20230217Veolia to Ada Co. Resp INT 1-25 and RFP 1-15.pdf

VEOLIA WATER IDAHO,INC.’S RESPONSES TO ADA COUNTY’S FIRST
SET OF INTERROGATORIES AND PRODUCTION REQUESTS PAGE 1 OF 3
16596973_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 ADA COUNTY’S FIRST SET
OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS
In response to Ada County’s First Set of Interrogatories and First Set of Production
Requests to Veolia Water Idaho, Inc. dated January 26, 2023, Veolia Water Idaho, Inc. (“Veolia”
or “Company”), submits the non-confidential responses contained below.
DATED: February 16, 2023.
By:_____________________________
Preston N. Carter
Givens Pursley LLP
Attorneys for Veolia Water Idaho, Inc.
RECEIVED
2023 FEB – 16 PM 2:12
IDAHO PUBLIC
UTILITIES COMMISSION
VEOLIA WATER IDAHO, INC.’S RESPONSES TO ADA COUNTY’S FIRST
SET OF INTERROGATORIES AND PRODUCTION REQUESTS PAGE 2 OF 3
16596973_1.DOCX (30-235)
CERTIFICATE OF SERVICE

I certify that on February 16, 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 ADA COUNTY’S FIRST
SET OF INTERROGATORIES AND PRODUCTION REQUESTS PAGE 3 OF 3
16596973_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
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary/Cooper
INTERROGATORY 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?
RESPONSE TO INTERROGATORY NO. 1:
Existing Customers: As of January 24, 2023 Veolia Idaho has 105,413 Active Service
Agreements. A customer may have multiple service agreements. A customer may have one
service agreement for Commercial water service for multiple service addresses and a second
service agreement for Private Fire Protection. For all intents and purposes this is the count that
Veolia tracks to represent a count of customers.
Water Rights: Veolia has an extensive water right portfolio. Between water rights and
storage that Veolia owns and purchased water, Veolia has enough water supply to serve existing
customers.
VEO-W-22-02
Ada Interogatory 1
Page 1 of 1
VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
INTERROGATORY 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.
RESPONSE TO INTERROGATORY NO. 2:
Veolia refers the County to both the listing of Veolia’s water rights that is publicly
available on the Idaho Department of Water Resources (IDWR) website, and the purchased
water exhibit included with its initial rate case filing.
Veolia’s existing water rights can be found on the IDWR water right search website at
this link: https://research.idwr.idaho.gov/apps/waterrights/wrajsearch/wradjsearch.aspx
Alternatively, there is a summary spreadsheet in the Integrated Municipal Application
Package (IMAP) filing, which can be found at this link (link to all IMAP documents):
https://idwr.idaho.gov/legal-actions/administrative-actions/suez-water-idaho-inc-imap/
Specifically, starting on PDF page 73 of this attachment: https://idwr.idaho.gov/wp-
content/uploads/sites/2/legal/suez-water-idaho-imap/IMAP-20201130-SUEZs-Response-to-
IDWRs-Staff-Memo.pdf
The purchased water exhibit can be found in Veolia’s initial submittals to the Idaho
Public Utilities Commission (IPUC), Exhibit No. 10, Adjustment No. 9, Schedule 1.
Veolia knows that these water rights are sufficient to serve existing customers in two
ways: 1) Veolia has enough water to meet customer demands year to year, 2) Veolia calculates
projected water needs into the future and obtains additional water rights based on those
projections (calculations are presented in detail in the IMAP documents linked above).
VEO-W-22-02
Ada Interogatory 2
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
INTERROGATORY NO. 3:
After serving existing customers, how much excess water is available from water rights
for future customers.
RESPONSE TO INTERROGATORY NO. 3:
This is a complicated question that Veolia; in this response Veolia will attempt to provide
a straightforward answer, but please understand that this is a summary, good-faith attempt to
respond to the question. The response will necessarily lack some of the detail and nuance that
this subject-matter would typically entail.
Recent maximum demands / diversion rates for the Veolia system are about 175 cfs. Its
total water right portfolio as reported in IMAP is 330.58 cfs (Table 5, Page 32, Suez’s Response
to IDWR’s Staff Memo by Michael P. Lawrence, November 30, 2020, link to the document:
https://idwr.idaho.gov/wp-content/uploads/sites/2/legal/suez-water-idaho-imap/IMAP-20201130-
SUEZs-Response-to-IDWRs-Staff-Memo.pdf).
