street, Room 3191
Boise, ID 83702
[e-mail]

Veolia Water Idaho Inc.

Preston N. Carter
Morgan D. Gooding
Givens Pursley LLP
601 W. Bannock Street
Boise, ID 83702
[e-mail]
[e-mail]

Veolia Water M & S

David Njuguna
Veolia Water M & S
461 From Road, Suite 400
Paramus, NJ 07052
[e-mail]

Micron Technology, Inc.

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
[e-mail]

Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

MICRON TECHNOLOGY, INC.’S
FIRST PRDUCTION REQUEST
TO VEOLIA -10- DECEMBER 9, 2022
Sharon Ullman

Sharon M. Ullman
5991 E Black Gold Street
Boise, ID 83716
[e-mail]

City of Boise City

Mary R. Grant
Deputy City Attorney
Boise City Attorney’s Office
105 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]

s/ Adele Lee
20487831_v1