20230221Veolia to Staff No. 163.pdf

VEOLIA WATER IDAHO, INC.’S RESPONSES TO SIXTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 1 OF 3
16630115_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 21, 2023.

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

RECEIVED
Tuesday, February 21, 2023 3:15:20 PM
IDAHO PUBLIC
UTILITIES COMMISSION
VEOLIA WATER IDAHO, INC.’S RESPONSES TO SIXTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 3
16630115_1.DOCX (30-235)
CERTIFICATE OF SERVICE

I certify that on February 21, 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
16630115_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
SIXTH 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:
1.Cause of the issue: Inaccurate meter readings were provided by one meter reader for
approximately 1,019 customers, or less than 1% of the total customer base. The
preliminary number of customers impacted of 1,136 provided informally to Commission
Staff was incorrectly totaled due to duplicate account numbers listed in the tracking file.
2.Timeframe: The bill periods impacted by inaccurate meter readings span from July 2022
through January 2023.
VEO-W-22-02
IPUC DR 163
Page 1 of 7
Background information: During December 2022 VWID’s billing staff began receiving
system generated exceptions for potentially problematic meter readings. The pending
bills showed an unusually high water usage amount for that (two-month) billing period
compared to the customer’s prior year usage consumption history for that same period. A
pattern with a single Meter Reader became evident as billing staff reviewed these
customer accounts and found irregularities in generally consistent and predictable
consumption patterns.
All safeguards to ensure meter reading accuracy and validity were in place,
including: company vehicle GPS positions, handheld meter reading device locations and
distances from last reading, acceptable parameters, average time to read the assigned
meter route, and the valid meter reading range (both high and low) based on the
customer’s prior year consumption. While the facts gathered during the investigation did
not reveal whether the employee intentionally falsified meter readings and there was no
admission of such, the company has reason to believe that the Meter Reader did not reach
each customer’s meter (by opening the meter box lid) as they moved through the assigned
meter reading route. The Company suspects the Meter Reader misrepresented meter
readings as actual that were low enough to avoid triggering the aforementioned
acceptable reading safeguards. Due to the number of delayed exceptions triggered and
erratic consumption generated from one Meter Reader’s work, it is the Company’s belief
that this individual was misrepresenting meter readings which were the basis for
customer bills and this required correction. Under-reported consumption from inaccurate
meter readings required rebilling for approximately 1,019 customers, to reallocate actual
consumption to the appropriate periods and true up under-reported water usage.
VEO-W-22-02
IPUC DR 163
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Rebilling is a necessary step in order for customer usage history to be accurately
reflected for billing purposes, including for customers who use budget billing level-pay
options based on their 12 months of consumption history, as well as for customers who
have their sewer bills based on their wintertime water usage. Rebills are generally done
for one prior billing period, however in this instance it was necessary to rebill customers
for up to 3 billing periods. That determination was made based on the billing staff’s
careful review of the customer’s usage history which indicated that this “mis-read” issue
was not a system error and not isolated to just one period but also that prior meter
readings by the same Meter Reader were suspect as well even though they fell within
acceptable system parameters. These inaccurate readings did not trigger an exception at
that time and were billed as actual readings on customer bills.
Corrective actions: The initial step in addressing meter read exceptions includes
verifying the meter reading by field customer service staff and conducting a leak check if
warranted. After the meter reading is verified as actual with no indication of constant
usage which would indicate a leak, billing staff perform an in-depth review of the
customer’s account to address the cause of the error, and determine whether a cancel-
rebill is warranted. Based on a careful review of the customer’s consumption history and
relying on their expertise, when billing staff determine a rebill is necessary, they cancel
the pending and prior bills(s) and rebill actual usage based on best available information.
Customer service representatives then contacted the affected customer by phone
as the rebillings are generated, rather than relying on the normally mailed customer letter
to inform customers of the extraordinary situation, to answer any questions and advise
VEO-W-22-02
IPUC DR 163
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that they should expect to see cancel/rebills on their next bill. Customers may request a
payment plan to extend the period they have to pay their bill.
Even though the rebilling(s) represent actual usage for each customer, the
company uses its discretion to provide an appropriate credit to customers with
outstanding concerns when they contact the company or Commission, if they are
burdened financially, unduly inconvenienced, or face hardship as a result. The
Company’s customer service staff work with customers to find an agreeable solution.
The meter reader responsible for the abnormally large number of mis-read meter
readings was placed on unpaid suspension during the investigation and was separated
from the company following completion of the investigation on January 20, 2023.