Based on factors identified below, Veolia estimated that existing water rights have the
capacity to serve between 52,706 and 93,715 additional connections under current usage
patterns.
Calculating the high end number of additional customers that could be served, would be
330.58 cfs - 175 cfs available, or 155.58 cfs. This means that Veolia could almost double the
current number of customers based on existing water rights, or more precisely, serve an
additional 155.58/175*105,413 = another 93,715 connections.
Calculating the low end number of additional customers that could be served by
removing the Snake River exchange (11 cfs) and junior priority Boise River rights (24.8 cfs and
VEO-W-22-02
Ada Interogatory 3
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35.21 cfs) that are not necessarily available in all water years, or at all times of the year, leaves
330.58 cfs - 11 cfs - 24.8 cfs - 35.21 cfs = 259.57 cfs diversion rate - 175 cfs = 84.57 cfs. This
would mean that Veolia could add about another 50% of customers currently served, or an
additional 105,413 / 2 = 52,706 connections.
VEO-W-22-02
Ada Interogatory 3
Page 2 of 2
VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
INTERROGATORY 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.
RESPONSE TO INTERROGATORY NO. 4:
Not Applicable.
VEO-W-22-02
Ada Interogatory 4
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
INTERROGATORY NO. 5:
Please identify the location of Veolia wells as to each of the three aquifers.
RESPONSE TO INTERROGATORY NO. 5:
A full listing of Veolia’s wells is detailed in Commission Staff Production Request
No. 36.
The location and relationship of wells to the Treasure Valley Aquifer system (in addition
to well logs with depths) can be found on the Idaho Department of Water Resources web site at
the following link: https://idwr.idaho.gov/wells/find-a-well-map/
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
INTERROGATORY NO. 6:
How frequently are Veolia wells tested for water quality and what entity tests the water
for water quality.
RESPONSE TO INTERROGATORY NO. 6:
The water quality testing frequency for Veolia wells varies based on its monitoring
history and Department of Environmental Quality (DEQ) Source Water Assessments. Veolia
meets all DEQ regulatory monitoring requirements based on the schedule DEQ sets. Sample
schedules vary from quarterly, to annually, to every 3, 6 or 9 years.
The laboratories Veolia uses for water quality testing are all certified by the State of
Idaho and include: Analytical Laboratories, Anatek, Eurofins, & Pace Analytical.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
INTERROGATORY 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.
RESPONSE TO INTERROGATORY NO. 7:
The Veolia/Suez wells have not exceeded any legal limits set by EPA for drinking water
contaminants/toxins.
VEO-W-22-02
Ada Interogatory 7
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cagle
INTERROGATORY NO. 8:
If shareholders have received a distribution since the acquisition of Suez by Veolia, what
was the distribution.
RESPONSE TO INTERROGATORY NO. 8:
Veolia has made no dividend distribution since the closing of the transaction.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
INTERROGATORY 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?
RESPONSE TO INTERROGATORY NO. 9:
ACQ_EAGLE stands for the Eagle Water Company Acquisition. This label was used to
track assets for the Eagle Water Company Acquisition.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
INTERROGATORY 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?
RESPONSE TO INTERROGATORY NO. 10:
Work orders on the list in Attachment 39 that are related to Eagle Water Company
include the following. Please note that these are all capital improvement projects, not O&M.
C21K104_060_001 EWC - UDF
C21K104_060_002 EWC - Hydraulic Model
C21K107_060_001 Disinfection Study
C22C501_060_002 EWC Well 6 Driveway
C22C514_060_002 EWC CL2 Installations
C22C514_060_002 Yard Bstr Flow Cntrl Valve
C22C514_060_005 Well 6 VFD Replacement
C22A104 EWC Water Right Transfers
C22C514 EWC Production Roll-Up
C22D611 EWC T&D Main Replacements
C22K103 Map EWC System
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
INTERROGATORY NO. 11:
What percentage of the work orders were devoted to the Eagle Water system that was
acquired by Suez/Veolia?
RESPONSE TO INTERROGATORY NO. 11:
Of the full listing of 421 work orders in Production Request 39, a total of 12 were
devoted to the Eagle Water system.
The percentage of work orders would then be = 12 / 421 * 100 = 2.85 percent.
