20221223Veolia Water to Staff 42-147.pdf

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]
prestoncarter@ sivenspursley. com
morsaneoodin@ givenspursley. com
iiLCiIVED
; lji il[[ 23 &H l0' 0l
,r :. -, .: - l-iLiLiC,'- ;1,11,11-llSSl0i'l
Attorneys for Veolia l(ater ldaho, Inc.
BEFORE TIIE IDAIIO PIIBLIC UTILITIES COM]VtrSSION
IN THE MATTER OF THE APPLICATION
OF VEOLIA WATER IDAHO, INC. FOR A
GENERAL RATE CASE Veoue Waren IDAHo, INC.'S
RrspoNsEs ro THrRD PRooucrroN
Rrqursr or rHE CoMMrssroN $1app
ln response to the Third Production Request of the Commission Staffto Veolia Water
ldaho, Inc. dated December 2,2022, Veolia Water ldaho, [nc. ("Veolia" or "Company"), submits
the non-confidential responses contained below. Documents are available for download at the
link provided in the transmittal email. Confidential responses and documents will be provided
separately under the terms of the Protective Agreement.
As set forth in correspondence with Stafl Veolia will provide additional responses on
January 4,2023 and complete the responses on January 9,2023.
DATED: December 22, 2022.
9 --_- '/ - ry. 2-Z--
Case No. VEO-W-zz-02
By:
Preston N. Carter
Givens Pursley LLP
Attorneys for Veolia Water ldaho, Inc.
Veolm. WATER IDAHo, INC.'S RrspoNsEs ro THnD PRoDUCTIoN
Rrqursror run CouutssloN STAFF
t6518505_l.Docx (3G.235)
PAGE I oF 3
CERTIFICATE OF SERYICE
I certiff that on December, 2022, a tnre and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:
Commission Staff
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise,ID 83714
Dap Hardie
Deputy Attomey General
Idaho Public Utilities Commission
I1331 W. Chinden Blvd., Bldg. 8, Suite 201-,4'
Boise,ID 83714
Loma K. Jorgensen
Meg Waddel
Ada County Prosecuting Attorney's Office
Civil Division
200 W. Front Street, Room 3191
Boise, D 83702
Sharon M. Ullmar5 pro se
5991 E. Black Gold St.
Boise, ID 83716
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Je,nsen
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, lD 83707
Mary Grant
Deputy City Attorney
Boise, City Attorney's Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
VBor-rl Wlrrn IDAHo, INC.'S RESPoNSES ro THRD PRoDUCTIoN
Rnquesr or rHE CoMMrssroN Srarr
l65l 8505_l.Docx (3G235)
Via Electronic Mail
j an.noriyuki@puc. idaho. gov
daym.hardie@puc. idaho. gov
civilpafiles@adacounty. id. gov
sharonu20 I 3 @gmail.com
darueschhoff@hollandhart. com
tnelson@hollandhart. com
awj [e-mail]
aclee@hollandhart. com
kdspriggs@hollandhart. com
[e-mail]
BoiseCityAttorney@cityofboise. org
mr gr ant@cityofboise. org
PecB 2 or 3
a?
Preston N. Carter
Veoln Wernn Ioego, INC.'s RESIoNSES To Tnmo PRooucnoN
Requrst or rHr Courr.rrsslou Srerr
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4.* Z-- --
Pece 3 op 3
\IEOLTA WATER IDAHO, INC. CASE \mo-\tr-22-02
THIRD PROIIUCTTON REQUEST OX'Tru COMMTSSTON STArr
Preparer/Sponsoring Witress: Zerhouni
REOI]EST NO.42:
Please provide supporting workpape(s), in Excel format with formulae intact, for
Management & Service ('M&S*) Fee Adjustment No. 19. Please update workpape(s) with actual
amounts as data become available.
RESPONSE NO.42:
Please see Attachment I as support for Management & Service ("M&S') Fee Adjustnent
No. 19. Attaohment 2 supports the calculation of the M&S shared assct adjustment.
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vEoLrA WATER IDAHO, rNC. CASE VE,O-W-22-02
THIRD PRODUCTTON REQUEST OF TEE COMn{ISSION STAFF
Preparer/Sponsoring Witness: Zerhouni
REOT]EST NO.43:
Please provide a copy of the Cost Allocation Manual ("CAM") in Word and PDF format.
RESPONSE NO.43:
Please see attached Attachmeirt I and Attachment 2 for copies of the Cost Allocation
Manual in Word and PDF format. Please note that Company names, the list of affiliates, and
organizational chart has not been updated since the change in control. However, the general
principles, services providd and cost allocation methodology lsalains the same.
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yEoLIA WATER IDAIIO,INC. CASE YEO-W-2242
THIRD PRODUCTION REQTIEST OF TIIE COMMISSION STAFF
Preparer/Sponsoring Witness: Zerhouni
REOUEST NO.45:
Please provide detailed descriptions and the cost-benefit analysis for each M&S Shared
Services department.
RESPONSE NO.45:
Please refer to Request No 43 Response Attachment I (Veolia Water M&S Cost
Allocation Manual) that provides descriptions of the different departuents that constitute the
service company, Veolia Water M&S (Paramus) Inc. ("M&S').
M&S is set up to provide a common suite of services to Veolia Water ldaho, Inc. ("VWID") and
other business units through the allocation of M&S fees based on the three - factor fonnula net .
of capitalization as applicable to each departrnent. This enables significant specialization and
provides the scale to enable investment in sophisticated information systems to support all
processes. Often, corporate acquisitions of additional utility service providers result in an
increasing ability to share the costs of these specialized services over a greater base. The
economies of scale benefit ratepayers by the "sharing" of services and costs among affiliates thus
reducing the costs to individual affiliates.
The services provided by M&S are critical all year round to provide standardization and
synergies across the business units. The importance of the services provided which were
highlighted in wake of the Coronavirus pandemic, were vital to the ongoing operations of the
business. During the outbreak, ffiily of the M&S employees were working remotely. WIID and
all other business units were able to maintain ongoing operations mainly with the help and
support of the information technology services provided by M&S.
M&S continues to provide the business units with needed services. For example,
Procurernent and Supply Chain Management ensures the business units receive good pricing,
Environmental Health and Safety continues to develop a safe culture throughout the business
units, and Human Resources ensures policies that apply to corporate are the same across the
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utilitybusiness (i.e., compensation, merit 29 increases etc.). Human Resources also provides
recruiting hiring and retiremeirt services to the business uni*.
In 2015 and2020, PA Consulting performed a comprehensive review of the services
M&S offered to Veolia Water New Yorlq Inc. and Veolia Water Pennsylvaniq Inc. respectively,
both subsidiaries of Veolia Utility Resources LL,IC similar to VWID. The results of the studies
(attached to this response as Attachme,nt 1 and Attachment 2) are relevant as they benchmark
M&S to the shared services of other utility companies. Though not performed directly for
services to V![ID, the results summarize the costs and benefits of the shared services offered by
M&S.
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YEOLIA WATER TDAHO, INC. CASE YEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Zerhouni
REOUEST NO.46:
Please provide a desciiption of the work that M&S Shared Services, Legal, directly
performed for Veolia Water Idaho, Inc.
RESPONSE NO. 46:
The following is a list of legal services provided by Veolia Water M&S (Paramus) [nc.
("M&S") to Veolia Water Idaho Inc. (*VWID') as detailed out in the Cost Allocation Manual
which is attached as part of Response No. 43.
l) Handle all matters related to general litigation involving the company.
2) Perform legal services for securities and corporate financial transactions, financial
reporting and disclosures, business organizations, mergers, acquisitions and business
development, corporate govemance, risk management, insurance, executive
compensation.
3) Manage legal services for commercial and contract law matters for the corporation,
including real estate maffers and land use permits.
4) Serve as board secretary and support corporate governance functions, board of
directors meetings, legal opinion letters, assists audit and compliance functions, and
ensures compliance with corporate registration and regulation.
5) Retain and manage external counsel to provide legal representation in specialized areas
of law and to manage variable level legal work.
6) Legal work supporting the negotiation of water purchase agreements and other
procurement contracts as well as legal work related to franchise renewals, water rights.
7) Provide legal advice and representation with regard to intellectual property matters.
8) Perform legal services for matters involving environmental law for the corporation
including environmental permitting activities, due diligence, defense in enforcement
actions, compliance advice, representation in environmental cleanup and environmental
litigation costs.
9) Provide legal advice, representation and counseling in matters arising under federal
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and stat€ wat€r rcgulatory laws, regulations and policies as they relate to the Company's
utilrty rolated assets for water and waste water.
l0) Provide risk management servioes including managoment of the instrance an(surety
bondprograms.
I l) lvlanagc and administers corporate legal and regulatory compliance prograrns.
YEO-W-2242
IPUC DR46
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vEoLIA WATER IDAHO, INC.
CASE VDO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper/Cagle
REOUEST NO.47:
Please provide the Company's operating plans and capital budgets for each year from
2022 through2026. 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 ('DS[C''), if
it is approved.
RESPONSE NO. 47:
The Company's operating plans and capital budgets for the years2022 through 2026 are
presented in Table I below.
Table I
Budeet Cateeorv 2022 2023 2024 2025 2026
Plant large proiects 4.744 600 13.500 32.537 29.500
Plant common proiects 13.686 n.637 13"91I 13.91I l3"9l l
Plant roll-up 5,812 6,477 6.234 6.234 6.234
Network common prolects 5,244 7,167 7,388 7,500 7,500
Network blankets 4,900 4,950 4,950 4,950 4,950
Meter blankets 1,270 1,270 2,514 2,514 2,514
Overheads (Local)2.300 2.412 2.484 2.559 2.559
Total 37,957 34,513 50,981 70.204 67,167
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Within the first year, after March 31,2023, the company would include water mains, valves
(including short mains and valves), services, hydrants, and meters. These assets are associated
with the budget categories found in Table I titled Network Common Projects, Network Blankets,
and Meter Blankets. The specific projects proposed for DSIC in the first year are presented in
Table 2, below.
Table 2
Project
ID Proiect Title Budget Cateeory
Budget
Amount
c23D604
East First Bench Main
Replacements Network common proiects t60
c23D603 T&D Main Replacements Network common proiects 850
c23D605 EWC T&D Main Replacements Network common proiects 100
c23D70l Agency Mains Network common proiects 3,200
c23D00l Fire Hydrants Network blankets 1,594
c23D002 New Short Mains & Valves Network blankets 27s
c23D502
Replacement Short Mains &
Valves/ Blow-Offs Network blankets 675
c23D503 T&D Valve Replacements Network blankets 200
c23F505 Domestic Services Network blankets 2,858
c23Gs0l Customer Meters Meter blankets 1,270
Total I l,l 82
Note: budget amounts in Tables I and2 are reported in thousands. The actual dollar amounts are
based on multiplying the reported amount by 1,000. The amounts do not include corporate
overhead rates, which would also be added to the total project costs and submitted in the DSIC
filing.
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IPUC DR 47
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vEoLIA WATER IDAHO, INC.
CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper/Cagle
REOUEST 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 and/or rehabilitation
within the next five years. Include why it needs replacing, when it needs to be replaced, and
expected cost.
RESPONSE NO. 48:
The material, number of miles, size, and age of transmission and distribution pipe in the
Company's system that currently needs to be replaced is listed in Table l. The pipeline
replacements are from Veolia's Master Facilities Plan dated October 2022 for the next five years.
The Master Facilities Plan evaluates system deficiencies and outlays a capital improvement plan
towards fixing the deficiencies. The reason for replacing the mainline, general timeline of
replacement, and expected costs are included in Table 2.
