20230123Veolia Water to Staff 152-158.pdf

VEOLIA WATER IDAHO, INC.’S RESPONSES TO FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 1 OF 3
16587731_1.DOCX (30-235)
Preston N. Carter, ISB No. 8462
Blake W. Ringer, ISB N. 11223
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 FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF
In response to the Fifth Production Request of the Commission Staff to Veolia Water
Idaho, Inc. dated January 9, 2023, Veolia Water Idaho, Inc. (“Veolia” or “Company”), submits
the non-confidential responses contained below.
DATED: January 23, 2023.

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

RECEIVED
Monday, January 23, 2023 3:07:15 PM
IDAHO PUBLIC
UTILITIES COMMISSION
VEOLIA WATER IDAHO, INC.’S RESPONSES TO FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 3
16587731_1.DOCX (30-235)
CERTIFICATE OF SERVICE

I certify that on January 23, 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]

VEOLIA WATER IDAHO, INC.’S RESPONSES TO FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 3 OF 3
16587731_1.DOCX (30-235)

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]

Preston N. Carter
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bui REQUEST NO. 152:
Please respond to the following in 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 (including all workpapers with formula intact) that
justifies the Company’s contention that “all customer classes peak at close to the
same time (coincident peaking).”

RESPONSE NO. 152:
a. The System Maximum Day ratio used in the analysis was based on the maximum water
production day over the last ten years as presented in Exhibit 14-F1. The Load Study
generated a System Maximum Day ratio based on usage (billing records) for a period of one-
year. The expectation is that the two approaches should be close from a system perspective,
yet the ten-year data provides a wider lens on system behavior and therefore it is used in the

VEO-W-22-02
IPUC DR 152
Page 1 of 2
analysis.
b. The average day and average hour (i.e., the denominators of the peaking ratios) are based on
2021 annual consumption data as documented in Worksheet
qry_2020_2021AccountsByMonth.sq in Excel Workbook Usage Summaries v2.xlsx. Cells
AV23:AV25 contain the average daily consumption values per account, and cells
AV29:AV31 contain the average hourly consumption per account. The value is multiplied by
the respective number of accounts to generate the Avg. Day demand in cells S47:S49 and the
Avg. Hourly demand in cells V47:V49 in Worksheet Summary Results in Excel Workbook
VWID Load Study Results.xlsx.
c. The ten-year system maximum day is based on calendar years 2012 to 2021. The data used in
the Load Study represented 2021.
d. Veolia has always suggested conservation measures in public media advertisements, social media and bill
inserts. There is a higher cost for water use over base usage in the summer to promote conservation.
However, there are no required conservation measures in place for customers.
e. As demonstrated in the Load Study, Appendix B, the residential and commercial customer
classes coincidentally peaked between the hours of 8 pm and 8 am.
VEO-W-22-02
IPUC DR 152
Page 2 of 2
VEO-W-22-02 IPUC DR 153 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bui

REQUEST NO. 153:
In Bui's Direct Testimony, page 8, Bui states: "the reviewed data showed no customer
classes or groups exhibiting significantly different usage patterns." Please identify the specific
information in the Load Study and provide the analysis that justifies this statement.

RESPONSE NO. 153:
The data review showed that the existing customer classes exhibited similar usage
patterns as demonstrated in the Load Study, Appendix B. Peaking for these customer classes
typically occurred between the hours of 8 pm to 8 am. Appendix B identifies the residential,
commercial, and public authority customer classes and overlays the total system pattern.
VEO-W-22-02 IPUC DR 154 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bui

REQUEST NO. 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 justify that the Company's currently
defined customers are the appropriate customer classifications.

RESPONSE NO. 154:
The Company currently has established customer classes of Residential,
Commercial, and Industrial, Public Authority, and Fire Protection. Such a classification
system is consistent with typical water utility practice and norms and as suggested by
AWWA Manual M1 Principles of Water Rates, Fees, and Charges. Based on the
existing definition of industrial customers per the Company’s rate schedule, it is
understood that no customers currently meet this definition.
The scope of the Load Study examined the available data for customers in the
Company’s billing system. Obtaining additional information on customer characteristics
(e.g., the size of a residential lot) was beyond the scope of the study. Thus, the analysis
conducted was limited to readily available customer billing information.
VWID’s current classification of customers is appropriate and reflects industry
norms. It represents a suitable balance between a fair segmentation of customers based
on broad similarities in customer characteristics and administratively complex
additional data capture and maintenance requirements.
VEO-W-22-02 IPUC DR 155 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bui

REQUEST NO. 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 the data used for each.

RESPONSE NO. 155:
As noted in our Response to Request No. 154, the Load Study’s scope was
limited to examining available billing records. Due to privacy concerns, customer data
records only included account or meter number identifiers. No other identifying (i.e.,
account holder name) information was provided. The analyses conducted in the Load
Study did parse data by meter size overall, and by existing customer classes, but no
additional classifications emerged.
The Company’s existing customer classifications appear reasonable based on
water utility practices and norms across North America, as noted in response to Request
No. 154.
VEO-W-22-02 IPUC DR 156 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bui/Thompson

REQUEST NO. 156:
Please explain why the Load Study did not collect data that could be used to
identify other potential consumptive customer classes.

RESPONSE NO. 156:
During the development of the Load Study, there were discussions regarding some
customers having access to irrigation ditches. No specific information was available for
review at the customer-level to analyze the impact of the presence of such an alternative
irrigation source. To do so, the Company would need to first identify all residential
customers with access to alternative water sources. This information was not available, and
we note that the presence or absence of an alternative irrigation source is not determinative
of how a customer may use water provided by the Company.
Collecting detailed classification data at the customer level, beyond what the
Company already collects and maintains, requires a significant effort and was beyond the
scope of the current Load Study in terms of time and resources, and was not deemed to be
necessary given the available data.

VEO-W-22-02 IPUC DR 157 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bui

REQUEST NO. 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.

RESPONSE NO. 157:
a. Based on the updated cost of service analysis, it was deemed that fire demands should
reflect the actual fire demands that can occur throughout the service area. The service
area has designated fire flow requirements based on the type of customers served. Based
on these requirements, three (3) fires occurring simultaneously were selected as the
appropriate fire flow demand for fire protection. The three fires consist of one 4-hour,
4,500 gpm fire, one 4-hour, 4,000 gpm fire, and one 2-hour 1,500 gpm fire. Prior filings
used a 10-hour, 10,000 gpm fire, which when applied in the cost-of-service analysis
means a single fire that lasts 10 hours and required 10,000 gpm of fire flow. It was Black
& Veatch’s opinion that in reality, the system would not see such an occurrence, but
could experience 3 simultaneous fires.
b. Private fire customers were not included in the Load Study as these customers do not
consume water in a similar manner as other customers. Private fire consumption only
occurs during fire events; therefore, consumption data is inconsistent to determine
peaking factors.
VEO-W-22-02 IPUC DR 158 Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Bui

REQUEST NO. 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.

RESPONSE NO. 158:
The AMI data provided to Black & Veatch for analysis was from 8/4/2019 to 12/31/2021.
The count of customers (i.e., number of meters) with AMI data available for analysis (as
shown in Table 1-1 on p7 of the Load Study) is derived from the AMI data provided to Black &
Veatch for analysis.