20221230Veolia Water to Micron 1-22.pdf

VEOLIA WATER IDAHO, INC.’S RESPONSES TO MICRON’S FIRST SET OF DISCOVERY PAGE 1 OF 3
16553425_1.DOCX (30-235)
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Veolia Water Idaho, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF VEOLIA WATER IDAHO, INC. FOR A
GENERAL RATE CASE
Case No. VEO-W-22-02
VEOLIA WATER IDAHO, INC.’S
RESPONSES TO MICRON’S FIRST SET OF
DISCOVERY REQUESTS
Veolia Water Idaho, Inc. (“Veolia” or “Company”), in response to Micron’s First Set of
Discovery Requests to Veolia Water Idaho, Inc. dated December 9, 2022, submits the responses
below. Documents are available for download at the link provided in the transmittal email. An
updated response to Request 41 of the Commission Staff is also available for download at the
same link.
DATED: December 30, 2022.
By:_____________________________
Preston N. Carter
Givens Pursley LLP
Attorneys for Veolia Water Idaho, Inc.
RECEIVED
Friday, December 30, 2022 11:42:51 AM
IDAHO PUBLIC
UTILITIES COMMISSION
VEOLIA WATER IDAHO, INC.’S RESPONSES TO MICRON’S FIRST SET OF DISCOVERY PAGE 2 OF 3
16553425_1.DOCX (30-235)
CERTIFICATE OF SERVICE

I certify that on December 30, 2022, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:

Commission Staff Via Electronic Mail
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
[e-mail]

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

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

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

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

Mary Grant
Deputy City Attorney
Boise, City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
VEOLIA WATER IDAHO, INC.’S RESPONSES TO MICRON’S FIRST SET OF DISCOVERY PAGE 3 OF 3
16553425_1.DOCX (30-235)

Preston N. Carter
VEO-W-22-02
MICRON DR 1 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna REQUEST NO. 1:
Please provide copies of all data requests and responses issued to Veolia Water Idaho, Inc. (“VWID”) by all parties in this case. This is an ongoing request.

RESPONSE NO. 1: Responses were provided on December 7, 2022 and December 22, 2022.

VEO-W-22-02
MICRON DR 2 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna REQUEST NO. 2:
Please provide the exhibits of all witnesses who filed direct testimony on behalf of VWID in electronic spreadsheet format with all formulas and links intact.

RESPONSE NO. 2: Please refer to the IPUC website where all testimony and exhibits filed in the case are available.
VEO-W-22-02
MICRON DR 3 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna REQUEST NO. 3:
Please provide the workpapers of all witnesses who filed direct testimony on behalf of VWID in electronic spreadsheet format with all formulas and links intact.
RESPONSE NO. 3: Work papers relating to this case have been provided and available on the sharefile site.
VEO-W-22-02
MICRON DR 4 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna REQUEST NO. 4:
To the extent not provided in response to the above, please provide a copy of the load study
discussed in Appendix B to Ms. Bui’s testimony, along with all supporting workpapers and
resource material. Please provide the load study in electronic spreadsheet format with all formulas
and links intact.

RESPONSE NO. 4:
Please refer to IPUC DR No. 41.

VEO-W-22-02 MICRON DR 5 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Bui REQUEST NO. 5:
For the test year and resource planning year purposes, please provide hourly water pumping
data at:
a. water treatment plant,
b. purchased water delivery to Veolia; and
c. water delivered via the transmission mains to the distribution mains.

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

RESPONSE NO. 5:
a. Hourly water treatment plant flow data for the test year and resource planning
year are in the attached Excel spreadsheet. Data for July 24 14:00-25 13:00, 2021 for
Columbia Water Treatment Plant is an estimate due to disruptions in data reporting.
b. No production water is purchased.
c. Hourly water delivered from the well sources via the transmission mains to the
system are in the attached Excel spreadsheet. This is water delivered in addition to the
water treatment plant flows included in part (a). Data for July 24 14:00-25 13:00, 2021 is
based on the estimates for Columbia WTP in part a. Data for 2 timesteps (March 14, 2021
0:00 and March 13, 2022 0:00) is not reported due to data reporting disruptions.

The Company has advanced metering devices that track hourly water source pumping for
the test year and resource planning purposes.

VEO-W-22-02
MICRON DR 6 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna REQUEST NO. 6:
Please refer to Bui, Appendix B at page 8. Paragraph 1.1 states that the current tariff
includes an Industrial classification; however, no active customers are in this class. Please
provide VWID’s definition of an Industrial customer, along with documentation supporting the
response.

RESPONSE NO. 6:
Please refer to Company Tariff Sheet No. 36, paragraph 52 II.
VEO-W-22-02
MICRON DR 7 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Bui REQUEST NO. 7:
Please identify any water customers that meet the following load characteristics: served
on meter size 8 inches and larger, have ratios of extra capacity volumes relative to base volumes
that are lower than the system average, and are served directly from a transmission main of 8
inches or larger.