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Table 1
Project
ID Proiect Title Pipe Material
Number of
Miles Size Aee
T.8
Market to
Entemrise
Asbestos
Concrete 0.70
8 and 12-
inch
1969 and
1972
T.17
Five Mile - Seneca
to Sandpiper
Asbestos
Concrete, Plastic t.67
6 and 8-
inch
1978,1992,
1997, and
I 998
T.20
Barlow Lane
Pipeline
Improvements
Asbestos
Concrete 0.08 4-inch 1962
T.2l
PhillippiStreet
Pipeline
Improvements
Asbestos
Concrete 0.14 6-inch 1992
T.22
Hillcrest View
Drive Pipeline
Asbestos
Concrete, Plastic,
and Steel 0.31
4,6, and
8-inch
1954, 1958,
and2014
Curtis - Targee to
Overland Pipeline
lmDrovements
Asbestos
Concrete 0.51 8-inch
1960,1970,
1971, and
1977T.23
Asbestos
Concrete 1.00 8-inch
1962,1975,
1976,1978,
1979, and
l98lT.24
Overland - Orchard
to Kirkwood
Pipeline
Improvements
Asbestos
Concrete 0.30
6 and l0-
inch 1963T.25
Orchard &
Hillcrest Shopping
Center Pipeline
Improvements
Cast Iron 0.48 6-inch t928T.26
Roosevelt -
Overland to Cassia
Pipeline
Improvements
T.27
Kootenai Street
Pipeline
Improvements Cast Iron 0.21 6-inch 1952
T.28
Camas Street
Pipeline
ImDrovements
Asbestos
Concrete and
Plastic 0.57
8 and 6-
inch
1963,1979,
and 2005
T.29
Columbus Street
Pipeline
Improvements
Asbestos
Concrete and
Steel 0.1r 6-inch
1956 and
1957
Ponderosa Pipeline
Imorovements Cast Iron 0.20
4 and 6-
inch r944T.30
T.3l
Vista - Overland to
Cassia Pipeline
Improvements
Asbestos
Concrete 0.50 8-inch t973
Euclid Street
Pipeline
Improvements
Asbestos
Concrete 0.25
4 and 6-
inch r959T.32
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T.35
Auto Drive
Pipeline
Asbestos
Concrete and
Plastic 0.40 8-inch
1969 and
1987
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T.37
Anna Street
Pipeline
Imorovements
Asbestos
Concrete 0.05 6-inch r 98l
T.39
Franklin - Curtis to
Orchard Pipeline
Improvements
Asbestos
Concrete 0.s0 8-inch 1956,1978
T.43
Clinton Street
Pipeline
Improvements
Asbestos
Concrete 0.15 6-inch 1977
T.44
Emerald & Curtis
Pipeline
Improvements
Asbestos
Concrete 0.24 6-inch 1962
T.45
St. Alphonsus
Pipeline
Improvements
Asbestos
Concrete 0.26 6-inch r970
T.46
Gage Street
Pipeline
Improvements
Asbestos
Concrete 0.09 6-inch t959
T.48
Orchard &
Fairview Pipeline
Improvements Cast Iron 0.t2 6-inch 1946
T.49
Hartman Park
Pipeline
Improvements Plastic 0.08 6-inch 1990
T.50
Opohonga Street
Pipeline
ImDrovements Plastic 0.06 6-inch l 984
T.55
Ustick Tank
Pipeline
Improvements
Asbestos
Concrete 0.25 l2-inch
1972 and
1979
T.58
Brynwood Drive
Pipeline
Improvements
Asbestos
Concrete 0.38
6 and 8-
inch
1964 and
1967
T.66
Hill Road Pipeline
Improvements
Asbestos
Concrete and
Ductile lron 1.30 l2-inch
1979,1981,
and 1989
20th Street Pipeline
Improvements Cast Iron 0.54
4 and 6-
inch
1924
andl937T.68
T.70
Horizon Drive
Pipeline
Improvements
Asbestos
Concrete 0.23 6-inch I 950
T.72
Crestline Drive
Pipeline
Improvements
Asbestos
Concrete, Cast
Iron, and Plastic t.l6
6 and 8-
inch
1982, 1987,
and 1988
T.73
Jefferson Pipeline
Improvements
Ductile Iron,
Plastic 1.26
l6 and
24-inch
l9l2 and
1994
23rd Street
Pipeline
Asbestos
Concrete and
Galvanized Iron
T.67 ements P 0.22
2 and 6-
inch
1949 and
1973
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Table 2
Project
ID Proiect Title Need
Replacement
Year I
Budget
Amount
T.8 Market to Enterprise
Increase
transmission
Capacity 2026 $ 2.125.900
T.t7
Five Mile - Seneca to
Sandpiper
Increase
transmission
capacity
2023 and
2025 $ 4,855,900
T.20
Barlow Lane Pipeline
Improvements
Increase fire flow
and pressure 2023-2027 $ 84,200
T.2t
Phillippi Street Pipeline
Improvements
Increase fire flow
and Dressure 2023-2027 $ 101.500
T.22
Hillcrest View Drive
Pipeline Improvements
Increase fire flow
and transmission 2023-2027 $ 293,400
T.23
Curtis - Targee to Overland
Pipeline Improvements
Increase
transmission of
max day and
peak hour
demand 2023-2027 $ 934"700
T.24
Overland - Orchard to
Kirkwood Pipeline
Improvements
Increase
transmission of
max day and
peak hour
demand 2023-2027 $ t,854,s00
T.2s
Orchard & Hillcrest
Shopping Center Pipeline Increase fire flow
and 2023-2027 $
T.26
Roosevelt - Overland to
Cassia Pipeline
Improvements
Improve Water
Quality and
increase fire flow
and pressure 2023-2027 $ 846,900
T.27
Kootenai Street Pipeline
Improvements
Improve Water
Quality and
increase fire flow
and Dressure 2023-2027 $ 341,700
T.28
Camas Street Pipeline
Improvements
Increase fire flow
and pressure 2023-2027 $ I,015.300
T.29
Columbus Street Pipeline
Improvements
Improve Water
Quality and
increase fire flow
and Dressure 2023-2027 $ 23s.300
T.30
Ponderosa Pipeline
Improvements
Improve Water
Quality and
increase fire flow
and Dressure 2023-2027 $ 315.600
T.3l
Vista - Overland to Cassia
Pipeline Improvements
Improve Water
Quality and
increase fire flow
and pressure 2023-2027 $ 897.s00
T.32
Euclid Street Pipeline
Improvements
Increase fire flow
and pressure 2023-2027 $ 912,500
T.35
Auto Drive Pipeline
ImDrovements
Increase fire flow
and pressure 2023-2027 $ 622.700
T.37
Anna Street Pipeline
Improvements
Increase fire flow
and pressure 2023-2027 $ 84,200
T.39
Franklin - Curtis to Orchard
Pipeline ImDrovements
Increase
transmission of
max day and
peak hour
demand 2023-2027 $ 448,100
T.43
Clinton Street Pipeline
Improvements
Improve Water
Quality and
increase fire flow
and pressure 2023-2027 $ 287.200
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T.44
Emerald & Curtis Pipeline Increase fire flow
and 2023-2027 $3 700
T.45
St. Alphonsus Pipeline
ImDrovements
Increase fire flow
and pressure 2023-2027 $ 382,500
T.46
Gage Street Pipeline
Improvements
Increase fire flow
and pressure 2023-2027 $ 268,600
T.48
Orchard & Fairview
Pipeline Improvements
Increase fire flow
and Dressure 2023-2027 $ 198,100
T.49
Hartman Park Pipeline
Improvements
Increase fire flow
and pressure 2023-2027 $ 126,300
T.50
Opohonga Street Pipeline
Improvements
Increase fire flow
and pressure 2023-2027 $ 143,600
$ 608.000T.55
Ustick Tank Pipeline
Improvements
Increase
transmission of
max day and
peak hour
demand 2023-2027
Brynwood Drive Pipeline
ImDrovements
Increase fire flow
and pressure 2023-2027 $ 666.100T.58
T.66
Hill Road Pipeline
Improvements
Increase
transmission 2023-2027 $ 4.307.300
Increase fire flow 2023-2027 $ 24s.100T.67
23rd Street Pipeline
Improvements
Increase fire flow 2023-2027 $ 82s,700T.68
20th Street Pipeline
Improvements
Horizon Drive Pipeline
Improvements
Increase fire flow
and pressure 2023-2027 $ 397,500T.70
T.72
Crestline Drive Pipeline
Improvements
Increase fire flow
and pressure 2026 $ 996,700
Jefferson Pipeline
ImDrovements
Increase
transmission 2025 $ 3.246.300T.73
TOTAL $ 27.383"700
L Projects with years 2023-2027 indicates the projects have not gone through Veolia's capital planning
and approval process and therefore do not have a specific year planned.
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vEoLIA WATER IDAHO, INC. CASE YEO-W-22-02
TITTRD PRODUCTTON REQITEST OF THE COMMTSSION STAIT'
Preparer/Sponsoring Witness: Cagle
REOUEST NO. 49:
Regarding Company witness Cagle's Direct Testimony at 3, please explain the difference
between replacement and rehabilitation.
RESPONSE NO.49:
In the instance of a rehabilitation, the original main is retained and rehabilitated through
the process of cleaning and lining or other lining application. In some instances, these processes
can be used to meet the demands of the project. A replacement is a full replacement of the main.
Generally, VWID replaces mains and does not utilize a rehabilitation process.
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vEoLrA WATER IDAHO, rNC.
cAsE vBo-w-22-02
THIRD PRODUCTION REQUEST OF TIIE COMMTSSTON STAIT'
Preparer/Sponsoring Witness: Cooper/Cagle
REOUEST 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.
RESPONSE NO.50:
Other infrastructure in the system that requires replacement and/or rehabilitation within
the next five years (outside of transmission/distribution and blanket project replacements)
includes plant roll-up projects that address pumping, storage, supply and operations facilities
(listed in Table 1). In addition, larger rehabilitation projects for pumping, storageo supply, and
operations facilities are planned (listed in Table 2). These projects are not included in the
summary of projects that could be considered for Distribution System lmprovement Charge
(DSIC) listed in Data Responses 47 and 48.
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Tablel - Plant Roll-Up Projects 2022 2023 2024 2025 2026
CYYB50l Replace Treatment Eouipment S 120 s 110 S t4o S rno S rao
CYYB5O3 Reolace Valves. lvleters. & Actuators at WTP'S s40 s 30 s40 Stm slm
CYYB5@ Chlorination Eouioment s 300 s 300 s3m s 300 s 300
CYYB506 Surface Treatment Plant Roll-Up S 7so S zso S zso S 7so S zso
CYYB5OT CL2 Generator Replacement s 6s0 S 488 S 488 S as8 S +e8
CYYC101 Pump Equip-Sources of Supply Sgm s 9m s 1m0 s Lmo s 1m0
CYYC102 Replace Booster Pump Equipment S 1oo s 100 Stm S loo S 1oo
CYYC501 Reconstruct Pumoine Facilities and Tank Roads s2m s 150 s 1s0 S rso S rso
CYYCs03 Replace Control Eouioment s82 s 82 S82 s82 s82
CYYC506 Facility Cooline / HVAC Replacement Sos s 55 s5s s6s s6s
CYYC507 Landscaoine Reolacement - Svstem Facilities s80 s 1m s1m s1m s 100
CYYCYB Svstem PRV re-builds s60 s 60 s60 s60 s60
cYYC513 VFD Replacement S rso S rso 5 rso S rso S rso
CYYC514
EWC Production Roll-up
Sam Scm Snm Sam
CYYDgOl Master Meter New/Re placement Soo s 60 Seo Seo Seo
CYYJlol lT Equipment Szs s 75 Szs Szs Szs
CYYJlO4 Power Monitoring S+s s 43
CYYJ5Ol Replace l&C Equipment S rao S rao S rso S rso S rso
CYYJ5O5 Reolace SCADA Eouioment Sss s 59 ss9 Ss9 Ss9
CYYKOOl Safetv/Securitv Uoerades s1m s 90 s90 s90 s90
CYYKOO2 Hvdraulic Model Updates / UDF Plans Sso s 50 ss0 Sso Sso
CYYK5Ol New and Replacement Tools s1m s 100 s 100 s1m s1m
TOTAL s 4.s24 s 4.302 s 4.m9 S 4.rmg s 4.009
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Table 2 - Larser Rehab Proiects for Pumoins, Storase, Suoplv, and Operations Facilities
Proiect lD Proiect Title Need Reolacement Year Budret Amount
8.3 Steelhead Tank Eooster UDgrades
lmproved pumping for max day
and p€ak hour conditions nB-2U7 s 1.ff0,1m
B.9 Brumback & Somerset Heichts Booster Uosrades
lmproved pumping capacity for
max dav conditions 2025 s s76.2@
8.10 Old Pen Booster Upsrades
Doesn't meet regulatory
reouirement of no redundano 2025 s tA7.s(Il
8.12 Federal Eooster UDcrades
lmproved pumping capacity to
meetfire demand nB-2027 s &)5,1m
8.13 Five Mile Booster Uoprades
lmproved pumping capacity to
meetfire demand 2023-2027 s 688.700
c21E510 Hillcrest Tank Reolacement
Steel tank is 75 years old and can
no longer be repaired and
recoated.2023 s 3.32.(m
c21C514 Ustick Booster UpSrades
lmproved pumpingfor max day
and oeak hourconditions 2023 S 1.110.m
c22Afi7
Marden waterTreatment Plant Collector 3
Uocrade
Collector that provides water
from Boise River to Marden
treatment plant is losing
caDacitv 2024 s 150.m
c22Cs11 Reolace La Granqe Well Buildinr, Motor, vFD
Olderwell needs motor
replaced and building brought
uo to code 2024 s 8so.m
c23As02 Franklin Park Well Rehab
Older well that need
rehabilitation to improve
production to meet water
demands 2024 s 250,m
c234503 Kirkwood WellRehab
Older well that need
rehabilitation to improve
production to meet water
demands 2024 s 250.(m
C22ESO2 ustick Tank Rehabilitation
Corrosion issues in support
beams causins structural issues 2023 s 2s0.(m
c22E5D7 Hidden Hollow Tank Rehabilitation
Corrosion issues in support
beams causinr structural issues zoz3 s 10.(m
c2rtA104 27th Street Well Replacement
Well is not housed indoors and
cannot be used through the
winter 2025 S 2,1m,m
c24A707 ReDlace Clinton Well
Existing well has poor water
oualiw 2025 s 1.9s0.m0
c24C511 Replace Old Penitentiary Booster
Replace to meet max day and
oeak demands 2025 s 8(n(m
c25A102 Reolace Maole Hills Wells
Existingwell has poor water
oualiw 2025 s z1m.m
c25A501 Westmorland Well Rehab
Existingwell does not meet
current demands 2025 s s00.m0
c25BSO8 Bali Hai Treatment Tank Rehab
Existing tank has internal
corrosion issues 2025 s u0.(m
c258507
Marden Water Treatment Plant Filter Flow
UDsrade
Existing filters short circuit
reducins treatment efficiencv 2025 s s00.m
c25CvX)Reolace Sunview Booster
Existi ng booster is u nderground
causine safetv issues 202s s 62s.(m
c25E501 Hulls Gulch Tank Floor Corrosion
Existing tank has internal
corrosron lssues 2025 s 758.(m
c25E92 Toluka Tank Reolacement
Existing tank has internal
corro5ron rssue5 2026 s 2.0so.m
TOTAL s 20.337.vn
YEO-W-22-02
IPUC DR 50
Page 3 of3
vEoLIA WATER IDAHO, INC.
