20230111Micron 23-47 to Veolia.pdf

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -1- JANUARY 11, 2023
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen
HOLLAND & HART LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

Attorneys for Micron Technology, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF VEOLIA WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO
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)
)
)
)
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CASE NO. VEO-W-22-02

MICRON’S SECOND SET OF
DISCOVERY REQUESTS TO
VEOLIA WATER IDAHO INC.

Micron Technology, Inc. (“Micron” or “Intervenor”), by and through its counsel, Holland
& Hart LLP, submits the attached second set of discovery requests to Veolia Water Idaho Inc.
(“Veolia”). The following response date, definitions, and instructions apply to the enclosed
discovery requests.
In addition to the written copies provided as responses to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
RESPONSE DATE, DEFINITIONS AND INSTRUCTIONS

Please respond to these interrogatories and requests for production of documents by
February 1, 2023.

DEFINITIONS

1. “Veolia Water Idaho Inc.,” “Veolia,” “VWID,” “the Company,” or “you” means Veolia
Water Idaho Inc. and the employees, officers, directors, agents, consultants, attorneys and
RECEIVED
Wednesday, January 11, 2023 3:18:18 PM
IDAHO PUBLIC
UTILITIES COMMISSION

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -2- JANUARY 11, 2023
all persons acting under contractual arrangement with or acting or purporting to act on
behalf of Veolia.

2. “VUR” means Veolia Utility Resources LLC.

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

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

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

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

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

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

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

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

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

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -3- JANUARY 11, 2023
10. Any request to “identify” or “provide” should be interpreted to mean:

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

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

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

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

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

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

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

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -4- JANUARY 11, 2023
14. “Relating To” or “Related To” means pertaining to, presenting, discussing, commenting
on, analyzing, or mentioning in any way.

GENERAL INSTRUCTIONS

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

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

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

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

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

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

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

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

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

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

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -5- JANUARY 11, 2023
11. If after exercising due diligence you are unable to answer any interrogatory or to produce
any document requested, you must explain your inability in detail.

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

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

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

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

INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 23: If not already provided, in electronic format with all formulas intact,
please provide all exhibits, tables and figures supporting the testimony of Mr. Walker. This is an
ongoing request for all subsequent testimonies filed by this witness.
REQUEST NO. 24: Please provide copies of all publications and credit reports considered
by witness Mr. Walker. This is an ongoing request for all subsequent testimonies filed by this
witness.
REQUEST NO. 25: Please provide copies of all credit reports published by Standard &
Poor’s (“S&P”), Moody’s, and Fitch Ratings for VWID and VUR, issued over the last two years.
This is an ongoing request.
REQUEST NO. 26: Please provide complete copies of credit reports issued by S&P,
Moody’s, and Fitch Ratings over the last two years that discuss the current regulated utility

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -6- JANUARY 11, 2023
industry as reviewed by any VWID witness. If VWID witnesses have not reviewed the material,
please so state. This is an ongoing request.
REQUEST NO. 27: Please provide copies of all correspondence, presentations and all
other materials that VWID, VUR, or its parent company provided to credit and equity analysts
over the last two years. This is an ongoing request.
REQUEST NO. 28: Please provide copies of VWID’s and VUR’s annual and quarterly
reports that include all financial reports and supporting notes for the period 2017-2022. This is an
ongoing request.
REQUEST NO. 29: Please provide a projection of VWID’s capital expenditures out over
the next five years, and an estimate of the sources of cash available to fund these capital
expenditures broken out by external debt markets, external equity infusions from its parent
company, retained earnings, depreciation expense, deferred taxes and other sources (explain).
Please also include in this response the funding planned for debt maturity, retirements and/or
refinancing over this same time period.
REQUEST NO. 30: In electronic format with all formulas intact, please provide the
monthly average balances for construction work in progress and short-term debt for the most recent
13-month period and the test period. Please identify the amount of short-term debt included in the
regulatory capital structure, if any.
REQUEST NO. 31: Please provide the amount of capitalized interest estimated to be paid
during the test year related to construction projects.
REQUEST NO. 32: In electronic format with all formulas intact, please provide VWID
and VUR’s five-year projected and five-year historical capital structure, capital expenditures and
capital funding. Please include a breakdown of all sources of equity capital including retained
earnings, paid-in capital, and debt capital, both long-term and short-term debt, etc.
REQUEST NO. 33: If not already provided, on electronic spreadsheet with all formulas
intact, please provide the calculations of all ratios included on page 2 of Schedule 10. Please
provide all financial statements used to derive these ratios.
REQUEST NO. 34: In electronic format with all formulas intact, please identify the
Commission approved capital structure, cost of capital and rate of return in VWID’s last three
regulatory proceedings. Please identify the docket and order numbers.
REQUEST NO. 35: Please describe how VWID accesses external capital. If the
Company’s external capital is provided by its parent company under a credit agreement, please
describe the terms of the credit agreement and the associated service fees.
REQUEST NO. 36: Please provide the most recent senior secured, unsecured and
corporate credit ratings of VWID and VUR, assigned by S&P, Moody’s, and Fitch. Also, please
provide VWID’s S&P business and financial risk profiles and identify the benchmark volatility