VEO-W-22-02
Ada Interogatory 11
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Michaelson
INTERROGATORY NO. 12:
Will the percentage rate increase for this rate case be the same for all Veolia customer,
including past Eagle Water Company customers?
RESPONSE TO INTERROGATORY NO. 12:
No. Please refer to the testimony of Company witness Bui which describes the Cost of
Service Study results and rationale for revenue allocation to the different customer classes.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
INTERROGATORY NO. 13:
How have the rates of past Eagle Water Company customers changed since Suez/Veolia
acquired Eagle Water Company?
RESPONSE TO INTERROGATORY NO. 13:
In accordance with Commission Order No. 35247 in the joint Case Nos. SUZ-W-18-02
and EAG-W-18-01 approving the acquisition, former Eagle Water Company customer rates
changed from existing Eagle Water Company’s tariff rates to 50% of the Company’s established
rates as of January 1, 2022 and those rates will continue to be phased-in to full rates over 7 years
(increase by 8.33% annually on January 1st) until January 1, 2028 when full rates will be in
effect for those customers. In its application in this case, the Company proposed that rates for the
former Eagle Water Company increase by the same percentage as other customers.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cagle
INTERROGATORY 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?
RESPONSE TO INTERROGATORY NO. 14:
Customers of Eagle Water Company will be charged rates in keeping with the
Commission’s Order in Case Nos. SUZ-W-18-02 and EAG-W-18-01. Please see the Stipulation
and Settlement (Dated 10/8/2021), the Stipulation and Settlement Exhibit 1 (dated 10/13/2021),
and the Final Order (Dated 12/9/2021). Such documents can be found at
https://puc.idaho.gov/Case/Details/3610. Other case related documents are also available at the
same link.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
INTERROGATORY NO. 15:
How many Veolia customers are located outside the city limits of Boise, including
unincorporated Ada County and the city of Eagle?
RESPONSE TO INTERROGATORY NO. 15:
The count of Active Service Agreements (customer count equivalent) based on service
address premise Locations and municipal boundaries as of February 1, 2023 is as follows:
City of Boise 81,161
City of Eagle 8,388
City of Meridian 937
Ada County 14,632
Total 105,118
Outside City of Boise limits 23,957
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Thompson
INTERROGATORY NO. 16:
Does Veolia have plans to acquire other water systems in the Treasure Valley?
RESPONSE TO INTERROGATORY NO. 16:
Veolia is always willing to consider acquiring water systems, however Veolia does not
have any definitive plans at this time to acquire other water systems in the Treasure Valley.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
INTERROGATORY 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?
RESPONSE INTERROGATORY NO. 17:
These are recurring network and blanket projects. The exact location of work varies.
East First Bench Main Replacements - recurring project to replace aged and undersized mains in
the East First Bench.
T&D Main Replacements - recurring project to replace aged and undersized mains across the
system.
EWC T&D Main Replacements - recurring project to replace aged and undersized mains in the
Eagle Water Company area.
Agency Mains - recurring project to replace mains associated with ACHD (Ada County Highway
District), ITD (Idaho Transportation Department), CCDC (Capital City Development Corp), and
other agency projects.
Fire Hydrants - blanket project - new and replacement hydrants across the system.
New Short Mains and Valves - blanket project - installs short sections of new main and valves
across the system
Replacement Short Mains and Valves/Blow-Offs - blanket project - replaces short sections of
main and valves/blow-offs across the system
T&D Valve Replacements - blanket project - replace aged/broken valves across the system.
VEO-W-22-02
Ada Interogatory 17
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Domestic Services - blanket project - new and replacement services across the system.
Customer Meters - blanket project - new and replacement meters across the system.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
INTERROGATORY 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?
RESPONSE TO INTERROGATORY NO. 18:
The $45,340 historic test year amount for Eagle Water power costs is not more expensive
than the power used in the rest of the Company’s system. IPUC Request No. 77 refers
specifically to a subset of the Company’s total power and utility costs noted in Exhibit 10,
Schedule 1 Adjustment 10 for Energy - Purchased Power and Other Utilities. That request is
regarding only the Company’s “other power” and other utility costs of $157,953 and the
supporting documentation provided in that response specifically excludes the Company’s
“pumping and distribution power costs” for sources such as its wells, boosters, water treatment
plants, and the raw water pump station, and Idaho Power Company invoices for Eagle Water.
