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Home My WebLink About20230628VEO to Staff 1-7.pdfVEOLIA WATER IDAHO, INC.’S RESPONSES TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF PAGE 1 OF 2 Preston N. Carter, ISB No. 8462 Morgan D. Goodin, ISB No. 11184 GIVENS PURSLEY LLP 601 West Bannock Street P.O. Box 2720 Boise, Idaho 83701-2720 Office: (208) 388-1200 Fax: (208) 388-1300 prestoncarter@givenspursley.com morgangoodin@givenspursley.com Attorneys for Veolia Water Idaho, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF VEOLIA WATER IDAHO, INC. FOR APPROVAL OF WATER MAIN INSTALLATION AGREEMENT Case No. VEO-W-23-01 VEOLIA WATER IDAHO, INC.’S RESPONSES TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Veolia Water Idaho, Inc. (“Veolia” or “Company”) in response to the First Production Request of the Commission Staff to Veolia Water Idaho, Inc. dated June 15, 2023, submits the following responses. DATED June 28, 2023. GIVENS PURSLEY LLP By Preston N. Carter Attorneys for Veolia Water Idaho, Inc. RECEIVED 2023 JUNE 28, 2023 12:29PM IDAHO PUBLIC UTILITIES COMMISSION VEOLIA WATER IDAHO, INC.’S RESPONSES TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2 CERTIFICATE OF SERVICE I hereby certify that on June 28, 2023, I caused to be served a true and correct copy of the foregoing document to the person(s) listed below by the method indicated: Jan Noriyuki, Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg. 8, Suite 201-A Boise, ID 83714 U.S. Mail, postage prepaid Express Mail Hand Delivery Facsimile Email jan.noriyuki@puc.idaho.gov _________________________________________ Preston N. Carter VEO-W-23-01 IPUC Staff PR 1 Page 1 of 1 VEOLIA WATER IDAHO, INC. CASE VEO-W-23-01 FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: C. Cooper REQUEST NO. 1: Please provide the estimated cost for construction for the proposed main line extension. RESPONSE NO. 1: We estimate construction cost for the proposed main line extensions between $3,000,000 and $3,500,000. VEO-W-23-01 IPUC Staff PR 2 Page 1 of 1 VEOLIA WATER IDAHO, INC. CASE VEO-W-23-01 FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: C. Cooper REQUEST NO. 2: Please provide the approximate annual maintenance costs for the proposed main line extension. RESPONSE NO. 2: Maintenance costs will be minimal and could include pipeline flushing, valve exercising, and hydrant maintenance. Estimated total maintenance cost per year of not more than $3,000. VEO-W-23-01 IPUC Staff PR 3 Page 1 of 1 VEOLIA WATER IDAHO, INC. CASE VEO-W-23-01 FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Preston Carter / Marshall Thompson REQUEST NO. 3: The second request in the Company’s Prayer for Relief is for the Commission to enter an Order “Approving the Agreement, and Veolia’s performance under the Agreement.” Application at 3. Please clarify what the Company means regarding its “performance under the Agreement.” RESPONSE NO. 3: The intent of the quoted language is to clarify that Veolia requests that the Commission approve both the Agreement itself, as well as the actions that Veolia will take pursuant to the Agreement, which are identified in the Agreement itself. Veolia does not view this language as materially different from standard language in a prayer for relief, and does not expect that this language would result in an order from the Commission that is materially different from orders in other similar cases. VEO-W-23-01 IPUC Staff PR 4 Page 1 of 1 VEOLIA WATER IDAHO, INC. CASE VEO-W-23-01 FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: C. Cooper REQUEST NO. 4: Please clarify if the scope of the main line extension will include service lines and hookups to each affected home. If not, how will service be extended to them? Who will pay the expense to connect each resident? RESPONSE NO. 4: The scope of the main line extension will not include service lines and hookups to each affected home. Veolia will pay for each service line from the main to the meter box, and the customer meter. The individual property owner will pay the cost of any service line from the back leg of the meter to their home. VEO-W-23-01 IPUC Staff PR 5 Page 1 of 1 VEOLIA WATER IDAHO, INC. CASE VEO-W-23-01 FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: C. Cooper REQUEST NO. 5: Please provide the number of new service connections the Company anticipates from the main line extension. RESPONSE NO. 5: We believe there will be a minimum of 30 service connections initially, this is the approximate number of homeowners in the planned construction area who have contacted Ada County with immediate well concerns. In the future, additional individual property owners that front the main would likely request service. There are 173 properties that the proposed mains will front. VEO-W-23-01 IPUC Staff PR 6 Page 1 of 1 VEOLIA WATER IDAHO, INC. CASE VEO-W-23-01 FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: C. Cooper REQUEST NO. 6: Please provide a map showing the planned and main line extension and the Company’s service boundary in the vicinity. RESPONSE NO. 6: The attached map shows the planned main line extension areas in relation to the Company’s service area boundary. BOGUS BASIN SHAW MOUNTAIN SUNSET PEAK §¨¦I-84 §¨¦I-84 §¨¦I-84 §¨¦I-84 MERIDIAN BOISE GARDENCITY EAGLE KUNA BOISE BOISE KUNA EAGLE W Cherry Ln W Ustick Rd N Orchard St S Five Mile Rd W Chinden Blvd N Ten Mile Rd E Lake Hazel Rd W Franklin Rd S Vista Ave E Gowen Rd N Meridian Rd S Federal Way W Overland Rd E Hwy 21 E Kuna Mora Rd N Five Mile Rd S Capitol Blvd W Overland Rd S Cole Rd W Fairview Ave N Cole Rd W State St E Overland Rd S Meridian Rd E ChindenBlvd S Broadway Ave S Orchard St W Lake Hazel Rd W Fairview Ave N Meridian Rd E Fairview Ave W Franklin Rd E Front St W Chinden Blvd W State St S Ten Mile Rd E Ustick Rd E ChindenBlvd W Lake Hazel Rd E Franklin Rd N Glenwood St S Eagle Rd N Hwy 55 N Eagle Rd E State St S Eagle Rd W Hwy 44 E Parkcenter Blvd E Hwy 44 N Hwy 55 E KunaMora Rd E KunaMora Rd W Kuna Mora Rd Print Date: 5/6/2022 No Scale WATER DISTRIBUTION SYSTEM ± Service Area VEO-W-23-01 IPUC Staff PR 7 Page 1 of 1 VEOLIA WATER IDAHO, INC. CASE VEO-W-23-01 FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: J. Cary REQUEST NO. 7: Please provide the expected tax effects of this project. RESPONSE NO. 7: Because the property is to be contributed as CIAC, which is treated as exempt for income-tax purposes, there should be no income tax effects from the project for ratemaking purposes.