CASE VEO-W-22-02
TIIIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper/Cagle
REOUEST NO.51:
Please describe any investments the Company has made over the last five years to reduce
and minimize replacement and/or rehabilitation costs.
RESPONSE NO. 51:
The company engages in maintenance and inspection programs to reduce replacement costs
on a variety of its assets including major infrastructure such as tanks, pumps, and buildings.
The Company routinely performs tank maintenance and painting on our existing tanks.
Maintenance activities include inspections of the inside and outside of the tanks to find cracks
and/or leaks, cleaning of the interior and exterior of the tanks, and lastly structural and safety
repairs to keep the tanks in regulatory compliance. The company maintains a painting schedule for
the tanks that considers the last time the tank was painted as well as inspection results so that tanks
are appropriately scheduled for repainting, protecting metal parts of the tank from rust and
corrosion.
The Company uses vibration and thermography analysis on its major pumps to determine
the health of the pump and whether maintenance needs to be performed on the pump. The
Company can then make plans to have the pump repaired before a pump failure saving cost and
time. The Company has recently invested in real-time pump vibration sensors to pilot the
usefulness in predicting pump maintenance needs. These technologies are becoming widely
accepted and used as a predictive maintenance tool.
vBo-w-22-02
IPUC DR 51
Page I of2
The Company performs weekly inspections of its buildings, pumps, and tanks in the
system. Observations of needed repairs are noted, and the Company invests in repairs as needed
to maintain the infrastructure and its useful life. Common repairs on buildings are siding, roof
repairs, grounds maintenance, and driveways or access roads.
The Company performed a pilot test in 2021 to rehabilitate 19 miles of existing water main
using ice pigging that was known to cause discolored water in the bench area. Ice pigging uses an
ice slurry to scour the water main and dislodge sediment and scale that forms on the walls of
distribution pipe over time. The project was presented to the Idaho Public Utilities Commission
(PUC) upon completion and monthly updates have been presented to the IPUC Task Force
overseeing water quality concerns on Boise's East First Bench. Thus far, the project has showed
a reduction in discolored water complaints from the area's residents.
YE,O-W-22-02
IPUC DR 5I
Page2 of2
vEoLrA WATER rDAnO, rNC. CASE VEO-W-22-02
THrRD PRODUCTTON REQUEST OF THE COMIITSSTON STArr'
Preparer/Sponsoring Witness: Cagle
REOUEST NO.52:
Please demonstrate how Operation and Maintenance ("O&M') costs will change if the DSIC is
approved.
RESPONSE NO.52:
Generally, O&M costs will not be impacted in a systematic manner. Systematic replacement of
aging infrastructure will prevent more costly unplanned replacements and/or repairs in the event
of a break.
wo-w-22-02
IPUC DR 52
Page I ofl
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMNtrSSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST 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.
RESPONSE NO.53:
Please see the attachment to this data request. Customer payment convenience fees are no
longer deferred to General Ledger Account 18699- Other Regulatory Assets as of conclusion of
the2020 general rate case in May 2021. Those costs are now included as part of operating
expenses reflected in General Ledger Account 50400- Outside Services Cost Element 641045 E-
Payment Convenience Fees.
The only deferred balance transactions posting are for monthly amortization per the
Commission's Order.
vBo-w-22-02
IPUC DR 53
Page I of I
YEOLIA WATER IDAHO, INC.
cAsE vEo-w-22-02
THrRD PRODUCTTON REQUEST OF TrrE COMMTSSTON STAIT'
Preparer/Sponsoring Witness: C. Cooper
REOUEST 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.
RESPONSE NO.55:
The Company has 16 approved pipeline contractors. Out of these 16 contractors, 3 have
annual service contracts. The annual service contracts include competitive pricing for pipelines
up to 16" diameter, and blanket project items such as fire hydrants and services.
Most blanket type items, including fire hydrants, are installed under the annual services
contracts with the most work going to the contractor with the least cost pricing. Main projects are
either competitively bid, following company procurement policy, and the lowest overall cost
contractor selected, or the annual service contract pricing is used ifit is expected to be good pricing
for a project.
YEO-W-22-02
IPUC DR 55
Page I ofl
vEoLrA WATER IDAHO, INC.
cAsE vEo-w-22-02
TrrrRD PRoDUCTTON REQIIEST OF TIm COMMTSSION STAIT'
Preparer/Sponsoring Witness: C. Cooper
REOUEST 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.
RESPONSE NO.56:
As described in Response No. 55, competitive pricing is used for the installation of these
assets to ensure that they are completed at the least cost to the Company's ratepayers. Either
annual services contract pricing is used or a competitive individual bid specific to a project.
YE;O-W-22-02
IPUC DR56
Page I ofl
vEoLIA WATER IDAHO, INC. CASE YEO-W-22-02
THIRD PRODUCTTON REQITEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REOUEST 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 and/or annual costs.
Please also state the average cost per delivered gallon for the resource.
RESPONSE NO. 60:
The only potential contractual limitation for utilizing the Company's water resources are
for those sources that have water rights with volumetric limitations on them. Typically water rights
that have been transferred from irrigation to municipal use through the Idaho Departrnent of Water
Resources process have volume limits. Not many of the Company's groundwater rights have
volumetric limitations. Many of the surface water rights have volumetric limitations because they
were historically used for irrigation. The Company has an extensive surface water right portfolio
to support pumping throughout the year as needed. See response to Data Request 88 for purchased
water details. For 2021, the purchased water expense was $276,467 providing available surface
water resources to the Marden and Columbia Treatment Plants to produce 4.216 billion gallons
which results in a cost per gallon of $0.0000655.
vEo-w-22-02
IPUC DR 60
Page I of I
vEoLIA WATER IDAIIO, INC. CASE VEO-W-22-02
THrRD PRODUCTION REQTTEST OF THE COMMTSSTON STAFr'
Preparer/Sponsoring Witness :cary
REOTIEST 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 4Yo pay change over 2022. Please include any and all studies
used to justifu the 4% wage adjustrnent.
RESPONSE NO.67:
Veolia engaged Gallagher Consulting to perform a comprehensive compensation study which
was provided in response to Request No 23. The Gallagher analysis and benchmarking survey concluded
that2022 wages increased an average of 4olo nationwide, please see Attachment I for a supplemental
compensation study slide provided by Gallager. In order for Veolia's wages to "meet" the market, the
overall wage adjustment should be at least 4Yobased on the compensation statery employed.
Additionally, the Company's 2023 budgeted wage adjustmentis 4o/o consistent with the analysis.
The Gallagher study provided in response to Request No 23 demonstrated that the overall average
Veolia base wage compared to 50% of market, is9.2l% below that benchmark, and total compensation
compared to 50Yo of market is 4.44% below that benchmark.
vBo-w-22-02
IPUC DR 67
Page I of 1
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST 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.
RESPONSE NO. 68:
The opex payroll to gross payroll percentage is calculated by taking gross payroll
accounts 50100 + 50105+ 501 l0 + 501 15 + 50120 + 50125 and dividing that total by net opex
payroll accounts 50100 + 50105 +501 l0 + 501 15.
For the Test Year ending June2022, those amounts were:
$6,672,27 6.67 / $ I 0,083,342.59 = 66.17%o
Net Opex Labor:
50100 - Supervisory labor
50105 - Direct labor
501l0 - Supervisory labor transferred in
501 l5 - Direct Labor transferred in
50120 - Supervisory labor trans out
50125 - Direct labor transferred out
Gross Labor:
50100 - Supervisory labor
50105 - Direct labor
501 l0 - Supervisory labor transferred in
50115 - Direct Labor transferred in
$10,083,342.59
Labor Transferred (predominantly to capital projects):
50120 - Supervisory labor trans out
50125 - Direct labor transferred out
$4,480,919.34
5,575,765.55
16,254.94
10,402.76
(2,115,937.68)
(r.29s.128.24)
$6,672,276.67
$4,480,919.34
5,575,765.55
16,254.94
t0.402.76
$(2,115,937.68)
I 128.24
vBo-w-22-02
IPUC DR 68
Page 1 ofl
$(3,411,065.92)
VEOLIA WATER IDAIIO,INC. CASE VEO-W.22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness : Cary
REOUEST NO.72:
With reference to Adjustment No. 2 - Workers Compensation on page 8 of Company
witness Cary's Direct Testimony, please provide the supporting documentation and workpapers
for the adjustment, including the inputs for the three-year average of workers compensation.
RESPONSE NO.72:
Workpapers and supporting information including journal entries for workers
compensation expenses were provided in response to Request No 63.
The "as filed" version of the workers compensation adjustment and an updated revised schedule
for the Adjustment for Worker's Compensation expense, including three years of expense
journal entries are included in Attachment I to this request.
The workers compensation adjustment originally filed has been updated to reflect a correct
and lower historic test year expense by correcting the excluded reserve number, which had
inadvertently excluded injuries and damages amounts from the June 2022 test year. The expense
and reserve amounts for 2019 to 2021 were reflected correctly.
The injuries and damages reserve entry represents actual claims paid and accruals for
claims filed but not yet paid, therefore those transactions should be included as part of worker's
compensation expense.
IBNR (Incurred but not reported) reserves journals represent unpaid claims estimates and
are excluded for rate making purposes.
YEO-W-22-02
IPUC DR 72
Page 1 of I
YEOLIA WATER IDAHO, INC. CASE VEO-W-22.02
THIRD PRODUCTTON REQUEST OF TIIE COMMISSION STAIT'
Preparer/Sponsoring Witness: Cary
REOUEST 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.
RESPONSE NO.75:
Please see the attachment which includes healthcare costs as filed and revised 2023 health
care costs with updated schedules for Adjustment 5 - Healthcare.
This information is reflected in Request No 63 Attachment 3 Exhibit l0 Revised Opex
Adjustments.
wo-w-22-02
IPUC DR 75
Page I ofl
vEoLIA WATER IDArIO,INC. CASE YEO-W-22-02
THIRD PRODUCTION OF TIIE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST NO.76:
With reference to Adjustment No. 8 - Payroll Overheads on page l0 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.
RESPONSE NO.76:
Please see Attachment 1 for an overview of the fringe benefit allocation method and
example of the calculation using June 2018 data.
The fringe benefit allocation amount in account 90950 for June 2018 is comprised of two
components: l) the $69,275.1I of fringe benefit allocation, and?) $2,460.94 of fringe benefits
for Mechanic labor allocated to account 50645 through the separate vehicle allocation process.