The worksheet provided in response to IPUC request No. 77 provides journal entry
supporting information only for other power and other utility costs. The $112,645 of support
relates to Idaho Power Company invoices for the Company’s office, warehouses, valves and
other miscellaneous power costs, diesel generator fuel (not provided by Idaho Power Company),
VEO-W-22-02
Ada Interogatory 18
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the demand response program rebate, sewer and trash costs, as well as natural gas costs from
Intermountain Gas Company.
VEO-W-22-02
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Page 2 of 2
VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
INTERROGATORY 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?
RESPONSE TO INTERROGATORY NO. 19:
Chlorination of drinking water is an industry standard best practice. It is the most
common type of drinking water disinfection. Public drinking water systems that use surface
water are required to chlorinate their systems. While chlorination is recommended for all public
drinking water systems, Eagle Water Company was not required to add chlorine since all of its
water came from wells (groundwater). The Veolia Water Idaho system uses both groundwater
and surface water. The Eagle Water service area will be connected to the Veolia Water Idaho
system in 2023. The Idaho Department of Environmental Quality will require the entire
integrated system to be chlorinated. In preparation for this integration, Veolia developed a
chlorination plan for Eagle so that chlorination levels are comparable between the systems prior
to integrating them.
The Company’s historic test year level of expense for chemicals included only a portion
of Eagle Water service area’s chemical costs for a year. Historic test year amounts are adjusted
to reflect a normalized annual cost for rate-making purposes.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
INTERROGATORY 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.
RESPONSE TO INTERROGATORY NO. 20:
During certain times of the year based on customer usage patterns, water demand can be
met with fewer wells. As demand for water increases, seasonal water sources are brought on-
line and as demand drops, those sources are temporarily taken off line. Non-producing wells are
listed because they are included as part of the Company’s available well sources, this includes
wells undergoing rehabilitation. In addition, some wells are maintained in a standby status to
provide fire protection supplies if required.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Thompson
INTERROGATORY NO. 21:
Does Veolia have any water rights applications before the Idaho Department of Water
Resources?
RESPONSE TO INTERROGATORY NO. 21:
The only proceeding that Veolia currently has in front of the Idaho Department of Water
Resources (IDWR) is the Integrated Municipal Application Package (IMAP). All information
related to IMAP can be found at this website: https://idwr.idaho.gov/legal-
actions/administrative-actions/suez-water-idaho-inc-imap/
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Thompson
INTERROGATORY 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.
RESPONSE TO INTERROGATORY NO. 22:
As stated in the Company’s response, Veolia’s Integrated Municipal Application Package
(IMAP) is the only proceeding currently open with IDWR.
However, that proceeding is not applicable to the subject of this interrogatory. IMAP is
not a typical application requesting any specific water right or allocation, but rather serves as a
planning framework for municipal water providers to forecast future water needs over an
extended planning horizon. Details can be found at the IDWR link provided in Interrogatory
Response No. 21.
The status of the application is: pending. IDWR has indicated that IDWR hopes to issue a
decision on the IMAP soon, but a precise date has not been identified.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Thompson
INTERROGATORY NO. 23:
Does Veolia anticipate submitting a water rights application related to Anderson Ranch
Dam?
RESPONSE TO INTERROGATORY NO. 23:
Veolia has submitted a letter of interest to IDWR in purchasing storage water related to
the Anderson Ranch Dam raise. If a water right application is the path forward to obtaining a
portion of that storage, Veolia plans to submit one.
VEO-W-22-02
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Thompson
INTERROGATORY NO. 24:
Is Veolia participating with the Idaho Department of Water Resources in the ground
water study?
RESPONSE TO INTERROGATORY NO. 24:
Yes, Veolia provided water resource data in support of the ground water study, and has
attended most of the planning meetings related to the study.
VEO-W-22-02
Ada Interogatory 24
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Thompson
INTERROGATORY NO. 25:
If the answer to Interrogatory Request No. 24 is no, please explain why Veolia is not
involved.
RESPONSE TO INTERROGATORY NO. 25:
Not applicable.
VEO-W-22-02
Ada Interogatory 25
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary/Cooper
REQUEST FOR PRODUCTION NO. 1:
Please provide all documents that support your response to Interrogatory Request No. 1.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
Existing Customers: Please refer to the Idaho Public Utilities Commission’s website -
File Room for Utility Company Annual Reports. Page 12 of the annual report shows customer
statistics.
Water Rights: Links to water right supporting information have been provided in
Interrogatory Response No. 2.