RESPONSE NO. 7:
For the test period under consideration, VWID reports two (2) 8-inch meters. One meter
is associated with a 24-inch diameter main and the other is associated with a 12-inch diameter
line. Customer confidentiality does not allow the provision of customer information.

VEO-W-22-02
MICRON DR 8 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Bui REQUEST NO. 8:
Please refer to Bui, Appendix B at page 11. Paragraph 2.2 states that the period of
6/1/2021 – 8/31/2021 would define the analytical window and would contain the MD and MH
values for the system and customer classes. Please confirm that there were no water usage
restrictions in place during this time. If not confirmed, please identify the dates in which
restrictions on water usage were in place.

RESPONSE NO. 8:
There were no water restrictions in place on the VWID system during the period 6/1/2021
– 8/31/2021.

VEO-W-22-02
MICRON DR 9 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna REQUEST NO. 9:
Please provide VWID’s definition of a Residential customer. Please include
documentation supporting the response.

RESPONSE NO. 9:
Please refer to Company Tariff Sheet No. 36, paragraph 51.

VEO-W-22-02
MICRON DR 10 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna REQUEST NO. 10:
Please provide VWID’s definition of a Commercial customer. Please include
documentation supporting the response.

RESPONSE NO. 10:
Please refer to Company Tariff Sheet No. 36, paragraph 52.1
VEO-W-22-02
MICRON DR 11 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna REQUEST NO. 11:
Please provide VWID’s definition of a Public Authority Customer. Please include
documentation supporting the response.

RESPONSE NO. 11:
Please refer to Company Tariff Sheet No. 36, paragraph 52.III

VEO-W-22-02
MICRON DR 12 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna REQUEST NO. 12:
Please provide VWID’s definition of Private Fire Customer. Please include documentation
supporting the response.

RESPONSE NO. 12:
Please refer to Company Tariff Sheet No. 35, paragraph 43, 44 and 45.

VEO-W-22-02 MICRON DR 13 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Bui REQUEST NO. 13:
Please refer to Bui, Appendix B at 15, Section 3.3.1. In electronic spreadsheet format with
all formulas and links intact, please provide the workpapers that were used to develop an average
hourly usage profile for each customer class, as described in Section 3.3.1.

RESPONSE NO. 13:
Three electronic files are provided that contain the main set of calculations for estimating
peak factors by customer class, and these are further described below. The source data
supporting this project was extensive, Over half a billion raw AMI data records (individual
hourly meter readings) were stored on a Snowflake data cloud and accessed by Black & Veatch
analysts. Raw data was loaded, cleaned, and transformed in an SQL server and then exported to
other databases and business intelligence tools for analysis and data visualization and used in the
three files listed below provided as part of IPUC Data Request No 41.
• Attachment 1: HoulyProductionSummary.xlsx. This file contains hourly production
volumes and reservoir storage volume changes for the VWID system and is used to identify
system max day and max hour timeframes.
• Attachment 2: UsageSummaries v2.xlsm. This file uses a data query from the billing
database to establish typical average and seasonal usage values by customer class. The data is
then joined with available AMI meter information to identify which customers have AMI
meters and to compare usage metrics for customers on AMI accounts against usage metrics
for all customers by customer class.
• Attachment 3: VWID Load Study Results.xlsx. This file uses the representative AMI
accounts identified in File 2 to construct hourly estimates of usage by each customer class for
the maximum day and hour periods identified for the study.

VEO-W-22-02 MICRON DR 14 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Bui REQUEST NO. 14:
Please refer to Bui, Appendix B at Table 4-1 and Table 4-3.
a. These tables show that the coincident peak demand and the non-coincident peak
demand for the Commercial class are the same (i.e., 3,681,223 cubic feet). Please
confirm that this is correct.
b. In electronic spreadsheet format with all formulas and links intact, please provide
the workpapers supporting the development of these tables.

RESPONSE NO. 14:
a. Confirmed as correct. See Cell T4 and T6 on tab Summary Results in Excel
Workbook File IPUC Data Request No 41 Attachment 3-VWID Load Study
Results.xlsx
b. The tables are shows in the region of R44 on tab Summary Results in Excel
Workbook file IPUC Data Request No 41 Attachment 3-VWID Load Study
Results.xlsx
VEO-W-22-02
MICRON DR 15 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Bui REQUEST NO. 15:
Please refer to Bui, Appendix B at page 22, which states, “although total rainfall for July
2021 was unusually high, over 90% of the entire volume recorded for July occurred in one day
(July 31st, 2021), meaning it was generally also a typically dry month.” In electronic spreadsheet
format with all formulas and links intact, please provide the workpaper supporting the quoted
statement.