In short, actual fringe benefit costs are allocated proportionately to where labor is coded on a
monthly basis. This methodology and steps of Fringe Benefit Allocation remain unchanged
since 2015.
Frinse benefit related costs (pool) cantured in the following accounts:
70250 Payroll Taxes
91460 Workers compensation
91500 Pension
91550 Post Retirement PBOP
91560 PenslPBOP Deferred
91700 Employee Group Health & Life
91800 Employee 40lK
91850 Other Employee Benefits (tuition)
92056 Amortization of OPEB Costs
vBo-w-22-02
IPUC DR 76
Page I of2
Process Overview:
Step -0- Sets the o/o's for fringe costs @y BtI) to be transferred to Capex, Opex and
Deferred based on PAID payroll for the month (Labor transferred out/Gross Labor)
Step -l- Takes the total fringe costs for the month (By BU) and multiplies those against
the o/o's set in Step -0-, arriving at the total fringe costs transferred to Capex, Opex and Deferred
Step -2- Applies the fringe costs calculated in Step -l- to Capex projects based on PAID
payroll for the month (Offset 90950000)
Step -3- Applies the fringe costs calculated in Step -l- to Opex projects based on PAID
payroll for the month (Offset 90950000)
Step -4- Applies the fringe costs calculated in Step -l- to Deferred projects based on PAID
payroll for the month (Offset 90950000)
Step -5- Takes the difference between the fringe costs transferred to (Capex, Opex &
Deferred) and TOTAL fringe costs for the month and spreads them to fringe benefits transferred
(90950xxx) byNARUC, based on PAID payroll
YEO-W-22-02
IPUC DR76
Page2 of2
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMTSSTON STAIT'
Preparer/Sponsoring Witness: Cary
REOUEST NO.77:
With reference to Adjustment No. l0 - Energy - Purchased Power and Other Utilities on
page l0 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.
RESPONSE NO.77:
Please see the attachment which details the other power cost journals and Idaho Power
Company invoice details.
The journal entries for Idaho Power Invoice payments are consolidated into invoice
groups such as well, booster, etc. Eagle Water invoices are separately identified on the Power
TY Data tab in the attachment, but appear on the Power JEs tab grouped generally under wells as
one lump sum monthly payment.
The $32 difference between $157,985 from the supporting documentation ofjournal entry power
expense and Schedule I Other Power total of $157,953 is due to discrepancy in coding between
account 50610 pumping power and 50620 other power $16.74 invoice coding issue, and a small
difference between the journal entry amount from consolidated Idaho Power invoice amounts
and the Company's spreadsheet utilized in itemizing and recalculating individual power charges
by location/site.
For voluminous requests such as numerous invoice copies or similar documentation, the
Company's files and records can be made available for inspection remotely via Google or Teams
scheduled meeting or in-person inspection via a scheduled office appointment at the Company's
Victory office.
vEo-w-22-02
IPUC DR 77
Page I ofl
vEoLrA WATER TDAHO, rNC. CASE VE,O-W-22-02
THrRD PRODUCTTON REQIIEST OF THE COMMTSSTON STAFF
Preparer/Sponsoring Witness: Cary
REOTJEST NO.78:
With reference to Adjustment No. 1l - 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,inExcel fonnat with formulas intact.
RESPONSE NO.78:
Workpapers and supporting information including joumal entries for chemical expenses
were provided in response to Request No 63.
Please see Attachme,nt I for test year ending Jrne2022 chemical journal enties.
vBo-w-22-02
TPUC DR 78
Page 1 of I
vEoLIA WATER IDArrO, rNC. CASE YE,O-W-22-02
THrRD PRODUCTTON REQUEST OF TTTF COMnISSTON STAFF
Preparer/Sponsoring Witness: Cary
REOT]EST NO.79:
With reference to Adjustment No. I I - Chemicals on page 12 of Company wifiress Cary's
Direct Testimony, please provide the source documents supporting the pro forma prices.
RESPONSE NO.79:
The pro forma chemical prices were based on invoice prices available at the time of
filing plus a 60/o cost increase based on vendor anticipated cost escalations. Chemicals for well
maintenance were per the historic test year average price and quantrty with no projected cost
escalation.
vBo-w-22-02
TPUC DR79
Page I ofl
vEoLIA WATER IDAHO, rNC. CASE VEO-W-2!02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witncss: Cary
REOT]EST NO. EO:
With referenoe to Adjustment No. l l - Chemicals on page 12 of Company witness Cary's
Direct Testimony, please provide the source documents for the additional chemicals for the former
Eagle Water service area.
RESPONSE NO.80:
The additional chenricals for the former Eagle Water service anea are calcr{atd as shown
in the Attachm€ilt, based oa planned and actual prurluction levels and chemical feed rates.
vEo-w-22-02
IPUC DR 80
Page 1 of 1
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THrRD PRODUCTTON REQTIEST OF THE COMMTSSION STAFF
Preparer/Sponsoring Witness: C ary
REOUEST NO.85:
With reference to Adjustment No. l7 - 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.
RESPONSE NO.85:
The July l0th first class postage increase from $0.58 to $0.60 or 3.45Yo increase was
applied to the test year level of postage costs of $23,815 resulting in a $821 adjustnent. While
some of mail is metered, the metered rate increase was higher at7.54o/o, the adjustnent reflects
the lower 3.45% rate increase. Please see the Attachment for postage cost increase infonnation.
For the test year, the postage costs included AutoSort metered mail from the Company's
Victory office, Federal Express shipping costs and Options postage for customer mailings. The
$821 adjustnent would equate to 1,369 first class rate leffers at $0.60 each.
vEo-w-22-02
IPUC DR 85
Page 1 of I
vEoLIA WATER IDAHO, INC. CASE VEO-W-22-02
THrRD PRODUCTION REQUEST OF THE COMMTSSION STAFF
Preparer/Sponsoring Witness : Cary
REOUEST NO.86:
With reference to Adjustment No. l7 - 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.
RESPONSE NO.86:
Description of Right Systems maintenance and support fee for the Company's UPS
backup system:
The Right Systems maintenance support fee charges shown on the attached invoice are
for three one-year break-fix support contracts for three separate Company UPS systems. One
each at the Marde,n WTP, Columbia WTP, and the Victory Operations Ce,nter. The unit cost for
each support contract is de,pendent on the power ou@ut capacity and the age of each system.
Please see the Attachment for the Right Systems Invoice.
vBo-w-22-02
IPUC DR 86
Page I of I
vEoLrA WATER rDArrO, INC. CASE VEO-W-22-02
THrRD PRODUCTTON REQTIEST OF Tm COMMTSSTON STAFF
Preparer/Sponsoring Witness: Wilson
REOUEST NO. E9:
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.
RESPONSE NO.89:
See attachment for historical test year transaction details for Account 50605, Purchased
Water
YEO-W-22-02
IPUC DR 89
Page I ofl
YEOLTA WATER TDAHO, rNC. CASE VEO-W-22-02
THIRD PRODUCTION REQTIEST OF TIIE COMMISSION STATT'
Preparer/Sponsoring Witness: Wilson
RBOUEST 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 March 2020 through the historical test year that ended
June 30, 2022, in Excel format with formulas intact.
RESPONSE NO.90:
See attachment for transaction details from March 2020 thru June 30, 2022. Please note
there is a.tab for each account requested.
vEo-w-22-02
IPUC DR 90
Page I ofl
yEoLrA WATER rDArrO, rNC. CASE VEO-W-22-02
THIRD PRODUCTION OF THE COMMISSION STATT'
Preparer/Sponsoring Witness : Wilson
REOUEST NO. 91:
With reference to Adjustment l5-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.
RESPONSE NO.91:
See attachment for transaction details for the historical test year before the corrections
listed in testimony.
YEO-W-22-02
IPUC DR9I
Page I ofl
vEoLrA WATER IDATIO, INC. CASE WO-W-22-02
TrrrRD PRODUCTION REQUEST OF TrrE COMMTSSION STAIT'
Preparer/Sponsoring Witness: Wilson
REOUEST 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.
RESPONSE NO.94:
The Company does not have an official vehicle replacement policy. However, our lease
management company, Element Fleet Management Co.p., provides an "Optimal Replacement
Planning Summary". This document is an analysis of our current fleet with recommendations on
optimal replacement planning. The latest assessment from June 2022 isattached.
lfEo-w-22-02
IPUC DR94
Page I of I
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
TrrrRD PRODUCTION REQIIEST OF THE COMMTSSION STAFF
Preparer/Sponsoring Witness: Wilson
REOUEST 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.
RESPONSE NO.95:
The projected fuel prices were established using the September lst, 2022 AAA Fuel Price
Chart (https://gasprices.aaa.com/). The Company used the Boise City "Current Avg." on that date.
See chart on page 2 under Boise City.
Fuel Consumption Calculation (see Attachment for further details)
5,813 gallons - Monthly average of total fuel usage YTD August2022
69,756 gallons - Forecasted 2022 total fuel usage (5,813 monthly avg x l2)
73,593 gallons - Projected Test Year total fuel usage using 69,756 gallons plus 5.5% (5.5%
is the forecasted increase in usage based on the percent increase from202l fuel usage total
to 2022 forecasted total. The Company has additional vehicles for head count increases and
expanded territory with the acquisition of Eagle Water Co. and continued customer growth
system wide.)
52761614 - 59,169 regular fuel gallons x $4.675 (average AAA regular fuel price per chart
on page 2) (59,169 gallons : 73,593 Test Year projected gallons x 80.4o/o, which is the
allocation percent of the August YTD fuel usage split betrveen regular and diesel)
574,876 - 14,424 diesel fuel gallons x $5.191 (average AAA diesel fuel price per chart on
page 2) (14,424 gallons :73,593 Test Year projected gallons x 19.60/o, which is the
allocation percent of the August YTD fuel usage split between regular and diesel)
$351,490 - Total Test Year projected fuel costs
vEo-w-22-02
IPUC DR 95
Page I of2
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15. a9,
lo 785
NEWS Drivers Find Relbf at the Pump, For Nor R..<,,*! D
IDAHO AVTRAGT GAS PRICTSO
}TGHEST RFCORDED AVERAGE PRCE
II)AHO MTIRO AVTRAGT PRICTSO
Eryand all I Cotlapee alt
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34.20'
wo-w-22-02
IPUC DR 95
Page2 of2
; [:r'.r -1,
8.grtar(rrad
h
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yEoLIA WATER IDAHO, INC. CASE VE,O-W-22-02
TIIIRD PRODUCTION OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REOTIEST 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.
RESPONSE NO.97:
Please see attached for cost-benefit analysis on leasing versus owning our fleet vehicles.
vBo-w-22-02
IPUC DR 97
Page 1 of I
YEOLIA WATER IDAHO, INC. CASE VEO.W-22-02
TErRD PRODUCTTON REQT EST OF TrrE COMMSSTON STATT',
Preparer/Sponsoring Witness: Wilson
RBOTIEST NO.99:
With reference to Adjustment 18 - 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.
RESPONSE NO.99:
See attachment for the transaction detail report for Account 50651 for the historical test
year ended June 30, 2022.
wo-w-22-02
IPUC DR99
Page I ofl
YEOLIA WATER IDAHO,INC. CASE YEO-W-22-02
TIIIRD PRODUCTION REQTIEST OF TIIE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson
REOUEST NO. 1OO:
With reference to Adjustment l8 - 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.
RESPONSE NO. lOO:
a. The ldaho Public Utility Commission requires customers be notified their annual Consumer
Confidence Report (CCR) is available to them. We currently notifo customers via a mailed
postcard letting them know how to find their CCR on our website. After analyzing the click rate
on the ldaho CCR web page the past two years, we determined less than 0.5% of our customers
are landing on the page. The Company strongly feels the CCR is an important document for
customers to review and understand what is in their water; hence, for the 2023 notification of the
2022 CCR, we intend to mail it to all customers. This type of push notification will land the CCR
in customers' hands directly, versus customers having to go to our website to look it up.
b. We have not mailed the CCR to customers yet. When we mail the 2022 CCR in 2023, we will
track any calls or emails that come in from customers regardirrg the mailing.
c. Regarding the regulatory requirernent. There is no requirement the CCR be sent out hard copy.
The requirement is that the CCR must be made publicly available and advertised, and all
customers notified of its availability by July I st every year.
d. We will track customer feedback after we mail the 2022 CCRin2023.
YEO-W-22-02
IPUC DR 47
Page I of I
yEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THrRD PRODUCTTON REQUEST OF Tm COMMISSION STAIT'
Preparer/Sponsoring Witress: Wilson
REOUEST NO. 101:
With reference to Adjustment l8 - 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.
