20230720Staff 10-12 to VEO.pdf

CHRIS BURDIN ,EDDEPUTYATTORNEYGENERAL
IDAHO PUBLIC UTILITIES COMMISSION DM a n
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 )
)THIRD 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 THURSDAY,AUGUST 3,2023,1.
This Production Request is to be considered as continuing,and the Company 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 or information produced.
i Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.1 JULY 20,2023
Please provide answers to each question,supporting workpapers that provide detail or are
the source of informationused in calculations,and the name,job title,and telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
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.10:Please provide additional details regarding the Company's response
to Production Request No.1.Specifically,
a.Please provide the estimate for the project costs that will be paid for by the City of
Meridian;and
b.Please provide information about the arrangement with the individual property owner,
the nature and value of the pipeline contribution,and the legal arrangements for the
property.
REQUESTNO.11:The Company's response to Production Request No.2 stated that
no cost-benefit comparison was completed.Please list and quantifythe benefits that the
Company believes will be provided.
REQUESTNO.12:The details of Exhibit A (Conceptual Drawing for Interconnection
Project)are difficult to discern.Please provide the following:
a.Please provide a clearer copy so that the text and numbers can be discerned;
b.Please provide the piping,meter,and valve details associated with the interconnection
vault;
c.Please use color highlighting(or suitable alternative)to distinguish the "Meridian
Work"and the "Company Work"so the respective scopes of responsibility can be
easily identified;and
d.Please use color highlighting (or suitable alternative)to distinguish the primary flow
paths of Meridian water and Company water to the interconnection.
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.2 JULY 20,2023
DATED at Boise,Idaho,this 20th day of July 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umise:prodreq/veow23.2cbms prod req 3
THIRD PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.3 JULY 20,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF JULY 2023,
SERVED THE FOREGOING THIRD 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]
EC ETA
CERTIFICATE OF SERVICE