20230307Staff to Veolia 1-3.pdf

CHRIS BURDIN IVED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.98 10
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )CASE NO.VEO-W-22-02
VEOLIA WATER IDAHO,INC.FOR A )GENERAL RATE CASE )
)COMMISSION STAFF'S
)RESPONSE TO VEOLIA
)WATER IDAHO,INC.FIRST
)PRODUCTION REQUEST
The Staff of the Idaho Public Utilities Commission,by and through its attorney of
record,Chris Burdin,Deputy Attorney General,responds as follows to Veolia Water Idaho,
Inc.'s First Production Request to Commission Staff.
REQUESTNO.1:Please provide all Exhibits filed in support of the testimony of
Commission Staff in native format,with formulas intact.
STAFF RESPONSE NO.1:For Staff witness English's Exhibit Nos.102 and 103,
please see file named "Response to PR l_English.Exhibits_102 103.xlsx"
For Staff witness Johnson's Exhibit Nos.104 through 117,please see file named
"Res onse to PR 1 Johnson.Exhibits 104 thru 117.xlsx"P
COMMISSION STAFF'S RESPONSE
TO VEOLIA WATER IDAHO'S FIRST
PRODUCTION REQUEST MARCH 7,2023
For Staff witness Terry's Exhibit Nos.119 through 121,please see the followingfiles:
Response to PR 1 Terry.Exhibit 119.xlsx
Response to PR
l_Terry.Exhibit¯l20.xlsx
Res onse to PR 1 Te r.Exhibit 121.xlsxp_
rg
For Staff witness Eldred's Exhibit Nos.123 and 126,please see the file named "Response
to PR l _Eldred.Exhibit_123_with_workpapers.xlsx"
For Staff witness Culbertson's Exhibit Nos.130 through135,please see the file named
"Response to PR 1 _Culbertson.Exhibits_l30_thru 135.xlsx"
For Staff witness Bossard's Exhibit Nos.137 through 141,please see the followingfiles:
Veow22.2 jbossard-exhibit No 137.xlsx
Veow22.2 jbossard-exhibit No 138.xlsx
Veow22.2 jbossard-exhibit No 139.xlsx
Veow22.2 jbossard-exhibit No 140.xlsx
Veow22.2 jbossard-exhibit No 141.xlsx
REQUESTNO.2:Please provide all workpapers that were created,referenced,or
otherwise used to support the testimony of Commission Staff.This request includes any
workpaper that includes or references calculations created,referenced,or otherwise used by
witness in creating or drafting his or her testimony.
STAFF RESPONSE NO.2:Workpapers are included as separate tabs in the Excel files
provided in response to production request No.1.For additional workpapers,please see thefollowingfiles:
Response to PR 2 English workpaper.xlsx
Veolia Commercial Regression Workpapers_2.28.23.xlsx
Veolia Residential Regression Workpapers_2.28.23.xlsx
Data Request No 42 Attachment 2-file as excel.xlsx
VEO-W-22-02 Revenue Requirement-Workpapersto IPUC Staff 02272023.xlsx
REQUESTNO.3:Please provide all documents that were used to create,or that are
referenced within,any exhibit of the testimony of Commission Staff.If such documents were
provided by Veolia in response to production requests,there is no need to provide a second copy
of these documents,but please identify the document by production response number,file name,
and other identifyingcharacteristic such as file name.
COMMISSION STAFF'S RESPONSE
TO VEOLIA WATER IDAHO'S FIRST
PRODUCTION REQUEST MARCH 7,2023
STAFF RESPONSE NO.3:Documents used to create exhibits are referenced in the
files included in Staff Response to Production Request Nos.1 and 2.Additional information isprovidedbelow:
For Exhibit No.104,please see the Company's Response to Staff PR No.63.
For Exhibit No.106,please see the Company's Response to Staff PR Nos.63 and 74.
For Exhibit Nos.107,109,112,and 114-116,please see the Company's Response to Staff
PR No.150.
For Exhibit No.138,please see the Company's Response to Staff PR No.133.
For Exhibit No.139,please see the Company's Response to Staff PR No.129.
For Exhibit No.140,please see the Company's Response to Staff PR No.126.
For Exhibit No.141,please see the Company's Response to Staff PR No.130.
DATED at Boise,Idaho,this day of March 2023.
Chris Burden
i:umisc:prodreq/veow22.2cbrk prod req 6
COMMISSION STAFF'S RESPONSE
TO VEOLIA WATER IDAHO'S FIRST
PRODUCTION REQUEST MARCH 7,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF MARCH 2023,
SERVED THE FOREGOING COMMISSION STAFF'S RESPONSE TO VEOLLA
WATER IDAHO,INC FIRST PRODUCTION REQUEST,IN CASE NO.
VEO-W-22-02,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
PRESTON N CARTER DAVID NJUGUNA
MORGAN GOODIN MGR-REGULATORY BUSINESS
GIVENS PURSLEY LLP VEOLIA WATER M&S INC
PO BOX 2720 461 FROM ROAD STE 400
BOISE ID 83701-2720 PARAMUA NJ 07052
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
[e-mail]
LORNA K.JORGENSEN SHARON M.ULLMAN,PRO SE
MEG WADDEL 5991 E.BLACK GOLD STREET
ADA COUNTY PROSECUTING BOISE,ID 83716
ATTORNEY'S E-MAIL:[e-mail]
OFFICE /CIVIL DIVISION
200 W.FRONT STREET,ROOM 3191
BOISE,ID 83702
E-MAIL:[e-mail]
JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY,INC.THORVALD A.NELSON
8000 SOUTH FEDERAL WAY AUSTIN W.JENSEN
BOISE,ID 83707 HOLLAND &HART,LLP
E-MAIL:[e-mail] 555 17TH STREET SUITE 3200
DENVER,CO 80202
E-MAIL:[e-mail]
MARY R.GRANT [e-mail]
DEPUTY CITY ATTORNEY [e-mail]
BOISE CITY ATTORNEY'S OFFICE aclee@hoÏ1andhart.com
105 N.CAPITOL BLVD.kdsprizes hollandhart.com
PO BOX 500
BOISE,ID 83701-0500
E-MAIL:[e-mail]
[e-mail]
SECRETAP
CERTIFICATE OF SERVICE