20230109Staff 152-158 to Veolia.pdf

CHRIS BURDIN O
DEPUTY ATTORNEY GENERAL
.IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 SS
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )CASE NO.VEO-W-22-02VEOLIAWATERIDAHO,INC.FOR A )GENERAL RATE CASE )
)FIFTH PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO VEOLIA WATER IDAHO,
)INC.
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy Attorney General,requests that Veolia Water Idaho,Inc.provide the
following documents and information as soon as possible,but no later than MONDAY,
JANUARY 23,2023.1
This Production Request is to be considered as continuing,and Veolia is requested to
provide,by way of supplementaryresponses,additional documents that it,or any person acting on
its behalf,may later obtain that will augment the documents or information produced.
Please provide answers to each question;supporting workpapers that provide detail or are
the source of information used in calculations;and the name,job title,and telephone number of
I Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff'sattorneyat(208)334-0314.
FIFTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 1 JANUARY 9,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUESTNO.152:Please respond to the followingin reference to the major findings
of the Load Study discussed on pages 7-8 of Bui's Direct Testimony.
a.Please explain how the Company determined that the System Maximum Day Ratios
from the Load Study are consistent with the Company's ratios based on the highest
annual maximum water production day over the last ten years.Please provide the
analysis with data that shows the comparison and the criteria used to justify the
Company's contention.Please include workpapers with formula intact.
b.What timeframes did the Company use to determine the average day and average hour
usage terms (denominator of the ratio)to calculate the peaking factors for the System
Maximum Ratios in the Load Study for each of the classes?
c.What timeframes did the Company use to determine the average day usage terms
(denominator of the ratio)to calculate the Company's ten-year System Maximum
Ratios used to compare against the System Maximum Ratios in the Load Study?
d.Please provide evidence and/or analysis that "water conservation efforts,commercial
irrigation patterns,and storage management,"are the causes that have "produced a
system whereby all customer classes peak at close to the same time (coincident
peaking)."
e.Please provide the analysis (includingall workpapers with formula intact)that justifies
the Company's contention that "all customer classes peak at close to the same time
(coincident peaking)."
REQUESTNO.153:In Bui's Direct Testimony,page 8,Bui states:"the reviewed data
showed no customer classes or groups exhibiting significantlydifferent usage patterns."Please
identify the specific information in the Load Study and provide the analysis that justifies this
statement.
FIFTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 2 JANUARY 9,2023
REQUESTNO.154:The Load Study,page 7,states a key objective is to "establish a
basis for selecting maximum day and maximum hour ratios for each appropriate customer
classification and the total system."Please provide the specific information in the Load Study and
the analysis that was performed to justifythat the Company's currentlydefined customers are the
appropriate customer classifications.
REQUESTNO.155:Please provide the results of any other breakdowns of potential
classes that the Company analyzed from the Load Study.Please include the results,criteria used
to form the alternative classes,workpapers of the analysis,and data used for each.
REQUESTNO.156:Please explain why the Load Study did not collect data that could
be used to identify other potential consumptive customer classes.
REQUESTNO.157:In Bui's Direct Testimony,page 9,Bui states:"The COSS based
total fire demand on 1 4-hour,4,500 gallons per minute (gpm)fire,1 4-hour,4,000 gpm fire,and
1 2-hour 1,500 gpm fire.This is a change from a total system demand for a 10-hour,10,000 gpm
fire."Please respond to the following:
a.Please explain why this change was made and provide justification for the change.
b.Please explain why private fire protection customers were not included in the Load
Study.
REQUESTNO.158:Please confirm that Advanced Metering Infrastructure ("AMI")
meter data from September 2020 to December 2021 was the only AMI meter data available for the
Load Study.Also,please confirm the number of AMI meters,broken out by customer class,
available during this time is consistent with Table 1-1 from the Load Study on page 7.If the time
frame and/or number of AMI meters is not correct,please provide the correct timeframe and/or
number of AMI meters.
FIFTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 3 JANUARY 9,2023
DATED at Boise,Idaho,this day of January 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umisc:prodreq/veow22.2cme prod req 5
FIFTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 4 JANUARY 9,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF JANUARY 2023,
SERVED THE FOREGOING FIFTH PRODUCTION REQUESTOF THE
COMMISSION STAFF TO VEOLIA WATER IDAHO,INC.,IN CASE NO.
VEO-W-22-02,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
PRESTON N CARTER DAVID NJUGUNA
MORGAN GOODIN MGR-REGULATORY BUSINESS
GIVENS PURSLEY LLP VEOLIA WATER M&S INC
PO BOX 2720 461 FROM ROAD STE 400
BOISE ID 83701-2720 PARAMUA NJ 07052
E-MAIL:[e-mail] E-MAIL:David.njuguna veolia.com
[e-mail]
[e-mail]
LORNA K.JORGENSEN SHARON M.ULLMAN,PRO SE
MEG WADDEL 5991 E.BLACK GOLD STREET
ADA COUNTY PROSECUTING BOISE,ID 83716
ATTORNEY'S E-MAIL:sharonu20l3 email.com
'OFFICE /CIVIL DIVISION
200 W.FRONT STREET,ROOM 3191
BOISE,ID 83702
E-MAIL:[e-mail]
JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY,INC.THORVALD A.NELSON
8000 SOUTH FEDERAL WAY AUSTIN W.JENSEN
BOISE,ID 83707 HOLLAND &HART,LLP
E-MAIL:[e-mail] 555 17TH STREET SUITE 3200
DENVER,CO 80202
E-MAIL:[e-mail]
MARY R.GRANT [e-mail]
DEPUTY CITY ATTORNEY [e-mail]
BOISE CITY ATTORNEY'S OFFICE [e-mail]
105 N.CAPITOL [e-mail]
PO BOX 500
BOISE,ID 83701-0500
E-MAIL:[e-mail]
boisecitvattornev citvofboise.ore
SECRETARY
CERTIFICATE OF SERVICE