20230125Staff 159-163 to Veolia.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 '
s 310N
[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-22-02
VEOLIA WATER IDAHO,INC.FOR A )GENERAL RATE CASE )
)SIXTH 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 AttorneyGeneral,requests that Veolia Water Idaho,Inc.provide the
followingdocuments and information as soon as possible,but no later than WEDNESDAY,
FEBRUARY 1,2023.1
This Production Request is to be considered as continuing,and Veolia is requested to
provide,by way of supplementary responses,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's
attorney at [phone].
SIXTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 1 JANUARY 25,2023
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.159:Please identifyany procurement starting October 1,2022,through
the period up to the current date,where the procurement was not compliant with the SUEZ North
American Inc.Procurement Policy (Revised July 2020).In each case,please explain why it was
not compliant and provide all Company documentation used to justify moving forward with the
procurement even though it was not compliant.
REQUESTNO.160:Please provide the followingdocumentation for each capital
project with a budget amount of $300,000 or more that was placed in service beginning October
1,2022,through the period up to the current date that the Company is seeking recovery in this
case.For any requested information not provided,please explain why it was not provided,and
how the Company assured that the construction of the project was completed at least cost to
ratepayers.
a.A full description of the work completed for each project.
b.Analysis of Need -a justification of need for each project along with a cost/benefit
analysis comparison of the alternatives.
c.Project Plan including:
i.Initial project scope
ii.Proposed budget
iii.Proposed schedule.
d.Documentation supporting competitive bidding practices including:
i.Company's completed Procurement Review Form ("PRF")
ii.Requests for proposals ("RFP")including:
1.Project requirements
2.Specifications.
iii.Short list bidder scorecard
iv.RFP from winningbid.
e.Project construction documentationincluding:
i.Construction contract
ii.Organizational chart
iii.Scope document
iv.Work breakdown structure
SIXTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 2 JANUARY 25,2023
v.Baseline Schedule
vi.Monthlyproject status report(s)
vii.Project action items list(s)
viii.Contractors change order request(s).
f.Company project completion analysis including:
i.Lessons learned
ii.Budget-to-actual comparisons for the overall project,by work breakdown
structure,and by year
iii.Baseline schedule-to-actual schedule comparison.
REQUESTNO.161:For the followingitems included in the Company's rate base
calculations,please provide the balances for the months ended December 31,2021;January 31,
2022;and February 28,2022.
a.Accumulated Deferred Income Taxes
b.Deferred Charges
c.Regulatory Liability-TCJA
d.Working Capital
REQUESTNO.162:Please update the Deferred Power with actual power costs to
December 31,2022.
REQUESTNO.163:Please explain the customer meter mis-read errors that occurred
during calendar year 2022.In addition,please provide:
1.The causes of the issue and the Company's corrective actions.
2.The timeframe and specific months that actual consumption data was impacted.
3.Any corrections that need to be made or have already been made to actual
consumption data for each month from January 1,2022,through December 31,2022.
4.A detailed explanation how the Company determinedthe amount of the corrections
for each month.
5.The Company's final actual customer counts and customer consumption from January
1,2022,through December 31,2022,by updating the Company's workpaper file
"VEO-W-22-02 Revenue Exhibits -Workpapers to IPUC STAFF,"provided in
electronic format with all formula enabled.
SIXTH PRODUCTION REQUEST
TO VEOLIA WATER IDAHO 3 JANUARY 25,2023
DATED at Boise,Idaho,this 25 day of January 2023.
Chris Burdin
Deputy Attorney General
i:umisc:prodreq/veow22.2cbrk prod reg 6
SIXTH PRODUCTIONREQUEST
TO VEOLIA WATER IDAHO 4 JANUARY 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF JANUARY 2023,
SERVED THE FOREGOING SIXTH 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:[e-mail]
[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:sharonu2013 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:iswier micron.co 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]
[e-mail]
SECRETAR
CERTIFICATE OF SERVICE