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -7- JANUARY 11, 2023
table (standard, medial or low) used by S&P and the benchmark risk grid (standard or low) used
by Moody’s.
REQUEST NO. 37: To the extent not already provided, please provide in electronic
format with all formulas intact, VWID’s and VUR’s credit metric calculations relied on by S&P
and Moody’s for the last five years and near-term projections if available. Please include all
financial statements used to derive these credit metrics. In addition, please provide S&P and
Moody’s benchmark ranges for the credit metrics.
REQUEST NO. 38: Please state whether VWID’s and VUR’s regulated retail operations
have any goodwill asset on its balance sheet over the period 2017-2022. If affirmative, please
describe the merger and/or acquisition, and any impairment charges the Companies have incurred
in the past.
REQUEST NO. 39: Please state whether VWID’s and VUR’s regulated retail operations
have any off-balance sheet debt such as purchased power agreements and operating leases. If the
answer is “yes,” provide the amount of each off-balance sheet debt item and estimate the related
imputed interest and amortization expense associated with these off-balance sheet debt equivalents
specific to VWID’s jurisdictional regulated retail water operations.
REQUEST NO. 40: Do any of VWID’s outstanding long-term debt issues have call
provisions? If the answer is “yes,” please provide a list of the callable issues with the following:
a. outstanding balance,
b. issuance date,
c. maturity date,
d. coupon payment percent,
e. annual interest expense, and
f. call price (as a percent of par).
REQUEST NO. 41: Has VWID performed any debt refinancing feasibility studies on its
outstanding debt issues? If the answer is “yes,” please provide the following:
a. A detailed description of the results from the study.
b. A detailed description of the conclusions(s) made by VWID based on the results of
the study.
c. All debt refinancing feasibility studies in electronic format with all formulas intact.

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -8- JANUARY 11, 2023
REQUEST NO. 42: Please refer to the Company’s response to Micron Request No. 6.
a. Please identify the number of customers that take service from VWID that satisfy
the definition of an industrial customer, as stated on Company Tariff Sheet No. 36,
paragraph 52 II.
b. Please confirm that in the Company’s class cost of service study supported by
witness Ms. Bui, all customers that satisfy the definition of industrial are included
in the Commercial class. If the response is anything other than an unqualified
confirmation, please provide a detailed explanation supporting the response.
c. Please confirm that Micron Technology, Inc. (“Micron”) satisfies the definition of
an industrial customer, as provided on Company Tariff Sheet No. 36. If the
response is anything other than an unqualified confirmation, please provide a
detailed explanation supporting the response.
d. For each customer that satisfies VWID’s definition of an industrial customer, please
provide the following information. Please note that customers do not need to be
identified, but can simply be numbered as customer 1, customer 2, etc.:
i. Please identify the size(s) and number of meters of each size serving each
customer.
ii. Please identify the size(s) of mains serving each industrial customer.
iii. For each industrial customer served by a main that is less than or equal to
10 inches in diameter, please provide the length of distribution main serving
that customer.
e. For each customer that satisfies VWID’s definition of an industrial customer, please
state whether or not that customer has an AMI meter.
f. Please provide the coincident peaking factors (maximum day and maximum hour)
that would apply to the group of customers that satisfy VWID’s definition of
industrial customer.
g. Please provide the non-coincident peaking factors (maximum day and maximum
hour) that would apply to the group of customers that satisfy VWID’s definition of
industrial customer.
h. To the extent that VWID has one or more customers that satisfy the Company’s
definition of an industrial customer, please provide a detailed explanation as to why
the class cost of service study does not recognize an industrial class. Please provide
all materials supporting the response.
i. To the extent that VWID has one or more customers that satisfy the Company’s
definition of industrial customer, in electronic spreadsheet format with all formulas