RESPONSE NO. 101:
Customers who receive a digital bill do receive a message prompting them to read the
CCR. The bill message states, for example, "Your 2021 CCR (Water Quality) Report is now
available at mywater.veolia.us/lDCCR202 I."
YEO-W-22-02
IPUC DR IOI
Page I ofl
vEoLIA WATER TDAHO, INC. CASE yEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witress: Njuguna
REOUEST 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.
RESPONSE NO. 102:
Please see below actual rate case expenses incurred through November 30,2022.
LineNo.Expense Description Amount
1 Outside Legal Counsel $ 9.680
2 Rate of Return Study $ l1.867
3 Load Studv & Cost of Service Study $ 60,425
4 Customer Notices, Public Information Campaim $ 43,291
5 Total $125,264
wo-w-22-02
IPUC DR IO2
Page I ofl
\rEoLIA WATER IDAEO, INC. CASE VEGW-22{2
THIRD PRODUCTION REQUEST OF Tm COMMISSTON STAFf
Frcparer/SponsoringWitress: Cary
REOTIEST NO. IM:
Please provide a copy of the Company credit card and purchase card policy.
RESPONSE NO. 104:
Please s€e the Attachment for the Company's purohasing card policy.
wo-w-2242
IPUCDR IO4
Page I of I
vEoLIA WATER IDAIIO, INC. CASE VEO-W-22-02
THIRD PRODUCTION REQIIEST OF TIIE COMIVISSION STAIT'
Preparer/Sponsoring Witness: Cary
REOUEST 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 - Office 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 - Other G&A Exp.
RESPONSE NO. IO5:
Please see the attachment for the Test Year ending June 2022 journal entries for accounts
50650, 50655,91860, 92300 and 92600.
YEO-W-22-02
IPUC DR I05
Page I ofl
vEoLIA WATER IDAIIO, INC. CASE VEO-W-22-02
TrrrRD PRoDUCTTON REQUEST OF TIIE COMMISSION STAIT'
Preparer/Sponsoring Witness: Cary
REOUEST NO. 1O?.
Please provide a list of all workman's compensation insurance claims that Veolia paid for
the test year.
RESPONSE NO. 107:
Please see attached file.
Please note adjustment No. 2 Workers Compensation REVISED tab corrected the Historic
Test Year Expense reserve exclusion amount from $203,439 to $174,147. The revised schedule is
included in the Attachmenl Rather than excluding the IBNR reserve entries, the adjustment also
excluded injuries & damage reserves, which should be included in costs.
vEo-w-22-02
IPUC DR 107
Page I ofl
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST NO. 108:
Please answer the following for the l5 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?
RESPONSE NO. IO8:
a. No positions added due to customer growth and increasing work demands will not
mitigate overtime.
b. Please refer to the response to Request No 65 below that addressed why these
positions are needed by the company, how they benefit customers and the services that will
be provided by these positions.
Position
Operator
Operator I
Operator I
Crew Chief
Cross Conn Control
Specialist
Vacant /
Filled
Filled
I Filled
Planned Ql
2023
Position Need
Increased
regulatory
requirements
and system
growth
Position
Backfill
Position
Backfill
Benefit to Customerc
Focused resource on copper and lead sampling
Field maintenance and operation of treatment plants,
wells, and other water facilities with oversight of
Operators work
Field maintenance and operation of treatment plants,
wells, and other water facilities with oversight of
Operators work
Field maintenance and repair with oversight of Utility
Person I and Utility Person work
Oversight and compliance for Company Cross
Connection Control program
Field maintenance and repair work
YEO-W-22-02
IPUC DR IO8
Page I of2
Utility Person Filled
Filled
Planned Ql
2023
Position
Backfill
System growth
and work
demands
Position
Backfill
Position
Backfill
Utility Person Filled Field maintenance and repair work
Position
Vacant/
EUE Positlon Need Benelit to Customerg
Utility Person Filled Position
Backfill
Field maintenance and repairwork
Utilit), Person Planned Ql
2023
Position
Backfill
Field maintenance and repair work
Customer Service
Person (fielO
Filled System growttr
and work
demands
Field customer senice leak investigations, turn on/off
services and notifications
Customer Service
Rep I
Filled Position
Bacldll
Call center representation to customer bi[ing
arrangements and field service requests
Operarions Lead CSR Filled System growth
and work
demands
Operational commrmications between field personnel
and customers, routing critical customer field visit
needs such as water quality, main breah leala etc.
Bxecutive Assistant Filled Position
Bacldll
Oversight of program developmenf maoagement
and rollout, general administrative support to general
administation Sr Leadership team
Env Health & Safety
Specialist
Plannd Ql
2023
Position
Backfill
Oversight and compliance for OSHA, DBq NFPA,
and other regulatory health and safely progrzuns
Communications
Specialist
Filled Position
Backfill
Community outreaclr, water conservation and other
stakeholder engagement programs
I/F,o.w-2242
IPUC DR IO8
Page2of 2
vEoLIA WATER IDAHO, INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMTSSION STAFF
Preparer/Sponsoring Witness: Cary
REOTIEST NO.11O:
Please provide copies of the Health, Vision, and Dental lnsurance Plans Veolia provided
to its employees, with cost breakdowns for employee, spouse, and family.
RESPONSE NO. 110:
Please see Attachment I through Attachment 5 for the Company's healthcare plans and
Attachment 6 for cost breakdown for 2023 for employee, employee plus children, employee plus
spouse and family plan coverage level costs.
YEO-W-22-02
TPUC DR IIO
Page I of I
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST 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?
RESPONSE NO. 1I1:
a. Payroll is processed every two weeks, a bi-weekly payroll. Exempt (salaried) employees
enter their time directly into PeopleSoft. Non-exempt (hourly employees) track time on timesheets
with the majority of Bargaining Unit employees also recording their time in the Cityworks work
management system. Supervisors and Managers review and approve timesheets for the
department's non-exempt employees. The Finance department timekeeper enters time into
PeopleSoft for non-exempt employees.
Non-exempt (hourly) time entry process:
After timesheets are reviewed by supervisors they are uploaded onto the Google drive.
After a predetermined cutoff time the timekeeper saves timesheets to adobe files to an
internal folder. Time is then entered into Peoplesoft by the timekeeper.
Once all time entry is complete for each department an email is sent to the supervisors to
clear up any outstanding issues or questions there may have been with time entry. Using the email
as backup the timekeeper then makes any necessary corrections or adjustments to timesheets.
A follow up email is sent to the supervisors and managers confirming payroll time entry is
complete.
A query is ran showing all employees that have time entered into the system. The
timekeeper compares that report to a list of employees for the site. If any timesheets are missing,
an email is sent requesting entry either be completed or a timesheet submitted. When the report
shows all time is complete, a system report if printed and time entry is reviewed and approved by
the Manager Financial Planning Reporting and Analysis.
When payroll is reviewed and documents signed off, system payroll reports are generated
vEo-w-22-02
IPUC DR 1I I
Page I of2
and sent to the payrotl depar,tnent at tho corporato oftice indioating any tmusuel eircumstances
such as time worked lcss than standard hours, etc.
b. Tracking:
Employees tr:ack their time on a timeshoet that is submitted to their supervisor for approval.
Some Transmission & Distribution employees and Production deparfinent employees algo use
Cityworks to fiack their time and then manually enter time onto a timesheet for Supervisor or
Manager review and approval. Time is enterpd by the employee direotly into PeopleSoft for
salaried employees and by the timekeeper for hourly employees after supervisor approval.
vBo-w-2242
IPUC DR IIl
Page2of 2
vEoLrA WATER rDAIrO, rNC. CASE VEO-W-22-02
TTTIRD PRODUCTION REQUEST OF Trm COMMTSSTON STAIT'
Preparer/Sponsoring Witness: Cary
REOUEST NO. 1I3:
Please provide all business insurance claims affecting liability and property coverage for the
test year.
RESPONSE NO. 1I3:
Please see the Attachment for test year business insurance joumal entries. Claims payments
are included in GL account 26200 as AP journal entries.
Adjustment No. 20 General Insurance inconectly excluded tnjuries and Damages reserve
entries. The Attachment also includes a corrected schedule with revises the Test Year Expense
reserve exclusion amounts from ($692,966) to ($285,194) for year 2020, from $204,020 to $49,992
for 2021, and Historic Test Year amount of reserve exclusion from $226,899 to $46,500. This
schedule correction was also included in response to Request No 63.
YEO-W-22-02
IPUC DR I13
Page I ofl
vEoLIA WATER IDAIIO,INC. CASE VE,O-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMTSSION STAFF
Preparer/Sponsoring Witness: Wilson
REOUEST NO. 114:
Please provide an itemized list of all necessary training and safety- related costs for the
test year for each of the following:
a. Uniform costs, Arc Flash personal protective equipment (PPE) rental costs, fire suppression
system inspections/alarm 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.
RESPONSE NO. 1I4:
Please see response to Request No 87 which contains the test year amounts, included in
the Attachment to this response and below.
Safety Cost Category Historic Test year Ending JaneZ1ZZ
Unitbrms $ 20,477
Hearing Test - Required S 1,340
Arc Flash PPE Rental $ IZ,g43
EPA/NESHAP/OSHA Asbestos Training (every 2 years) $ 10,79g
Xit"_lptt..:tql,!If{em Inspections, Alarmmonitoring $ 18,874(Kegulatory requreo)
First Aid/CPR/AED Training Certitication Required
OSHA 500 Standards - Trainer Course
Multimeter testing, Test PPE gloves
N oise h,xposure Monitoring
Job demand analysis
lndustrial Hygienist - Respuato.r/chemical program
assessments- exposure morutonng
Sat'etv eouinment (Sat'etv Toe Boots & Pacs. Hard Hats.
PPE,'saGty signs, de-icei, includes Covid exirenses)
TOTAL 154,824
vEo-w-22-02
IPUC DR I14
Page I of I
$
$
$
$
$
$
1,281
775
r,075
4,675
200
7,250
$ 7s.137
$
yEoLIA WATER IDAHO, INC.
CASE VEO.W.22.O2
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: C. Cooper
REOUEST 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.
RESPONSE NO. 115:
This is a roll-up project, Safety and Security Upgrades. The project was initially approved
for up to $150,000 in costs. The forecast in July was for $125,000 ($140,400 including overheads)
in project spend, which is what was included in the pro forma amount. The PPM approval is
shown below.
Approval History
Approval Process UW_PRJ_BUG_APPROVAL
Business Unit 00060
Budget Approver
Defin.tion ID U\ry-PRJ_BUG-APPR_EXE
Project C22K001_060
v Profcc{Ac$Yity Approval:Approvcd @uewnrioe cornmenb
Afgateppqtcr
[ppi"i*i ___
Cathy Cooper
^ LEVEL tv tr,frvn-6-rl Pu
l Comments) Commeril Hlstory
r rApprqyqL --------- i L4rptgygC-- -- li_--ri MarshallThompson i*5 McEvoy.PaulaL ;t ' ^ IEVEL2 rLE\lEL3 ,v W-1:1.3Qlr, , ,Y t2Nl?l-6:Q7AMr
vEo-w-22-02
IPUC DR I I5
Page I of2
The projects in the safety and security upgrade pdect are proposed by Environmental Health &
Safety personnel and/or field crews, and completed by the Project Manager. Projects included in
the 2022 Safety and Security Upgrades project included:
C22K00 l_060_002 Gas Monitoring Equipment ($6033.74)
C22K00l_060_004 Cart Cutting Torch (not completed yet - actuals not available)
C22K00l_060_005 Columbia ladder (not completed yet - actuals not available)
C22K00 l_060_006 Fire Extinguishers ($38,428. I 5)
C22K00l_060_007 Fence at Market Well ($3,781.63)
C22K00l_060_008 Fence at Chamberlain Wells ($16,574.71)
C22K00 l_060_009 Fall Protection ($22,536.9 t )
C22K00 I _060_0 I 0 Monitors ($2,29 4.04)
Total to date: $89,649.18
vBo-w-22-02
IPUCDR 1I5
Page? of2
YEOLIA WATERIDAHO,INC.
cAsE vEo-w-22-02
TrrrRD PRODUCTTON REQUEST OF TIIE COMMTSSION STAIT'
Preparer/Sponsoring Witness :
REOUEST NO. 116:
Please provide the Company's policy for purchasing and retiring fleet vehicles.
RESPONSE NO. 116:
Please see attached policy with regards to purchasing and retiring fleet vehicles.
