20230202Veolia to Micron 23-47(Second Set).pdf

VEOLIA WATER IDAHO, INC.’S RESPONSES TO MICRON’S SECOND SET OF DISCOVERY PAGE 1 OF 3
16572030_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 MICRON’S SECOND SET
OF DISCOVERY REQUESTS
Veolia Water Idaho, Inc. (“Veolia” or “Company”), in response to Micron’s Second Set
of Discovery Requests to Veolia Water Idaho, Inc. dated January 11, 2023, submits the non-
confidential responses set forth below. Response documents are available for download at the
link provided in the transmittal email. Confidential responses and documents will be provided
separately under the terms of the Protective Agreement.
DATED: February 1, 2023.

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

RECEIVED
Wednesday, February 1, 2023 4:43:46 PM
IDAHO PUBLIC
UTILITIES COMMISSION
VEOLIA WATER IDAHO, INC.’S RESPONSES TO MICRON’S SECOND SET OF DISCOVERY PAGE 2 OF 3
16572030_1.DOCX (30-235)
CERTIFICATE OF SERVICE

I certify that on February 1, 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 MICRON’S SECOND SET OF DISCOVERY PAGE 3 OF 3
16572030_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
VEO-W-22-02
MICRON DR 23
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Walker 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.

RESPONSE NO. 23:
Please see attachment provided in response to fourth production request of the
Commission Staff No. 149 for the requested information.
VEO-W-22-02
MICRON DR 24
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Walker 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.

RESPONSE NO. 24:
Attached is the requested information.
VEO-W-22-02
MICRON DR 25
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna 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.

RESPONSE NO. 25:
Please see the response to request no. 24 and the attachment to this response for credit
reports published by Standard & Poor’s issued over the last two years for Veolia Utility
Resources, Inc. No credit reports are issued for Veolia Water Idaho, Inc.
VEO-W-22-02
MICRON DR 26
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna 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 industry as reviewed by
any VWID witness. If VWID witnesses have not reviewed the material, please so state. This is
an ongoing request.

RESPONSE NO. 26:
See the response to Request No. 24. In the preparation of testimony in this case, other
Company witnesses did not review such documents.

VEO-W-22-02
MICRON DR 29
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Cagle/Jacob 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.

RESPONSE NO. 29:
Please see below VWID’s Capital expenditure to 2026 also as provided in response to
IPUC DR 40.

We employ cash pooling as one of our primary centralized cash management techniques.
Debt financing is done at the VUR consolidated level and the parent entity distributes liquidity to
better serve the interests of each business unit (such as Idaho).
Regarding sources of cash available to fund the above capital expenditures, please refer
to the answer to Micron Request number 32.
VEO-W-22-02
MICRON DR 30
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna 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.

RESPONSE NO. 30:
Please see below the monthly average balance for construction work in progress (CWIP)
for the 13 months ended December 31, 2022.
No short-term debt is included in the regulatory capital structure.

VEO-W-22-02
MICRON DR 31
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Cagle REQUEST NO. 31:
Please provide the amount of capitalized interest estimated to be paid during the test year
related to construction projects.

RESPONSE NO. 31:
Please see the response to request nos. 29 and 40. Debt financing is done at VUR and funds
provided to Idaho through cash pooling.
VEO-W-22-02
MICRON DR 33
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna 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.

RESPONSE NO. 33:
Please see revenue requirement work papers provided to the Idaho Public Utilities
Commission in excel format with all formula intact.

VEO-W-22-02
MICRON DR 34
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna 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.

RESPONSE NO. 34:
The orders from the last three regulatory proceedings did not specify the information
requested.
VEO-W-22-02
MICRON DR 35
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Cagle 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.

RESPONSE NO. 35:
Please see the response to request no. 29. VWID does not utilize a credit agreement with
its parent Company.
VEO-W-22-02
MICRON DR 36
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Cagle 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 table (standard, medial
or low) used by S&P and the benchmark risk grid (standard or low) used by Moody’s.

RESPONSE NO. 36:
Credit ratings are at the VUR level, and the company only uses S&P. Please see the
request nos. 24 and 25. The company does not have other S&P information requested.
VEO-W-22-02
MICRON DR 37
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Cagle 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.

RESPONSE NO. 37:
N/A. Please also see the response to request no. 36.
VEO-W-22-02
MICRON DR 38
Page 1 of 2
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Jacob 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.

RESPONSE NO. 38:
VWID does not have any goodwill asset on its balance sheet over the period 2017-2022.
Consolidated VUR has the following goodwill asset balances on its balance sheet over the period
2017-2022.
(in thousands USD)
12/31/2017 $39,947
12/31/2018 $39,947
12/31/2019 $40,380
12/31/2020 $41,967
12/31/2021 $41,468
12/31/2022 $45,601

The balance of goodwill as of 12/31/2017 consisted of the following (in thousands USD):
1. $37,361 of goodwill related to United Water Resources, Inc.’s acquisition of
General Waterworks Corporation.
2. $2,586 of goodwill related to United Water Resources, Inc.’s acquisition of
Aquarion Water Company of New York, Inc.