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -9- JANUARY 11, 2023
intact, please provide a class cost of service study that includes these customers in
a separate industrial class.
j. Please explain why VWID has not classified any of its customers as industrial, in
accordance with the definition shown on the Company’s Tariff Sheet No. 36.
REQUEST NO. 43: Please identify the top 10 largest customers served by VWID ranked
based on annual water consumption.
REQUEST NO. 44: Is Micron one of the top ten largest customers of VWID in terms of
annual water consumption?
REQUEST NO. 45: Please refer to VWID’s response to Micron Request No. 7, and
VWID’s response to IPUC’s Request No. 41, Attachment 2, Usage Summaries file.
a. Please explain why there are no customers with 8-inch meters included in the file
labeled “Data Request No 41 Attachment 2 – Usage Summaries v2.”
b. Please confirm that the customer(s) described in VWID’s response to Micron
Request No. 7 are included in the Commercial class, for purposes of the class cost
of service study.
REQUEST NO. 46: Does VWID agree that some of its customers (which are currently
included in the Commercial class) are connected directly to the transmission system (i.e., mains
greater than or equal to 12 inches in diameter), and are not served by the mains sized less than
12 inches that comprise the distribution system? If VWID does not agree, please provide a detailed
explanation supporting the response.
REQUEST NO. 47: Please refer to the class cost of service study provided as Exhibit 14-2
of Ms. Bui’s direct testimony.
a. Please confirm that plant investment and expenses associated with transmission and
distribution (“T&D”) mains should be classified to the Base, Max Day, and Max
Hour functions. If not confirmed, please provide a detailed explanation supporting
the response.
b. Please refer to Exhibit 14-2, page 5. Please confirm that expenses associated with
the Maintenance of T&D Mains (Labor, Other, and Fringe Benefits) have been
classified to the Base, Max Day, and Max Hour functions, and have been allocated
on the basis of Factor 6.
c. Please refer to Exhibit 14-2, page 8. Please explain why depreciation expense
associated with Trans. & Distrib. Mains & Accessories has been allocated on
Factor 3, which reflects base and max day, rather than Factor 6, which reflects base,
max day, and max hour components.
d. Please refer to Exhibit 14-2, page 10. Please explain why rate base associated with
Trans. & Distrib. Mains & Accessories has been allocated on Factor 3, which

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -10- JANUARY 11, 2023
reflects base and max day, rather than Factor 6, which reflects base, max day, and
max hour components.
Respectfully submitted January 11, 2023.

HOLLAND & HART, LLP

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

Attorneys for Micron Technology, Inc.

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -11- JANUARY 11, 2023
CERTIFICATE OF SERVICE
I hereby certify that on January 11, 2023, a true and correct copy of the within and
foregoing SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO
VEOLIA WATER IDAHO INC. was served in the manner shown to:

Idaho Public Utilities Commission

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

Ada County

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

Veolia Water Idaho Inc.

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

Veolia Water M & S

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

Micron Technology, Inc.

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

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

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO VEOLIA -12- JANUARY 11, 2023
Sharon Ullman

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

City of Boise City

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

s/ Adele Lee
20669875_v2