Cooper
vBo-w-22-02
IPUCDR I16
Page 1 of I
vEoLIA WATER IDAIIO, INC.
CASE VEO-W-22-02
THrRD PRODUCTTON REQUEST OF THE COMMISSTON STAFF
Preparer/Sponsoring Witness: C. Cooper
REOUEST NO. 117:
Please explain and provide supporting documentation for the "File Relocation plan"
found on the list of pro forma projects. Please include any cost benefit analyses and approvals
for the project.
RESPONSE NO. I17:
The frle relocation plan project developed a naming convention for scanning paper files to
electronic files, and then scanned the paper engineering files going back to 1969 into a searchable
electronic format. The scanning was done for several reasons - l) the paper files take up a lot of
space and are heavy, 2) in preparation for our upcoming office remodel, these filing cabinets
needed to be removed, 3) with the onset of more remote work, paper files in the oflice were
difficult for employees to access and search, 4) the paper was becoming aged and brittle, and
scaruring the papers preserved these important facility documents.
The project was approved as part of the Victory Offrce Phase I Remodel. Project approvals
are affached.
YEO-W-22-02
IPUC DR 1I7
Page 1 ofl
A
yEoLIA WATER IDAHO, INC.
CASE YEO.W-22.02
THIRD PRODUCTION REQI]EST OF THE', COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
REOUEST 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.
RESPONSE NO. I18:
The computer refresh project purchased a new computer for every Veolia Water Idaho
employee. The previous computers were 5* years old and needed replacement. The project
approval from Peoplesoft is provided below.
PmFcrA.ttm. 9st ourl
Prolrt C2t.t553-O6O'
.eece E E
Prqlcc-t Ac{vld.!
i sctr.dth Uor.o.tr o"tG U$FEI(b
ia3 D Xdrlyxe
t Errqr!_CfiedrRoict
adgctApprovcr
- Pnd.cfA.dul0ADelDvirADproir.d
irt.fFrr.
'iforirili ,Aolmd-: m*o r**p,rlttritri )v wM.-f:eN J arwz2-r{lN; c t.ril.I Cocmrnil[rtory
OaerlDd@ Cdrrutd R.trsh
€ lulberRm
lfuorud
Pl@3dng 3i116 A!tv.
tI. erp"no
Ctrlltno l-rwl C6lirg Lfist !
R[ b Excd
l0.r.)
9\ikil[ccmirr
AlStffi
foil(}dt
Oa C2lJ553-060-lIl1
.mh 'Ed o.t
6t tdznszozt 6 tznnozz B
YEO-W-22-02
IPUC DR II8
Page I ofl
h
C
il$td nE(9s0
^ r.e\/ll!17 w.t:s*
llaiiolJr l-*855fi6Edftfidf-'1 -mm1, wtw;afn
ADrud
---EErcr.FeELr l.E\iEl, utzz..JaN
vEoLrA waTER IDAHO, rNC.
cAsE vDo-w.22-02
TEIRD PRODUCTION REQTIEST OTTHE COMMISSION STAXT
Preparer/Sponsoring Witnees: Njuguna
REOTIEST NO. 119:
Please provide updated aotual plant-in-service additions and retirement amormts for July
2A22 through the most reoent period.
RESPONSE NO. 119:
Please se the attachment to this rqponse with aotual plant in serviee additions and
r*iremonts from July 2022 through November 2022.
vEo-w-22-02
IPUC DR 119
Page I ofl
vEoLIA WATER IDAHO, INC.
cAsE vEo-w-22-02
THIRD PRODUCTTON REQITEST OF THE COMMTSSTON STAFF
Preparer/Sponsoring Witress :Wilson
REOUEST NO. 120:
Please provide receipts for the credit card transactions listed in Attachment A, and identi$
where the costs are included in the Application.
RESPONSE NO. 120:
Please see the attachment for details on the requested credit card tansactions and where
the costs are included in the Application. Receipts for each transaction are attached and labeled to
correspond with the Attachment number listed in the Attachment.
vBo-w-22-02
IPUC DR I2O
Page I of 1
vEoLIA WATER IDAHO, INC. CASE VEO-W-22-02
THrRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOTIEST NO. I21:
Please identifr the number of disconnections for non-paynent on a monthly basis for
calendar years 2020,2021, and2022 to date. For comparison, please include the number of
customers for those same time frames, and the number of disconnections as a percentage of total
residential customers for the same time period.
RESPONSE NO. 121:
Please see the Attachment for the number of disconnections for non-payment.
vBo-w-22-02
IPUC DR I2I
Page I of I
yEoLIA WATER IDAHO, INC. CASE VEO-Wa2-02
TIIIRD PRODUCTION REQUEST OF THE COMMISSION STAIT'
Preparer/Sponsoring Witness: Cary
REOUEST 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.
RESPONSE NO. 122:
Veolia Idaho does not generally request a customer deposit. If an applicant for water
service is required to pay a deposit in advance of receiving service, it is due to the applicant
demonstrating red flag wamings i.e. misrepresentation of identity, termination of service, previous
unpaid balance, etc. There is currently only one customer we have a deposit for, with the reasons
listed above as the basis for requiring the deposit.
Customer Deposits are recorded in General Ledger Account 23500 - Customer Deposits,
as of November 30, 2022there is one customer with a deposit of $191.00.
YEO-W-22-02
IPUC DR I22
Page I of I
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST NO. 123:
Please provide the following details for the Company's leak adjustment program by year for 2020,
2021, and2022to date.
a. What are the audit parameters that prompt the Company to send a notice to the customer
because ofhigh 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 notiff the respective waste-water authority of the
adjustment?
RESPONSE NO.123:
a. Audit parameters:
From May I to September 30 an account with lOOccf (ccFl00 cubic feet) more than the
average usage for that account will be sent to the field for a meter reading verification. If the
meter reading is verified as correct and there was not an issue noted at the property, such as a
meter issue or evidence of a visible leak, we will then send the customer a notification of high
usage.
From October I to April 30 an account with 50ccf (ccFl00 cubic feet) more than the average
usage for that account will be sent to the field for a meter reading verification. If the meter
reading is verified as correct and there was not an issue noted at the property, such as a meter
issue or evidence of a visible leak, we will then send the customer a notification of high
usage.
b. Customers that received a leak adjustment:
During 2020 - 353 Accounts,202l - 301 Accounts, and 2022to date - 402 Accounts.
c. Arrangement with wastewater system operators to adjust sewer rates:
We do not have agreements in place with wastewater system operators to adjust sewer rates,
each entity bills customers differently and has different requirements for leak adjustments.
We will refer customers to reach out to their wastewater system operator directly to inform
them of the leak on their account so that the customer's wastewater bill is not impacted by
high consumption due to leaks. Upon a customer's request, we will provide usage history to
the wastewater system operator to aid the customer in applying for a wastewater leak
adjustment.
d. Wastewaterauthority notification:
We do not reach out to the waste-water authority with our adjustment as we do not adjust the
customers actual usage, meter readings or ccf consumption history, but rather provide a
monetary adjustment to the customer's account when the customer qualifies for a leak
adjustment. We advise customers to reach out to their wastewater authority to inquire how
they can apply for a leak adjustment for their wastewater bill.
vBo-w-22-02
IPUC DR I23
Page I of I
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
TrrrRD PRODUCTION REQITEST OF THE COMI{TSSTON STAFF
Preparer/Sponsoring Witness: Cary
REOUEST 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 yearc 2020, 2021, and 2022 to date. How many of those customers were subsequently
disconnected for nonpayment during the following two months?
RESPONSE NO. 124:
Please see the Attachment.
vBo-w-22-02
IPUC DR I24
Page I of 1
vEoLIA WATER TDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTION REQT]EST OF TIIE COMMISSION STATT'
Preparer/Sponsoring Witness: Cary
REOUEST 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.
RESPONSE NO. 125:
Please see the summary below.
Average Monthly Consumption of Customers who received Veolia Cares Financial
Assistance - reflected in Thousand Gallons:
Jan2020
Feb 2020
Mar2020
Apr2020
May 2020
hn 2020
Jul2020
Aug2020
Sep 2020
Oct2020
Nov 2020
Dec2020
lan202l
Feb202l
N4ar202l
Apr202l
May 2021
Jun202l
lul202l
Aug202l
5.73
6.27
4.98
6.39
6.57
I l.l0
I 1.85
16.86
17.01
15.91
9.75
7.69
5.27
6.52
4.39
6.76
6.49
12.00
14.73
19.86
YEO-W-22-02
IPUC DR I25
Page I of2
Sep 2021
oc/"202l
Nov 2021
Deo2021
Ian2022
Feb2022
Mar2022
A,pr2022
May2A22
Il.um2022
lul2022
Aug2022
Sep2022
Oct2022
Nov 2022
tatD022
@artial Month)
r6.95
14.ll
7.76
7.10
5.18
6.29
4.56
6.81
s.32
8.13
10.53
14.08
16.13
15.18
9.87
6.36
YEO;-W-2242
IPUC DR I25
Page2of 2
vEoLIA WATER TDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST NO. 126:
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, and
2022 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.
RESPONSE NO. 126:
As a result of the Company's 2020 Rate Case outcome and subsequent change in rates,
the annual cap of financial assistance available per qualified customer has changed from $75 to
$85 to reflect the overall 8.57% increase in tariff rates. While the Commission Order phased-in
rates over two years, the Company reflected the full increase in the low-income financial
assistance cap right away.
The name of the program also changed from SUEZ Cares to Veolia Cares in2022 as a
result of the rebranding and Company name change. There have been no other changes in the
Company's low-income financial assistance program.
Originally as noted in Order 29838 in case UWI-W-04-4 the assistance amount was set to
$50 per customer annually. In 201I the amount was increased to $65 per UWI-W-ll-02
Settlement. It was raised to $75 in 2016 in UWI-W- I 5-01 Settlement and thereafter would
continue to increase by any subsequent general rate proceeding percentage change awarded. In
2018 as result of the Tax Cuts Job Act which reduced income tax rates, the tariffrates charged to
customers were reduced, however the Company did not reduce the $75 assistance amount.
Please see the Attachment for Veolia Cares Financial assistance provided to customers.
The Company has not received any customer contributions to the program in several
years.
El-Ada has not billed the Company for their administration fee since 2017. The Company
does not have a written agreement on file for the El-Ada Administrative fee, but it was
previously billed as a lloh fee of the amount of financial contributions awarded for the
year. The Company has requested invoices from El-Ada. There is no cost for this service
reflected in the Company's operating costs for this rate filing.
vBo-w-22-02
IPUC DR 126
Page I of I
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
TIIIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST NO. 12'.
Please state whether all costs associated with the Veolia Cares program are covered by
shareholders. Please explain.
RESPONSE NO. 127:
Costs associated with the Veolia Cares program funding are covered by shareholders. The
financial assistance provided to customers is funded by shareholders and recorded in account
71253 Non-recoverable costs, Cost Element 711003. These costs are not included in the
Company's rate request.
Administrative fees from El-Ada for processing customer funding requests have been
included in the Company's operating costs in prior years, but El-Ada has not invoiced the
Company for these services and therefore that cost is not included in this rate filing. The Company
has contacted El-Ada to request regular invoicing for their services.
Internal Company processing costs by the customer service department to inform
customers of financial assistance resources are not separately tracked or allocated to the Veolia
Cares program. Those costs are in the Company's operating costs.
The Company does not deduct costs of implementing or administering the Veolia Cares
program from the funds made available by Veolia for assisting low-income customers. Also, since
2010, the Company does not include costs for specific customer outreach to provide customers
information on how to voluntarily donate to the program. Funding available for the Veolia Cares
program is not reduced by any administrative cost.
There is no Veolia Cares specific customer outreach program, information about Veolia
Cares is promoted in conjunction with other company services and initiatives. These costs are
captured in the Company's operating costs.
vBo-w-22-02
IPUC DR 127
Page I of I
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSTON STAFF
Preparer/Sponsoring Witness: Cary
REOUEST NO. 128:
Please provide the number of incoming calls handled by the customer service representatives
by month for calendar years 2020,2021, and2022 to date. Are all incoming calls handled within the
Boise office? If not, how are incoming calls handled?
RESPONSE NO. 128:
All incoming calls are handled by our Boise office. Majority of the Company's Treasure
Valley CSR's work remotely (from home), not at the Boise office. If a call comes in after hours or
on a company observed holiday, the after hours answering service receives the emergency calls and
sends the appropriate Company resource to investigate.