VEO-W-22-02
Ada PR 1
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
REQUEST FOR PRODUCTION NO. 2:
Please provide all documents that support your response to Interrogatory Request No. 2.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
Links to supporting documents are provided in the Interrogatory Response.
VEO-W-22-02
Ada PR 2
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
REQUEST FOR PRODUCTION NO. 3:
Please provide all documents that support your response to Interrogatory Request No. 3.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
Links to supporting documents are provided in the Interrogatory Response.
VEO-W-22-02
Ada PR 3
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
Drilling logs and other information is available on IDWR’s website. The link has been
provided in the accompanying responses to interrogatories. Veolia is unaware of documents “that
identify the location of Veolia wells as to each of the three aquifers,” as this is not Veolia’s
understanding of the hydrogeolic characteristics of Veolia’s service territory.
VEO-W-22-02
Ada PR 4
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
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 performing the sampling.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
Please refer to the Company’s annual Customer Confidence Report (CCR) for water
quality sampling results. The past two years of water quality reports can be downloaded from the
Veolia website (https://mywater.veolia.us/water-in-my-area/water-quality-reports/83709).
Additional records can be obtained by submitting a public records request to the Idaho
Department of Water Quality (DEQ) (https://www.deq.idaho.gov/public-records-request/).
Water samples are collected by trained Veolia company personnel and testing is
conducted by a state certified laboratory. The laboratories used for water quality testing include:
Analytical Laboratories, Anatek, Eurofins, and Pace Analytical.
VEO-W-22-02
Ada PR 5
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
Please refer to the Company’s annual Customer Confidence Report (CCR). The past two
years of water quality reports can be downloaded from the Veolia website
(https://mywater.veolia.us/water-in-my-area/water-quality-reports/83709). Additional records
can be obtained by submitting a public records request to DEQ
https://www.deq.idaho.gov/public-records-request/).
VEO-W-22-02
Ada PR 6
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cagle
REQUEST FOR PRODUCTION NO. 7:
Please provide all documents that support your response to Interrogatory Request No. 8.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
None.
VEO-W-22-02
Ada PR 7
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cagle
REQUEST FOR PRODUCTION NO. 8:
Please provide all documents associated with executive salaries before and after the
acquisition of Suez.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
Executive salaries were not impacted specifically as a result of the transaction.
VEO-W-22-02
Ada PR 8
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
REQUEST FOR PRODUCTION NO. 9:
Please provide all documents that support your response to Interrogatory Request
No. 13.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
Veolia’s tariff rates are available on the Idaho Public Utilities Commission website - Fire
Room - Approved Tariffs and Price Lists. The Company’s tariff includes specific rate schedules
applicable to only former Eagle Water Company customers with the 7-year rate phase-in per
Commission Order No. 35247. Those rate schedules are designated for existing customers
“residing in the area formerly serviced by Eagle Water Company as of January 1, 2022.”
VEO-W-22-02
Ada PR 9
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
REQUEST FOR PRODUCTION NO. 10:
Please provide all documents that support your response to Interrogatory Request No. 18.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
Please refer to the response to IPUC Request No 77.
VEO-W-22-02
Ada PR 10
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
REQUEST FOR PRODUCTION NO. 11:
Please provide all documents that support your response to Interrogatory Request
No. 19.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
Please refer to the response to IPUC Request No. 80.
VEO-W-22-02
Ada PR 11
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cary
REQUEST FOR PRODUCTION NO. 12:
Please provide all documents that support your response to Interrogatory Request
No. 20.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
Please refer to the response to IPUC Request No. 61.
VEO-W-22-02
Ada PR 12
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
There is not an available overall map that shows the location of these pipelines.
VEO-W-22-02
Ada PR 13
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Thompson
REQUEST FOR PRODUCTION NO. 14:
Please provide any applications before the Idaho Department of Water Resources?
RESPONSE TO REQUEST FOR PRODUCTION NO. 14:
The link to available IMAP documents is provided in the response to Interrogatory No.
21.
VEO-W-22-02
Ada PR 14
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-22-02
ADA COUNTY’S FIRST SET OF INTERROGATORIES AND FIRST SET OF
PRODUCTION REQUESTS TO VEOLIA WATER IDAHO, INC.
Preparer/Sponsoring Witness: Cooper
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
There is no available overall map of these infrastructure improvements.
VEO-W-22-02
Ada PR 15
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