VEO-W-22-02
MICRON DR 38
Page 2 of 2
Since 2017, VUR’s regulated retail operations had the following acquisitions that resulted in
goodwill balances to be recorded on its balance sheet (in thousands USD):
1. Veolia Water New Jersey, Inc. acquired SB W&S Corp. resulting in an increase to goodwill
of $433.
2. Veolia Water New York, Inc. acquired Heritage Hill Water Works Corporation resulting
in an increase to goodwill of $639.
3. VWID acquired Eagle Water Company, Inc., resulting in an increase to goodwill of $701.
4. Veolia Water New Jersey, Inc. acquired the water system of the Borough of Allendale,
resulting in an increase to goodwill of $3,881K.
There have been no goodwill related impairment charges incurred by VWID’s and VUR’s
regulated retail operations between 2017-2022.
VEO-W-22-02
MICRON DR 39
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Jacob 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.

RESPONSE NO. 39:
All leases related to VWID’s and VUR’s regulated retail operations are recorded on the
balance sheet in accordance with ASC 842. Please refer to Request No. 28 for VUR’s
consolidated financial statements and notes to financial statements discussing the off-balance
sheet debt.
There are no purchased power agreements specific to VWID’s jurisdictional regulated
retail water operations. VWID has performance/bid bonds totaling $35,000 as of 12/31/2021.
These performance/bid bonds would only result in a liability in the event of non-performance
and therefore there is no related imputed interest and amortization expense.

VEO-W-22-02
MICRON DR 40
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna 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).

RESPONSE NO. 40:
VWID does not have long-term debt issuances.

VEO-W-22-02
MICRON DR 41
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Njuguna 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.

RESPONSE NO. 41:
Please see the response to request no. 40. VWID currently does not have outstanding
debt.
VEO-W-22-02
MICRON DR 42
Page 1 of 3
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Thompson/Cary 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.
VEO-W-22-02
MICRON DR 42
Page 2 of 3
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 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.

RESPONSE NO. 42:
a. N/A
b. N/A
c. Please see Sheet No. 36, Paragraph 52 I and II whereby a commercial customer and an industrial
customer are defined respectively, as follows:
i. Commercial customer shall designate:
1. A building containing two or more apartments or family units, which are
rented or leased to tenants.
2. A building occupied by a retail or service business which does not
manufacture any item or items on the premises
3. Any building containing any combination of 'A' and 'B' above.
4. A hotel, motel, tourist court, trailer court or mobile home park which
rents or leases rooms or spaces to tenants.
ii. Industrial customer shall designate any building or combination of buildings in
the same compound whose primary use is for the manufacture, fabrication,
and/or assembly of any product.
To be designated as an Industrial customer, the use of water must be primarily
for the manufacture, fabrication, and/or assembly of any product. No customer
has designated any building or combination of buildings in the same compound
VEO-W-22-02
MICRON DR 42
Page 3 of 3
whose primary use is for the manufacture, fabrication, and/or assembly of any
product. Currently, it is the Company's understanding Micron's water use from
VWID is primarily for office space as well as fire protection and therefore does
not fit the definition of an industrial customer but does fit the definition of a
commercial customer under Paragraph 52 I 'B'.
d.
i. i N/A
ii. N/A
iii. N/A
e. N/A
f. N/A
g. N/A
h. N/A
i. N/A
j. See the response to Item C. above.
VEO-W-22-02
MICRON DR 43
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Cary REQUEST NO. 43:
Please identify the top 10 largest customers served by VWID ranked based on annual water
consumption.

RESPONSE NO. 43:
As a matter of customers’ privacy, VWID is not able to identify specific customers nor
their annual water consumption.
VEO-W-22-02
MICRON DR 44
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Cary REQUEST NO. 44:
Is Micron one of the top ten largest customers of VWID in terms of annual water
consumption?

RESPONSE NO. 44:
Yes.

VEO-W-22-02
MICRON DR 45
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Bui 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. RESPONSE NO. 45:
a. Billing data for the two 8-inch meters is included in Excel file Usage Summaries
v2.xlsm. In the original billing reports, the meter size shows as 2-inch, which the
Company confirmed is incorrect.
b. Of the two 8-inch meters operational during the study timeframe, one was included in
the final selection set of representative (Commercial) AMI customer meters for the
Load Study. Micron is classified as a commercial customer according to the
Company’s records.

VEO-W-22-02
MICRON DR 46
Page 1 of 1
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Cooper 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.

RESPONSE NO. 46:
VWID does not agree on this characterization of specific customer connection to system
transmission capacity based solely on mainline size.
VWID has customers of all classes - commercial and residential - connected to mainlines
of varying diameters and function including those greater than or equal to 12 inches in diameter
and those smaller than 12 inches in diameter.

VEO-W-22-02
MICRON DR 47
Page 1 of 2
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
MICRON’S SECOND SET OF DISCOVERY REQUESTS TO VEOLIA WATER IDAHO INC
Preparer/Sponsoring Witness: Bui 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
reflects base and max day, rather than Factor 6, which reflects base, max day, and
max hour components.
RESPONSE NO. 47:
a. Yes, we are confirming that plant investment and expenses associated with
transmission and distribution mains should be classified to the Base, Max Day and
Max Hour, as appropriate.
b. This is an error. Exhibit 14-2, page 5 has been revised to reflect the separation of
transmission and distribution. Transmission and distribution have been separated
using the total inch-feet of main analysis shown in Factor 6. Based on the revised
VEO-W-22-02
MICRON DR 47
Page 2 of 2
Exhibit 14-2, transmission has been allocated based on Factor 3 while distribution
has been allocated based on Factor 6.
c. Exhibit 14-2, page 8 has been revised to reflect the separation of transmission and
distribution, as described in (b). Exhibit 14-2, page 10 has been revised to reflect
the separation of transmission and distribution, as described in (b).