Reporting Date la",,uo,rr" lnenortins oate lar,,ro,r*" lReportins Date la.,,ro,rr"
YEO-W-22-02
IPUC DR 128
Page I of I
1t2022 4143 1t2021 3669 1t2020 lo.ut
212022 3963 2t2021 3823 2t2020 louuo
312022 4834 3t2021 4171 3t2020 loeas
4t2022 4307 4t2021 4228 412020 loro,
5t2022 4864 5t2021 3845 5t2020 l.aua
6t2022 6078 il2021 4939 6t2020 loaso
712022 6123 7t2021 5036 7t2020 los.,
8t2022 6931 8t2021 5484 8t2020 losso
9t2022 6677 912021 4890 912020
lu,' ',
10t2022 5370 10t2021 4588 10t2020 lu*u
11t2022 4'.t97 11t2021 4516 11t2020 lor.,u
12t2021 3794 lo,o '
12t2020
vEoLIA WATER IDAHO, INC. CASE VEO-W-22-02
THIRD PRODUCTION REQTIEST OX'THE COMMISSION STAFT
Preparer/SponsoringWitness: Cary
REOUEST NO.13O:
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
y ears 2020, 2021, and 2022 to date.
RESPONSE NO. I3O:
The data below shows l) the number of flushing calls and credits applied to customers in the East
First Bench area (EFB), 2) the amount of flushing credits and 3) the total number of discolored water issues
reported.
The total count of issues reported includes discolored water concems reported from customers
including those where customers were advised to flush their water lines and subsequently received a flushing
credit, and other concerns including those related to the annual flushing progftrm, ice pigging, customer
plumbing issues, etc.
Date Count of EFB Discolored water
issues reported with Flushing
Credit based on date credit was
applied
Total Count of EX'B
Discolored water issues based
on date initiated in Cityworks
X'lushing
Credits
Applied
Jm-20
Feb-20
Mar-20
Apr-20
May-20
Jun-20
Jul-20
Aug-20
1.50
1.50
6.00
4.50
2
I
3
4
2
I
I
4
J
$
$
$
$
8
4
7
8
3
2
6
$ 4.s0
s 3.00
s 9.00
wo-w-22-02
IPUC DR I3O
Page I of3
Sep-20
Dato
Oct-20
DEf,-zo
Jan-21
Countof EFB Dlscolorcd wator
lssues tcrorted with Flushins
Credit biscd on date crrcdit fres
applied
Total Count of EFB
I)lrcolored wetcr hsucs bssed
on dete initiatod tn Cltynorla
Ftushing
Creditu
Apptied
I
6
2
9
s
5 $ 7.s0
1.50
$ 1.50
$ 3.00
$ 1.50
$ 1.50
$ 4.s0
$ 33.00
$ 12.00
Feb-21
I\.{arrl
Apr-21
May-21
Jun-21
Jul-21
Aug-21
Sep-21
otr'.-21
Nsv-21
Dee-21
Feb-22
1
2
I 2
5
5
4
6
4
5
30
t6
5
3
22
8
Apr-22 I
I
vBo-w-2242
IPUCDR 130
Page2of 3
May-22
Date
hmAz
lul-22
Ang22
Sep22
Oct-22
TOTAL
Count of EBB l)'iscolored weter
isruer reoorted with Flushine
Credit bfued on detecrcditfras
sppliod
Total Count of EfB
Illscolored watcr bsu€o basod
on detetnifirtcd in Cityro*s
Flushing
Crcdits
Applied
4
3
II$ 1.50
$ l.s0
$ 99.00 152
2
1
I
ffi
vEc.w-22-02
IPUCDR I3O
Page 3 of3
vEoLIA WATER TDAHO, INC. CASE VEO-W-22-02
THIRDPRODUCTION REQUEST OF THE COMMISSION STAF',F
Preparer/SponsoringWitness: Cary
REOUEST NO.131:
Please describe the customer self-help tasks that can be handled by the Interactive Voice
Response ("lVR") or online, (e.g., bill payment, payment arrangements, etc.).
RESPONSE NO.131:
TVR
Balance information
Bill Due Date
Last payment arnount
Payment Date of last payment
Pay by phone check or credit card
Paperless e-billing where to sign up mysuezwater.com
Direct Debit where to sign up mywater.veolia.us
Budget billing explanation with estimated amount
Online at mywater.veolia.us
Submit a contact us ticket
Chat with a CSR
Sigr up to receive text messages
Opt in to categories of email messages.
Sign up for automatic payments (direct debit or recuning)
Add a payment method to your online wallet
Make a payment
Make a payment as a guest
View previous payment information
Update profile information such as email address, password, phone numbers
Enroll in eBilling
Take a conservation survey and view results (usage information and potential savings)
View conservation tips
View water quality reports
View Rates (water tariffs & upcoming rate cases)
Set a conservation goal (AMI meters)
View water usage
View statements (up to 12 months back)
View message center messages
Start / stop water service
Add additional water accounts to your web profile
YEO-W-22-02
IPUC DR 131
Page I ofl
o
o
a
a
a
a
a
O
o
a
a
o
a
a
a
o
a
a
a
o
a
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/SponsoringWitness: Cary
REOUEST 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?
RESPONSE NO. 132:
Veolia's goal is to answer all incoming calls as quickly as possible and provide a "one call
resolution" experience. The call center Customer Service Representatives target for speed of answer is
within 45 seconds along with an abandoned call rate of 3o/o or less. Veolia's goal is also to answer 80oZ
of customer calls within 60 seconds or less. The self-service goal through the IVR is 50%.
Veolia customer service department takes the following steps to help ensure speed of answer and
abandoned call rate targets are being met.
. Maintain minimum staffing levels with no more thanZl%o of workforce unavailable
. Stagger Customer Service Representative (CSR) lunch hours and break times, avoiding
peak call times
. Call Center team leader role (implemented July of 2018) to monitor and respond to call
flow, escalations
. Phone calls are recorded, monitored, evaluated and reviewed with each CSR for
improvement opportunities
. Digital call boards posted on computer displays allow CSR's to monitor call flow
. CSR side work tasks are set aside to answer calls when calls waiting in que
. Utilize an authorized amount of overtime to augment peak call times (shorter lunch
hours) and to accomplish side work tasks outside of a regularly scheduled workday
. Offer over time Monday morning from 7:30am - 8am before the phone lines open to
complete web requests so focus can remain on phone calls during the workday
. Call metrics tracked by day, by CSR and reported regularly
. Average call handle time expectation of 4 - 5 minutes
. Continued training, feedback and coaching provided to CSR's on a regular basis
. Coordination with Manager of Communications and other company departments on
communication efforts to ensure CSR staff has available up-to-date information to
answer customer inquiries
vBo-w-22-02
IPUC DR I32
Page I of2
Provide customer information and contacts in various forms - electronically,
MyWater.Veolia.us website, bill inserts, bill messages, social medi4 etc.
Utilize a call routing and call answering system that will provide customers with
information and direct calls to an appropriate extension as needed
Call metrics included as part of employee evaluations
Monthly productivity metrics are shared with CSR's
Monthly meetings with Customer Service Supervisors to discuss best practices
If CSR call center objectives are not met with additional coaching focused faining and more
frequent call evaluations, escalating disciplinary actions will take place in addition to the Company's 30,
60 and 90 day evaluation reviews, and specific performance improvement plans.
a
a
a
a
a
YEO-W-22-02
IPUC DR I32
Page? of2
vEoLIA WATER IDAHO, INC. CASE VEO-W-22-02
THrRD PRODUCTTON REQUEST OF TrIE COMMTSSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST NO. I33:
Please provide the average speed of answer (ASA) for CSR-handled calls by month of the calendar
y ears 2020, 202 l, and 2022 to date.
RESPONSE NO. 133:
ASA (Seconds)Period
20
43'
26i
t4lt
28'
i6'.
38,
21
29
36
24
l3
t4
t6
t4
l3
23
42
29
l3
l3
26
22
t9
t2
l5
l3
23
23
37
75
170
140
59
Janugry-20
February-20
March-20
April-20
May-20
June-20
July-2O r
August-20 r
Seatember-20
October-20
November-20
OecemUir-ZO
lanlary-Zt
February-21
Marclr-2!
April-21
May-21
June-21
July-21
August-21
September-21
October-21
November-21
December-21
January-22
February-2?
March-22
Apil-22
May-22
Jvne-22
July-22
August-22
September-22
October-22
November-22
vEo-w-22-02
IPUC DR I33
Page I ofZ
The increase in average speed of answer during September and October 2022was due to an erhployee
vacancy and two employees on short-term disability.
vBo-w-22-02
IPUC DR I33
Page2 ofZ
VEOLIA WATER IDAHO,INC. CASE VEO.W.22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary
REOUEST 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?
RESPONSE NO. 134:
The Company offers emergency shut-off services 24 hours a day 365 days a year.
Dedicated on-call personnel are available after hours and on holidays to assist all customer classes,
as well as local police and fire agencies, with emergency services and leak response.
In all instances customers who have been disconnected for non-payment will be reconnected
within 24 hours of making their payment and contacting the company, whether that falls outside
of office hours, on weekends or holidays.
Reconnections
- Reconnections will take place Monday through Friday, between the hours of 8:00
a.m. and 6:30 p.m., or weekends/observed holidays between 8:00 a.m. and 4:30 p.m.
- Reconnections will not take place Monday through Friday, between the hours of 6:31
p.m. and 7:59 a.m., or weekends/observed holidays between 4:31 p.m. and 7:59 a.m.
New service connections
- New service connections will take place Monday through Friday, between the hours of
8:00 a.m. and 6:30 p.m., or weekends between 8:00 a.m. and 4:30 p.m.
- New service connections will not take place on observed holidays
- New service connections will not take place Monday through Friday, between the hours
of 6:31 p.m. andT:59 a.m., or weekends between 4:31 p.m. andT:59 a.m.
vEo-w-22-02
IPUC DR I34
Page 1 of I
vEoLIA WATER IDAIIO,INC. CASE VEO-W-22-02
THrRD PRODUCTTON REQUEST OF TrrE COMr\flSSION STAIT'
Preparer/Sponsoring Witness: Cary
REOUEST NO. 135:
Do the CSRs have access to the status of the customer's certification (if required under
the Company program?). [f not, how does a customer obtain that information?
RESPONSE NO. 135:
The CSR's do not have access to any cross connection certification results or information
concerning customers' backfl ow testing.
The customers contracted backflow tester should provide each customer with a copy of the
completed assembly test report for their records. Additionally certified cross connection control
testers must physically tag each tested backflow assembly, and the tags must include the test date,
tester's name, license number, and name of testing company.
YEO-W-22-02
IPUC DR I35
Page I ofl
vEoLrA WATER TDAHO, rNC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/SponsoringWitness: Cary
REOUEST 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.
RESPONSE NO. 136:
Please see the summary below in response to the number of customer complaints via an IPUC
inquiry by month for 2020,2021 and 2022 to date, by category of complaint. Each of these complaints
came through via an email from the ldaho Public Utilities Commission. In each instance a commission
staff review took place. The majority of customer complaints pertain to high bills, followed by inquiries
related to billing, the collections process and notices received by customers regarding disconnection for
non-payment.
In the summer of 2022 Veolia Idaho received feedback from Commission staff related to the
increase of sewer and trash bill issues through City of Boise utility billing. It was suggested by Staff at that
time to convene with City of Boise utilities staff and come up with a plan that would streamline the process
for customers to dispute their sewer bills. Veolia has met with City of Boise utilities and will continue
meeting monthly to discuss items impacting customers for both entities. The monthly rneetings will allow
coordination, awareness and to help address any emerging issues.
