20230126Ada County INT 1-25 and RFP 1-15 to VEO.pdf

ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC – PAGE 1
JAN M. BENNETTS
ADA COUNTY PROSECUTING ATTORNEY
Deputy Prosecuting Attorneys
Civil Division
200 W. Front Street, Room 3191
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
ISB Nos. 6362 & 11288
Email: [e-mail]
Attorneys for Intervenor Ada County
IN THE MATTER OF APPLICATION OF
VEOLIA WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO
Intervenor Ada County, by and through its attorneys of record, requests that Veolia Water
Idaho, Inc. provide the following documents and information as soon as possible.
This First Set of Interrogatories and First Set of Production Requests are to be considered
as continuing, and Veolia Water Idaho, Inc. 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 of information produced.
1. The term “Veolia Water Idaho, Inc. or “Veolia,” or “Veolia Water” means Veolia Water
Idaho, Inc. and the employees, officers, directors, agents, consultants, attorneys and all
RECEIVED
Thursday, January 26, 2023 3:04:42 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC – PAGE 2
persons acting under contractual arrangement with or acting or purporting to act on behalf
of Veolia.
2. The term “Documents” should be used in its broadest sense and shall include, but is not
limited to, the originals, or any copies, regardless of origin or location, whether sent or
received, whether made and/or used internally, and both sides thereof, of the following
items, whether printed, recorded, taped, written by hand, typed or reproduced or stored by
mechanical or electronic process: writings, agreements, communications, correspondence,
emails, maps, plans, drawings, sketches, photographs, financial documents, summaries or
records of meetings or conferences, opinions or reports of consultants, book, pamphlet,
periodical publication, scrapbook, diary, calendar, canceled check, form, schedule, tax
return, 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 retrievable matter to which Veolia has or has had access. This definition
includes all documents which have been created and/or which reside in any type of
electronic format.
INTERROGATORIES
INTERROGATORY REQUEST NO. 1: How many existing customers does Veolia
have? Does Veolia own enough water rights, as of the beginning date of this rate case, to serve
existing customers?
INTERROGATORY REQUEST NO. 2. If the answer to Interrogatory Request No. 1 is
yes, please list the water rights and how Veolia has determined that the water rights are sufficient
to service existing customers.
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC – PAGE 3
INTERROGATORY REQUEST NO. 3. After serving existing customers, how much
excess water is available from water rights for future customers.
INTERROGATORY REQUEST NO. 4. If the answer to Interrogatory Request No. 1 is
no, please explain in detail how Veolia obtains sufficient water to serve existing customers and
will obtain sufficient water to serve future customers.
INTERROGATORY REQUEST NO. 5: Please identify the location of Veolia wells as
to each of the three aquifers.
INTERROGATORY REQUEST NO. 6: How frequently are Veolia wells tested for
water quality and what entity tests the water for water quality.
INTERROGATORY REQUEST NO. 7: If any of the Veolia and/or its predecessor Suez
wells has ever exceeded EPA limits for toxins, please list those wells, and explain if the wells are
currently exceeding EPA limits.
INTERROGATORY REQUEST NO. 8: If shareholders have received a distribution
since the acquisition of Suez by Veolia, what was the distribution.
INTERROGATORY REQUEST NO. 9:With your response to Request No. 39 from
the Second Production Request of the Commission Staff, you provided an attachment with a list
of in-service work orders. The first line of this list is labeled ACQ_EAGLE. What does ACQ
EAGLE stand for?
INTERROGATORY REQUEST NO. 10:Which of the other work orders in the list in
response to Request No. 39 are related to the acquisition and/or operation and/or maintenance of
Eagle Water Company that was acquired by Suez/Veolia?
INTERROGATORY REQUEST NO. 11:What percentage of the work orders were
devoted to the Eagle Water system that was acquired by Suez/Veolia?
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC – PAGE 4
INTERROGATORY REQUEST NO. 12:Will the percentage rate increase for this rate
case be the same for all Veolia customer, including past Eagle Water Company customers?
INTERROGATORY REQUEST NO. 13:How have the rates of past Eagle Water
Company customers changed since Suez/Veolia acquired Eagle Water Company?
INTERROGATORY REQUEST NO. 14:In paying for the acquisition of Eagle Water
Company, will past Eagle Water Company customers be charged a higher rate for water in order
to offset what Veolia/Suez paid to acquire Eagle Water Company?
INTERROGATORY REQUEST NO. 15:How many Veolia customers are located
outside the city limits of Boise, including unincorporated Ada County and the city of Eagle?
INTERROGATORY REQUEST NO. 16: Does Veolia have plans to acquire other water
systems in the Treasure Valley?
INTERROGATORY REQUEST NO. 17: In IPUC Request No. 47, Veolia was asked
for operating plans and capital budgets. In response, two tables were presented. Where are the
exact locations of the items listed in table 2 of the response?
INTERROGATORY REQUEST NO. 18: In IPUC Request No. 77, the IPUC asked for
source documents regarding purchased power and other utilities. In response, the Company
provided an excel spreadsheet. That spreadsheet shows power invoices as $112,645. Eagle Water
power is listed separately as $45,340. Why is Eagle Water Power so much more expensive than
the power used in the rest of the system?
