20220916Staff 1-5 to Veola.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II7I4
Street Address for Express Mail:
1 I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION TO
AMEND BRIAN WATER SURCHARGE AND
REFUND CUSTOMERS.
CASE NO. VEO-W-22-03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
VEOLA WATER IDAHO,INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Veola Water Idaho, Inc. ("Veola or
"Company") provide the following documents and information as soon as possible, or by
FRTDAY, OCTOBER 7, 2022.
This Production Request is continuing, and Veola is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may later
obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Veola is reminded that responses pursuant to
Commission Rules of Procedure must include the name and phone number of the person preparing
the document, and the name, location and phone number of the record holder and if different the
witness who can sponsor the answer at hearing if need be. Reference IDAPA 31.01.01.228.
FIRST PRODUCTION REQUEST
TO VEOLA WATER
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SEPTEMBER 16,2022
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a list of all customers that are eligible for the credit
and or refund, the principal balance still owed, and whether they pay monthly, or bi-monthly.
REQUEST NO.2: The Company's Application states that it "will provide credits on
customer bills in the amount of the customer's surcharge overpayment, including interest atarate
of 2%o, which is the amount of interest on customer deposits." Does the Company propose to
apply the credit to the customers' monthly water bill, or to the principal balance still owed by the
customer for Schedule No. 1C - Brian Water Surcharge?
REQUEST NO.3: If the credit will be applied to the customers' monthly water bill, did
the Company consider applying the credit to any unpaid principal balance for Schedule No. 1C -
Brian Water Surcharge?
REQUEST NO. 4: Does the Company have a contingency plan for retuming the
overpayment to former customers if those customers cannot be located?
REQUEST NO. 5: Did the Company consider any other options on how to retum the
overpayment to customers? If so, please explain those options and why the Company chose a bill
credit as the appropriate means to refund the overpayment.
,.r/1
tUDated at Boise, Idaho, this day of September 2022
Michael Duval
Deputy Attomey General
i:umisc/prod req/veow22. ldvksk prod reql
FIRST PRODUCTION REQUEST
TO VEOLA WATER
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2 SEPTEMBER 16,2022
CERTIFICATE OF SERVICE
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I HEREBY CERTIFY THAT I HAVE THIS /(O-OIY OF SEPTEMBEF.}O}L,
SERVED TIIE FOREGOING FIRST PRODUCTION REQTIEST OF TIrE
COMMISSION STAXT' TO VEOLA WATER IDAHO, MC., IN CASE NO.
VEO.W.22.O3, BY E.MAILING A COPY TIIEREOF, TO THE FOLLOWtrNG:
PRESTON N CARTER
MORGAN GOODIN
GIVENS PURSLEY LLP
PO BOX 2720
BOISE rD 83701-2720
E-MAIL : prestoncartet@ givensoursley.com
morqansoodin@ giveqspursley.oom
CERTIFICATE OF SERVICE