20230207Veolia to Staff No. 163.pdf

VEOLIA WATER IDAHO, INC.’S RESPONSES TO SIXTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 1 OF 3
16611042_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 SIXTH PRODUCTION
REQUEST OF THE COMMISSION STAFF
In response to the Sixth Production Request of the Commission Staff to Veolia Water
Idaho, Inc. dated January 25, 2023, Veolia Water Idaho, Inc. (“Veolia” or “Company”), submits
the non-confidential responses contained below. Documents are available for download at the
link provided in the transmittal email.
DATED: February 7, 2023.

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

RECEIVED
Tuesday, February 7, 2023 12:37:56 PM
IDAHO PUBLIC
UTILITIES COMMISSION
VEOLIA WATER IDAHO, INC.’S RESPONSES TO SIXTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 3
16611042_1.DOCX (30-235)
CERTIFICATE OF SERVICE

I certify that on February 7, 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 SIXTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 3 OF 3
16611042_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 IPUC DR 163 Page 1 of 1
VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cary/Michaelson

REQUEST NO. 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 determined the 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.

RESPONSE NO. 163:
5. Interim response to the request:
Staff clarified its request via email and requested certain interim information be provided
which are components of the requested analyses. This clarification was: “We would like
the full update to the workpapers using a 2022 test year (1/1/2022 through 12/31/2022)
with no customer growth adjustment beyond December 31, 2022 and the customer
growth adjustment from January 1, 2023 through March 31, 2023, broken out
separately. We understanding that to provide a full update may require the full 3-weeks,
although we would like to get it as soon as possible”.

Given the understanding that some of the information can be provided earlier because it is
currently available, please provide the following as early as possible:
VEO-W-22-02 IPUC DR 163 Page 2 of 1

1. Columns B, C, and D for a 2022 Test Year (1/1/2022 through 12/31/2022) as
shown in Worksheet: “Exhibit 5 Schedule 2.”
2. Actual Data by customer class for the following:
a. Billed Volumes for months July 2022 through December 2022 in
Worksheet: “Billed Volumes”
b. Customer Counts by Cycle for months July 2022 through December 2022
in Worksheet: “Customer Count by Cycle”
c. Total Customer Counts for months July 2022 through December 2022 in
Worksheet: “Total Customer Count”
d. Number of customers on 1/1/22 and 12/31/22 for Eagle Water by customer
class in Worksheet: “Exhibit 5 Sched 4 Eagle”

INTERIM RESPONSE
1. Please, see attachment 1
2. Please see attachment 2