RESPONSE NO. 15:
The Excel Workbook Attachment 1-USW00024131_BoiseAirTerminalClimateData.xlsx
has been provided. Refer to cell F3135 on tab 2013-2021 to see the calculation supporting the
referenced statement.
VEO-W-22-02
MICRON DR 16
Page 1 of 1

VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S FIRST SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Bui REQUEST NO. 16:
Please refer to Bui, Appendix B, at page 5. Regarding the subset of 14,245 AMI meters
that were used to develop the customer class MD and MH demand ratios in the load study, please
provide the monthly billed water consumption for calendar year 2021 for each AMI meter in the
subset. Please provide the data by customer class, in electronic spreadsheet format, with
formulas and links intact.

RESPONSE NO. 16:
VWID bills their customers bi-monthly and not monthly, so only bi-monthly billing data
can be provided. Bi-monthly billing data for 2021 is included in columns Q:AB in tab
qry_2020_2021AccountsByMonth.sq in Excel Workbook IPUC Data Request No 41
Attachment 2- Usage Summaries v2.xlsx. The accounts that were in the final 14,245 meter
subset are indicated in column BC with “YES.”
VEO-W-22-02 MICRON DR 17 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
FIRST PRODUCTION REQUEST OF MICRON
Preparer/Sponsoring Witness: Cooper
REQUEST NO. 17:
Regarding transmission mains:
a. Please identify all sizes (in diameter) of transmission mains installed on the Company’s
transmission system.
b. For each main size identified in part a., above, please provide the total length of main
installed on the Company's transmission system.
c. Please describe the Company’s meter installation protocols in terms of specifying the size of
a main that is needed to connect a specific meter size to its transmission system.
RESPONSE NO. 17:
a/b. The size in diameter and total length of transmission mains are in Table 1 below.
Table 1 12” 14” 16” 18” 20” 24” 30” 36” Total
Length (miles) 336.22 1.82 55.16 0.98 5.41 19.47 3.85 0.38 423.28
c. The size of transmission mains that are used to service various meter sizes are determined
by the Company using engineering analysis.

VEO-W-22-02 MICRON DR 18 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
FIRST PRODUCTION REQUEST OF MICRON
Preparer/Sponsoring Witness: Cooper
REQUEST NO. 18:
Regarding distribution mains:
a. Please identify all sizes (in diameter) of distribution mains installed on the Company’s
distribution system.
b. For each main size identified in part a., above, please provide the total length of main
installed on the Company's distribution system.
c. Please describe the Company’s meter installation protocols in terms of specifying the size of
a main that is needed to connect a specific meter size to its distribution system.
RESPONSE NO. 18:
a/b. The size in diameter and total length of distribution mains are in Table 2 below.
Table 2 ≤1.5” 2-2.5” 3” 4” 6” 8” 10” Total
Length (miles) 0.99 28.20 1.12 42.11 296.12 649.75 10.80 1029.10
c. The size of distribution mains that are used to service various meter sizes are determined
by the Company using engineering analysis.

VEO-W-22-02 MICRON DR 19 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
FIRST PRODUCTION REQUEST OF MICRON
Preparer/Sponsoring Witness: Cary
REQUEST NO. 19:
Please identify the number of meters, the size of the meters, and the sizes of mains that
serve Residential customers.

RESPONSE NO. 19:
The number and sizes of Residential meters are in Bui Exhibits; Factor 8 of Exhibit 14-F.
The sizes of mains that serve Residential customers ranges from 0.5” - 24”.
VEO-W-22-02
MICRON DR 20 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
FIRST PRODUCTION REQUEST OF MICRON
Preparer/Sponsoring Witness: Cary
REQUEST NO. 20:
Please identify the number of meters, the size of the meters, and the sizes of mains that
serve Commercial customers.

RESPONSE NO. 20:
The number and sizes of Commercial meters are in Bui Exhibits; Factor 8 of Exhibit 14-
F. The sizes of mains that serve Commercial customers ranges from 0.5” - 24.”

VEO-W-22-02 MICRON 21 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
FIRST PRODUCTION REQUEST OF MICRON
Preparer/Sponsoring Witness: Cary
REQUEST NO. 21:
Please identify the number of meters, the size of the meters, and the sizes of mains that
serve Public Authority customers.

RESPONSE NO. 21:
The number and sizes of Public Authority meters are in Bui Exhibits; Factor 8 of Exhibit
14-F. The sizes of mains that serve Public Authority customers ranges from 0.5” - 24.”

VEO-W-22-02 MICRON DR 22 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
FIRST PRODUCTION REQUEST OF MICRON
Preparer/Sponsoring Witness: Cooper
REQUEST NO. 22:
Please provide documentation describing VWID’s meter installation policies, including
descriptions of the sizes of mains that can be used to safely and reliably provide service to
various meter sizes.

RESPONSE NO. 22:
Rules governing the Company’s meters and main extension sizing are in the Tariff
documentation. The size of mains that are used to service various meter sizes are determined by
the Company using engineering analysis. The Company reserves the right to establish the size and
location of meters required by each customer and main extensions are normally to be 8-inch inside
diameter, however the Company determines the size of all water mains to be extended.