20230615Staff 1-8 to VEO.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 50
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
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 VEOLIA WATER )IDAHO,INC.'S APPLICATION FOR )CASE NO.VEO-W-23-02
APPROVAL OF INTERCONNECTION )AGREEMENT WITH CITY OF MERIDIAN )
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO VEOLIA WATER IDAHO,
)INC.
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Veolia Water Idaho,Inc.("Veolia"or
"Company")provide the followingdocuments and information as soon as possible,but no later
than WEDNESDAY,JULY 6,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,additional documents that it,or any person
acting on its behalf,may later obtain that will augment the documents or information produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.1 JUNE 15,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please provide the estimated cost for construction of the Company's
portion of the interconnection line.
REQUESTNO.2:Please explain how this interconnection is the least cost solution to
provide additional reliability to the Company's system.In the explanation,please provide a net
present value cost-benefit comparison to the next least cost solution over a 20-year life cycle.
REQUESTNO.3:Please provide any technical analysis the Company has performed
regarding its system's capabilities and capacity in the vicinity of the interconnection.Please
provide any information regarding anticipated Company capacity surpluses or shortfalls in the
vicinity of the interconnection.
REQUESTNO.4:Please provide the water quality standards that City of Meridian and
the Company are each required to meet.Please provide the most recent water qualityresults of
the two systems.
REQUESTNO.5:Please provide the current rate the Company would pay City of
Meridian if the Company received water at the interconnection.
REQUESTNO.6:Please elaborate on the term "Emergency Event"as discussed in
Page 7,Section 2.1 in the Agreement includingthe following:
a.Please provide the threshold level of water pressure below which the pressure will
be considered inadequate and invoke the stated "Emergency Event"in the
Agreement.
b.Please describe what is meant by "adequatewater quality"as stated in the
agreement (Page 7,Section 2.1),and elaborate on what conditions could make the
water quality inadequate.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.2 JUNE 15,2023
REQUESTNO.7:Please explain how Veolia will account for the revenues earned
when selling water to the City of Meridian during an "Emergency Event."
REQUESTNO.8:Please explain how the Company will handle the stranded assets ifeitherpartybreachestheAgreement.
DATED at Boise,Idaho,this N ay of June 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umise:prodreq/veow23.2ms prod req l
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.3 JUNE 15,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15th DAY OF JUNE 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO VEOLIA WATER IDAHO,INC.,IN CASE NO.
VEO-W-23-02,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
PRESTON N CARTER
MORGAN GOODIN
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-MAIL:[e-mail]
[e-mail]
[e-mail]
SECRETAR
CERTIFICATE OF SERVICE