3.Corrections made to consumption data by month: Verified meter readings for actual
meter reads were completed as of January 24, 2023. Rebillings due to this abnormality in
mis-read meter readings have been processed starting November 29, 2022, with the
majority completed in January 2023, and a few remaining rebills completed in February
2023. Consumption billed by month for system reports are not retroactively restated. Any
consumption and the amount billed difference between prior bills that are subsequently
canceled and rebilled, are reflected in the month when the rebilling takes place. Even
though consumption was “reallocated” to the other billing periods, the subsequent meter
reading and rebilled total captures a true-up of under-reported consumption and
potentially “new” consumption for the current billed period. Bills for bi-monthly billed
customers reflect consumption over a two-month period. The consumption reported for
December 2022 will include rebilled consumption for prior bills that span as far back as
July 2022 in this instance. The canceled and rebilled amounts below reflect 100 cubic
VEO-W-22-02
IPUC DR 163
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feet (CCF) consumption as well as the total amount billed, which includes: consumptive
fees, meter fees, franchise taxes, safe drinking water fees, surcharges, etc. There are no
retroactive adjustments made to prior month-end consumption or revenue reports.
However based on the company’s analysis the rebilling which took place and based on
available data for 994 rebilled customers resulted in the approximate impact per TABLE
1 below:
TABLE 1
Bill Date (Start - End)
Canceled
Bills
CCF's
Rebilled
CCF's
(with
Consumptio
n True-up)
Cancele
d Bills
Total
Rebilled
Total
CCF
Differenc
e
Billed $
Differenc
e
July - September 2022 -1,206 5,222 -$4,332 $12,681 4,016 $8,348
August - October 2022 -12,582 58,147 -$39,454 $131,592 45,565 $92,138
September - November
2022 -5,837 25,586 -$23,044 $58,371 19,749 $35,327
October - December 2022 -6,505 1,599 -$12,641 $4,695 -4,906 -$7,947
November - January 2023 -8,149 1,877 -$16,692 $6,332 -6,272 -$10,360
TOTAL -34,279 92,431 -$96,163 $213,670 58,152 $117,507
Billed by December 2022
Revenue Cutoff Date -14,643 48,724 -$40,663 $110,756 34,081 $70,093
Billed after December
2022 Revenue Cutoff Date -19,636 43,707 -$55,501 $102,914 24,071 $47,414
TOTAL -34,279 92,431 -$96,163 $213,670 58,152 $117,507
The difference in the count of rebilled accounts of 1,019 compared to the data that
calculated the impact of above for 994 accounts, is due to incorrect account numbers
reflected in the tracking file of 1,019 accounts, and data query limitations. To adjust for
the discrepancy in number of accounts tracked as rebilled versus the available data to
calculate the impact, a gross-up of 1,019 divided by 994 accounts or 1.02515% is applied
and reflected in TABLE 2 Grossed-up below:
VEO-W-22-02
IPUC DR 163
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TABLE 2 Grossed-up
Bill Date (Start - End)
Canceled
Bills
CCF's
Rebilled
CCF's
(with
Consumptio
n True-up)
Cancele
d Bills
Total
Rebilled
Total
CCF
Differenc
e
Billed $
Differenc
e
July - September 2022 -1,236 5,353 -$4,441 $12,999 4,117 $8,558
August - October 2022 -12,898 59,609 -$40,447 $134,902 46,711 $94,455
September - November
2022 -5,984 26,230 -$23,623 $59,839 20,246 $36,216
October - December 2022 -6,669 1,639 -$12,959 $4,813 -5,029 -$8,147
November - January 2023 -8,354 1,924 -$17,111 $6,491 -6,430 -$10,620
TOTAL -35,141 94,756 -$98,582 $219,044 59,615 $120,462
Billed by December 2022
Revenue Cutoff Date -15,011 49,949 -$41,685 $113,541 34,938 $71,856
Billed after December
2022 Revenue Cutoff Date -20,130 44,806 -$56,897 $105,503 24,676 $48,606
TOTAL -35,141 94,756 -$98,582 $219,044 59,615 $120,462
Of the 2022 under-reported consumption and revenue plus any “new” usage, 34,938 CCF
of the 59,615 CCF total difference is reflected in year 2022 revenue and consumption
total, while the remainder was rebilled and reflected in year 2023.
4.Explanation for amount of correction: The amount of correction for each rebilling (two
month) period is based on the customer’s unique consumption history.Billing staff
compare the customer’s consumption to the three-year average consumption for the same
time period. During this review they must factor in several variables including:
seasonality, number of billing days in the cycle, historical averages for the same time
period in previous years, how much historical data exists for the current customer and
prior customer of record, is the meter manually read or is an automated meter, previous
reads in the read history, regular reads, estimated reads, and verified reads.
VEO-W-22-02
IPUC DR 163
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If there are anomalies in the customer’s usage history i.e., unusually high or low
consumption for a particular period and unexplained or uncharacteristic changes in
consumption trends from one bill period to the next, billing staff may exclude those
outliers from the standard three-year average on which the reallocation of usage is based.
If billing staff determine that the customer’s usage history indicates that more than just
one bill period reflected incorrect consumption based on inaccurate meter readings (such
as in this instance) they will analyze and re-allocate customer usage for up to three billing
periods, according to Commission rules.
5.Actual customer counts and customer consumption: In response to staff’s request,
please see the attachment which is an update to the Company Revenue schedules
incorporating the final actual customer counts and customer consumption from January 1,
2022, through December 31, 2022. Please note the attached does not necessarily
represent the Company’s rebuttal position in this case.
VEO-W-22-02
IPUC DR 163
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