Month High
Bill
HomeServe Collections Water
Quality
Billing Payment Misc Total PUC
Inquiries
20-Jan
20-Feb
20-Mar
20-Apr
20-May
3
I
2 I 6
4
2
I
3
I
I
vBo-w-22-02
IPUC DR 136
Page I of3
Month
20.Jun
20-Jul
20-Aug
20-Sep
20-Oct
2&Nov
2GDec
2l-Jan
2l-Feb
21-Mar
21-Apr
21-May
21-Ju
21-Jul
21-Aug
2l-Sop
2t-otr/.,
2l-Nov
2l-Dec
22-Jm
22-Feb
22-Mu
22-Apr
22-NIay
22-hm
22-Jul
22-Aug
22-Sep
HlshBfi HomeServe Collecflons Wlter
Quellty
Biiling Palment Mtuc TotalPUC
Inquiries
I 1
1
3
3
I
1
I
I
1
2
I
I
I
2
.,
I
2
I
I
3
3
4
3
0
l
1
2
I
2
3
2
I
I
2
3
I
2
2
3
3
4
7
4
7
I
1
1 I
I
I
I
I2
1
I
I
I I
I 2
I
I I
2
I
I
1
I
I
I
2
I
I
I
I
3
I
2
vEo-w-22-02
IPUCDR 136
Page 2 of3
I
I
Month
22-Oct
22-Nov
TotaI
Hish
BiII
HomeServe Collections Water
Quatity
Billing Payment Misc Total PUC
Inquiries
6
2
94
2
10
2
2t
J
I
I
24 4 t6 9
YEO-W-22-02
IPUC DR I36
Page 3 of3
vEoLIA WATER IDAHO, rNC.
cAsE vEo-w-22-02
THIRD PRODUCTION REQUEST OF THE COMMTSSTON STAFF
Preparer/Sponsoring Witness :Cooper
REOUEST NO. I37:
Please provide the number of Tq-inch and l-inch residential meters installed for new
accounts for the years 2020, 2021, and2022 to date. Were the meters installed all AMI meters?
Please explain.
RESPONSE NO. 137:
The count of 3/t" and l" new meters installed for each of the requested years is shown in
the following table. All new meters installed in these years were AMI.
vBo-w-22-02
IPUC DR I37
Page I ofl
2020 2021 2022
(ut- ru30)
New %" and l"
meters installed
1,300 1,014 878
vEoLIA WATER TDAHO, rNC.
cAsE vEo-w-22-02
TI{IRD PRODUCTTON REQITEST OF TI{E COMMTSSTON STAIT'
Preparer/Sponsoring Witness: Cooper
REOUEST NO. 138:
Please provide the number of customers who have requested the Company install an AMI
meter to replace an older functioning non-AM[ meter for 2020,2021, and2022 to date. Please
identifu the size of the meter installed and whether the customers were residential or commercial.
RESPONSE NO. 138:
The Company doesn't specifically track this information. There are not a lot of
customers that specifically request AMI meters. Anecdotally, it's less than 1 percent of meter
replacements per year.
vEo-w-22-02
IPUC DR 138
Page 1 of 1
vEoLrA WATER IDAHO, INC.
cAsE vEo-w-22-02
TIIIRD PRODUCTION REQUEST OF THE COMMISSTON STAFF
Preparer/Sponsoring Witness: Cooper
REOUEST 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?
RESPONSE NO. 139:
Reports for slowing or stopped meters are reviewed daily following normal meter reading schedules
for billing. When meters are read for routine billing purposes each period (every 2 months), new readings
are compared against prior records to detect slowing or stopped conditions. These audit reports are
automatically generated the following day after billing reads are collected.
When audit reports show a meter to have zero increase in consumption from the prior period, a
variety of possible reasons are investigated (i.e. record of vacant property, or notice from customers of
temporary inactivity such as traveling out of town for the winter). If no cause for the zero-consumption is
found for the account, the bill will be allowed to generate a one-time zero-consumption record.
When the audit reports show accounts with two consecutive billing periods of zero consumption
(ie. 2 billing periods, or 4 months), a field technician will be sent to investigate the meter. If it is determined
that the meter has stopped due to mechanical failure, the technician would immediately replace the meter.
These workflows can be modified for expedited response in any case where an account is found to
have an advanced AMI meter with higher reading frequency.
Year - Meter Reolacement Count (Estimated Replacement Count due to malfunction)
2020 - 1,632 (13)
2021 - 1,712 (7)
YEO-W-22-02
IPUC DR I39
Page I of2
The following guidelines are used when rebilling a customer that has a stopped or malfunctioning
meter.
Commercial Accounts
The customer could not have reasonably known they were either not being billed for consumption, or being
under billed.
. If the inaccurate or zoro consumption bills cover one or up to three billing periods (6 months),
we will rebill all affected bills up to 3 based on the average usage for the same time period of
the last three years.
. The customer should have reasonably known that they were either not being billed for
consumption, or being under billed.
. If the inaccurate or zoro consumption bills cover one or up to l8 billing periods (3 years), we
will rebill all affected bills up to l8 based on the average usage for the same time period for
the last three years.
Residential Accounts
The customer could not have reasonably known that they were either not being billed for consumption, or
being under billed.
I 1 If the inaccurate bills cover at least three billing periods (6 months), we will rebill them based
on the average usage for the same time period for the last three years.
. If it is less than three billing periods (6 months) it will be left in the customers favor and not
rebilled.
. The customer should have reasonably known that they were either not being billed for
consumption, or being under billed.
. If the inaccurate bills cover one or up to 18 billing periods (3 years), we will rebill them for all
said bill periods based on the average usage for the same time period for the last three years.
wo-w-22-02
IPUC DR I39
Page2 ofZ
YEOLIA WATER IDAHO, INC.
cAsE YEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAITF
Preparer/Sponsoring Witness :Cooper
REOUEST NO. I4O:
Please provide a copy of the most recent Company Cross Connection Control Program as
required by the ldaho 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 notification 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 offon 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 Inigation/Fire Backflow Assembly."
RESPONSE NO. 140:
The most recent copy of the Company Cross Connection Control Program is attached
(Attachment l).
a. The Company's plan is based on assessing risk by l) degree of hazard,2) new acquisition, 3)
commercial customers. This ranking process informs the Company's daily and annual work
plans.
YEO-W-22-02
IPUC DR I4O
Page 1 of2
b. The licensed tester, contracted by the customer, is required to send Veolia a copy of the
premise backflow test report. This process is the same for all Veolia customers, regardless of
whetherthey live in a Municipality.
c. The Certificate of Occupancy in all jurisdictions where Veolia Water Idaho operates does not
require the Company to sign off on cross connections.
d. The Company is notified by the licensed backflow tester, and the tester's name, address and
license number appear on the test report, and on the certification tag placed on the backflow
assembly.
e. Veolia sends annual mailers to all customers about testing backflow assemblies, and also runs
commercials on local media. A copy of the mailer from2022 is attached (Attachment 2).
vBo-w-22-02
IPUC DR I4O
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vEolra WATER IDAHO, INC.
cAsE vEo-w-2242
THrRD PRODUCTTON BEQUEST OF Tm COMMISSION STArF
Preparer/Sponsoring Witness: Cooper
REOUEST NO. 141:
Please provide a ourrent copy offte Company's database for its Cross Conncction
Contnol Program.
RESPONSE NO.1{1:
The Company does not have a database for cnoss oonncction conhol. Paper rceords of
bacldow assembly tosts arc rstained by the Company.
VEG,W-22-02
IPUCDR I4I
Page I ofl
YEOLIA WATER IDAHO, rNC.
cAsE vEo-w-22-02
THrRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
REOUEST NO. 142:
For calendar years 2020,2021, 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.
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.
RESPONSE NO. 142:
a. The Company does not track the total number of customers with connections such as these
within our system. However when they are encountered in the field, our Cross Connection
Control Specialis(s) veri$ that the required backflow assembly is properly installed and has a
current test tag in place.
b. All of our customers are sent notifications via a yearly mailer in addition to commercials run on
local media stations. The Company does not track the total number of additional notices provided
directly to specific customers regarding their compliance with our Cross Connection Control
Policy.
c. The number of test certificates received is as follows:
a. 2020 - 1,759
YEO-W-22-02
IPUC DR I42
Page I of2
b.2021-1,228
c. 2022 (thloughNovembor)- 1,015
d. The Company does nottack how many cugtomers have had sonrice disconffit€d due to
failuro to comply with our Crcss Csnnoction Confrol Policy. If therc is an issue with a
cros$ contrtrtiotr, it is tlpically on adodicud inigationserviog whichhas no impact on
a customer's rosidcntial or commercial supply. The appropriate action taken in the feld
is always basd onthe observed degrce of hazard"
vEo-w-22-02
IPUC DR I42
Page 2 of2
vEoLIA WATER IDAHO, rNC.
cAsE vEo-w-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
REOUEST 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.
RESPONSE NO. I43:
a. As noted in the Company's Cross-Connection Control Program, for assemblies that operate
year-round, the final due date for annual testing will be one year from the last record of
successful testing (found on the test tag). Failure to comply with the annual testing
requirements may result in a customer receiving an Initial Notice of Termination l0 days
prior to a proposed date of termination. Company staff diligently attempt to contact and
work with any customer to advise them on steps that can be taken to avoid termination and
ensure both our customers and water system are protected. Average test times from initial
contact to completion vary based on seasonal demand, but are completed as soon as
possible.
b. It is the Company's intention to provide customers every opportunity to comply with the
state cross connection control requirements of our program, but as stated in our Cross-
Connection Control Policy on page l2:
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IPUC DR I43
Page I of2
"IPUC Utility Customer Relations Rules provide Veolia the right to deny or terminate
service without prior notice to any customer or applicant andwithout the castomers or
applicants permission when conditions immediately dangerous or hazardous to ltfe,
physical safety, or proryrty exists, or if necessary to prevent a violation offederal, state
or local safety or health code. (Ref IDAPA 31.21.01, Rule 303)
Alternatively, if a customer can demonstrate that the potential hazard has been
eliminated, water service may not be intemrpted.
c. Determination of the appropriate backflow assembly is made at the discretion of
Veolia's Cross-Connection Control Specialist(s) in accordance with referenced
industry standards. Failure to comply with any notice of determination will result in
denial of water service to new customers, or potentially immediate termination for
existing connections. As previously stated, actions taken in the field are a direct result
of the degree of hazard observed by Company staff. Every effort is made to work with
our customers to ensure that an improper assembly is removed and replaced with the
correctly installed, required assembly, as quickly as possible.
vBo-w-22-02
IPUC DR I43
Page2 of2
vEoLIA WATER IDAHO,INC. CASE VEO-W-22-02
THIRD PRODUCTTON REQUEST OF THE COMMTSSTON STAIT'
Preparer/Sponsoring Witness: Cary
REOUEST 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.
RESPONSE NO. 144:
The Company's rules & regulations bill insert is shared annually with customers, mailed
generally in January and February or as the Company's rates or rules change as the result of a
general rate case. These notices are mailed to customers with their paper bill or delivered
electronically for customers who opt in to receiving electronic bills and electronic notices.
Please see Attachment I through 3 of the Company's rules & regulations inserts.
During 2022, customers received one of three rules & regulation bill inserts due to the
acquisition of Eagle Water Company and the different rates and bill frequencies that apply to those
customers.
Former Eagle Water Company customers who were part of the acquisition and will have
their rates phased in over time, received Attachment l.
Customers that are new to the Eagle Water area that are billed full Veolia rates at a monthly interval
received Attachment 2.
Veolia customers who are billed bi-monthly received Affachment 3.
wo-w-22-02
IPUC DR I44
Page I of I
vEoLrA WATER TDAHO, rNC. CASE VEO-W-22-02
TITTRD PRODUCTION REQUEST OF THE COMMTSSION STArr'
Preparer/Sponsoring Witness: Cary
REOUEST 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.
RESPONSE NO. 145:
Please refer to the response to Request No 144 and accompanying Attachments 1-3.
The Company's Rules & Regulations insert addresses both the Summary of Rules and Explanation
of Rate Schedules in that response, as both items are addressed in the same customer insert.
vEo-w-22-02
IPUC DR I45
Page I ofl
vEoLrA WATER TDAHO, INC. CASE VEO-W-22-02
THrRD PRODUCTTON REQUEST OF TTTT COMMSSTON STArr'
Preparer/Sponsoring Witness: Cary
REOUEST NO. 146:
Please provide copies of the following Company documents:
a. Initial Notice to Terminate
b. Final Notice of lntent to Terminate Service
c. Notice of Procedure for Reconnecting Service left at the premises following disconnection of
service (door tag or notice, ifused).
RESPONSE NO. 146:
Please see Attachment I for Initial Termination Notice, Attachment 2 for Final Notice
and Attachment 3 for Termination Door Tag.
YEO-W-22-02
DR IPUC 146
Page I ofl
vEoLrA WATER TDAHO, rNC. CASE VDO-W-22-02
TErRD PRODUCTION REQUEST OF TrrE COMMTSSION STAFF
Preparer/Sponsoring Witness: Cary
REOTJEST NO. 147:
Please provide a sample copy of a biling statement currently sent to customers who have:
a. no past due balance owing.
b. a past due balance.
c. a monthly payment arrangement.
RESPONSE NO. 147:
Please see Attachment 1 for no past due balance owing, Attachment 2 for past due
balance and Attachment 3 for monthly payr.ent arrange,ment (Budget Bill).
vBo-w-22-02
IPUC DR 147
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