INTERROGATORY REQUEST NO. 19: In IPUC Request No. 80, the IPUC asked for
source documents for the additional chemicals for the former Eagle Water service area. Why are
additional chemicals needed for the former Eagle Water service area?
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC – PAGE 5
INTERROGATORY REQUEST NO. 20. In IPUC Request No. 61, the IPUC asked for
the amount of water pumped (gal) by site. The Response in Attachment 3(c) shows that some of
the wells are sporadically producing during the year and some are non-producing during the entire
year. Please explain why some wells only produce water sporadically and please explain why non-
producing wells continue to be listed.
INTERROGATORY REQUEST NO. 21 Does Veolia have any water rights
applications before the Idaho Department of Water Resources?
INTERROGATORY REQUEST NO. 22 If the answer to Interrogatory Request No. 21
is yes, how much water is requested for the water right and what is the status of the application.
INTERROGATORY REQUEST NO. 23:Does Veolia anticipate submitting a water
rights application related to Anderson Ranch Dam?
INTERROGATORY REQUEST NO. 24:Is Veolia participating with the Idaho
Department of Water Resources in the ground water study?
INTERROGATORY REQUEST NO. 25: If the answer to Interrogatory Request No. 24
is no, please explain why Veolia is not involved.
REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST FOR PRODUCTION NO. 1:Please provide all documents that support
your response to Interrogatory Request No. 1.
REQUEST FOR PRODUCTION NO. 2:Please provide all documents that support
your response to Interrogatory Request No. 2.
REQUEST FOR PRODUCTION NO. 3:Please provide all documents that support
your response to Interrogatory Request No. 3.
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC – PAGE 6
REQUEST FOR PRODUCTION NO. 4:Please provide all documents, including
maps, that identify the location of Veolia wells as to each of the three aquifers.
REQUEST FOR PRODUCTION NO. 5:Please provide all documents associated with
the sampling of water quality for Veolia wells, including all water quality sample results and who
is preforming the sampling.
REQUEST FOR PRODUCTION NO. 6:Please provide all documents associated with
exceeded EPA limits for toxins in Veolia wells, including when those exceeded EPA limits were
discovered and remediated.
REQUEST FOR PRODUCTION NO. 7:Please provide all documents that support
your response to Interrogatory Request No. 8.
REQUEST FOR PRODUCTION NO. 8:Please provide all documents associated with
executive salaries before and after the acquisition of Suez.
REQUEST FOR PRODUCTION NO. 9:Please provide all documents that support
your response to Interrogatory Request No. 13.
REQUEST FOR PRODUCTION NO. 10:Please provide all documents that support
your response to Interrogatory Request No. 18.
REQUEST FOR PRODUCTION NO. 11:Please provide all documents that support
your response to Interrogatory Request No. 19.
REQUEST FOR PRODUCTION NO. 12:Please provide all documents that support
your response to Interrogatory Request No. 20.
REQUEST FOR PRODUCTION NO. 13: The IPUC request #48 requested the location
of transmission and distribution pipes that need to be replaced for the next five years. Please
produce a map that shows the location of the pipes that need to be replaced.
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC – PAGE 7
REQUEST FOR PRODUCTION NO. 14:Please provide any applications before the
Idaho Department of Water Resources?
REQUEST FOR PRODUCTION NO. 15: The IPUC request No. 50 asked for a
description of any other infrastructure in the system that would need rehabilitation or replacement
within five years. Please produce a map that shows the location of the infrastructure that would
need rehabilitation or replacement within five years.
th day of January 2023.
JAN M. BENNETTS
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC – PAGE 8
CERTIFICATE OF SERVICE
I hereby certify that on the 26th day of January 2023, I served the foregoing document on
all parties as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201A
P.O. Box 83720
Boise, ID 83720
X Electronic Means w/ Consent
[e-mail]
[e-mail]
Chris Burdin
Dayn Hardie
Deputy Attorney’s General
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Bldg. No. 8
PO Box 83720
Boise, ID 83720-0074
X Electronic Means w/ Consent
[e-mail]
[e-mail]
Preston N. Carter
Morgan Goodin
SUEZ Water Idaho Inc.
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
X Electronic Means w/ Consent
[e-mail]
[e-mail]
[e-mail]
David Njuguna
Veolia Water M&S Inc.
461 From Road, Suite 400
Paramus, NJ 07052
X Electronic Means w/ Consent
[e-mail]
Mary Grant
Deputy City Attorney
Boise City Attorney’s office
105 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
X Electronic Means w/ Consent
[e-mail]
[e-mail]
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
X Electronic Means w/ Consent
[e-mail]

ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC – PAGE 9
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
X Electronic Means w/ Consent
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Sharon Ullman, Pro Se
5991 E. Black Gold Street
Boise, ID 83716
X Electronic Means w/ Consent
[e-mail]
By: ______/s/ Monica M. Devroude_________
Monica M. Devroude, Legal Assistant