20230104_Veolia to Staff 42-147.PDF

VEOLIA WATER IDAHO, INC.’S RESPONSES TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 1 OF 3
16518505_2.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 THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF
In response to the Third Production Request of the Commission Staff to Veolia Water
Idaho, Inc. dated December 2, 2022, Veolia Water Idaho, Inc. (“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 Staff, Veolia will complete the responses on January
9, 2023.
DATED: January 4, 2023.

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

VEOLIA WATER IDAHO, INC.’S RESPONSES TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 3
16518505_2.DOCX (30-235)
CERTIFICATE OF SERVICE

I certify that on January 4, 2023, 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 THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 3 OF 3
16518505_2.DOCX (30-235)

Preston N. Carter
VEO-W-22-02 IPUC DR 61 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary

REQUEST NO. 61:
Please provide the following monthly information in Microsoft Excel electronic format for
each well pump and/or booster pump within the system over the past 5-years:
a. Electric energy consumed (kWh)
b. Differential pressure between the pump suction and discharge (psi) Electric
energy consumed (kWh)
c. Amount of water pumped (gal).

RESPONSE NO. 61:
Please see the following attachments in response to the requested information:
a. Attachment 1-Request No 61 (a) - Power by Site
b. Attachment 2-Request No 61 (b) - Differential pressure
c. Attachment 3-Request No 61 (c) - Production by Site
VEO-W-22-02 IPUC DR 62 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary REQUEST NO. 62:
Please provide the following monthly information in Microsoft Excel electronic format
for each location where chemical treatment is introduced into the system over the past 5-years:
a. Location
b. Chemical treatment type and concentration
c. Amount of chemical treatment introduced into the system
d. Amount of water treated.

RESPONSE NO. 62:
Please see Attachment 1. The chemical calculations are based on average monthly
system data.

VEO-W-22-02 IPUC DR 92 Page 1 of 2
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson

REQUEST NO. 92:
With reference to Exhibit No 10, Schedule 1, Adjustment 16 - Vehicle Allocation, please
provide supporting documentation for the following transportation expenses as shown in
Company witness Wilson's Direct Testimony beginning on page 6. In the response, please
identify any additional costs necessary for future employees that have been included as a pro
forma adjustment to the Company's revenue requirement. Also, please verify that the mechanic
payroll has not been already included in the Payroll Adjustment.
a. Mechanic payroll and benefits
b. Lease Cost & GPS fees
c. Fuel
d. Material, Maintenance
e. Insurance
f. Other Costs
g. Depreciation
h. Tax
i. VA Allowance

RESPONSE NO. 92:
With reference to the pro forma Test Year Expense filed in Exhibit No 10, Schedule 1,
Adjustment 16 - Vehicle Allocation, please see below for supporting documentation.

a. Mechanic payroll and benefits ($99,362): The Test Year expense is based on the
annual salary of the mechanic as included in the total on Line 3 - Transmission and
Distribution labor in Exhibit No 10, Schedule 1, Adjustment 1 - Payroll. The annual
salary of $74,246 is based on the rate of pay effective in the current Collective
Bargaining Agreement. Additionally, Historic Test Year Fringe Benefit Allocation as
filed in Exhibit No 10, Schedule 1, Adjustment 8 of 33.83% is added for a total Test
Year expense of $99,362. The mechanic payroll and benefits are initially recorded to
VEO-W-22-02 IPUC DR 92 Page 2 of 2
direct labor expense but through an allocation process, are transferred out to the
vehicle allocation account 50645000. As a result, the mechanic’s payroll is not also
included in the payroll adjustment.
b. Lease Cost & GPS fees ($736,412): See Attachment 1 - Test Year Lease Costs.
Column Q summarizes the Test Year lease expense. GPS fees are included in "Other
Costs".
c. Fuel ($351,490): See Request No 95 for documentation regarding the Test Year fuel
expense.
d. Material, Maintenance ($216,070): Test Year expense was calculated using the
actual materials and maintenance charges for 2021, plus a 3% projected inflation
factor. See Attachment 2 - Materials, Maintenance for details.
e. Insurance ($211,509): Corporate allocation
f. Other Costs ($207,652): Includes depreciation ($140,248), Heavy Highway Vehicle
Use Tax ($2200), VA Allowance ($37,404), and ($27,800) of various other costs
including GPS fees and monthly lease management fees.
g. Depreciation : $140,248 - Corporate allocation based on depreciable assets and
included in Other Costs total.
h. Tax: Refers to Heavy Highway Vehicle Use Tax at $2200 and is included in Other
Costs total.
i. VA Allowance: $37,404 - 5 Upper Management Employees receive a vehicle
allowance. These costs are included in the Other Costs total and reflected in
confidential Attachment 4- VA Allowance (Confidential).

Historic Test year journal entries are included in Attachment 3 - Historic Test Year Journal
Entries and tie to filed amount of $834,494.
VEO-W-22-02 IPUC DR 93 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson REQUEST NO. 93:
Please provide a schedule showing the year, make, and model of the Company's current
fleet of vehicles. For each vehicle, please state whether it is leased or owned by the Company,
along with the purchase price and net book value.

RESPONSE NO. 93:
Please see the attachment for current fleet details.
VEO-W-22-02 IPUC DR 96 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Wilson REQUEST NO. 96:
Please provide the source documents and calculations that support the increase in costs of
$70,176 for the insurance and vehicle maintenance costs mentioned on page 8 of Company
witness Wilson's Direct Testimony. Please include the invoices, insurance policies, and other
source documents to support this increase.

RESPONSE NO. 96:
The testimony of Company witness Wilson inadvertently stated an increase in costs of
$70,176 for the insurance and vehicle maintenance costs mentioned on page 8 whereas it should
have been stated as a decrease of $68,669. The table below shows the Historic Test Year ending
June 30, 2022 compared to the Test Year expense by category. The costs in question are
comprised of Vehicle Maintenance (Cost Element 682004), Auto Insurance (Cost Element
682005), and Other Transportation Costs (Cost Element 682006) – highlighted in grey below. In
total, these specific costs are decreasing by a net expense amount of $68,669. Vehicle
maintenance costs decreased from the Historic Test Year by $34,321. Auto insurance costs
decreased from the Historic Test Year by $88,536. Other Transportation costs increased by
$54,188 which is predominantly depreciation expense due to the purchase acquisition of a vac
truck and two large crew trucks.

Expense Type
Cost
Element
Historic Test
Year - Gross
Test Year -
Gross
Gross
Difference
Net
Difference
Labor Expense 682001 128,907 99,362 (29,545) (16,718)
Leased Vehicles (Net of Proceeds)682002 310,818 725,912 415,094 234,888
Vehicles:Gasoline 682003 274,872 351,490 76,618 43,356
Vehicle Maintenance 682004 276,722 216,070 (60,652) (34,321)
Auto Insurance 682005 367,970 211,509 (156,461) (88,536)
Other Transporation Costs 682006 111,891 207,652 95,761 54,188
TOTAL GROSS 1,471,182 1,811,996 340,814 192,856 NET EXPENSE 832,494 1,025,350 192,856
Historic Test Year Opex Ratio 56.59%
Subtotal Vehicle Maintenance, Auto Insurance, & Other Transportation Costs (68,669)