20230727VEO to Staff 10-11.pdf

RESPONSE TO THIRD 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
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Fax: [phone]
[e-mail]
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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-23-02

VEOLIA WATER IDAHO, INC.’S
RESPONSES TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF

Veolia Water Idaho, Inc. (“Veolia” or “Company”) in response to the Third Production
Request of the Commission Staff to Veolia Water Idaho, Inc. dated July 20, 2023, submits the
following responses. Confidential documents are provided under separate cover.
DATED July 27, 2023.
GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Veolia Water Idaho, Inc.
RECEIVED
2023 JULY 27, 2023 2:08PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSE TO THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on July 27, 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
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_________________________________________
Preston N. Carter
VEOLIA WATER IDAHO, INC.
CASE VEO-W-23-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: C. Cooper
REQUEST NO. 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.
RESPONSE NO. 10:
a.Meridian’s contractor bid price for the interconnect work is $142,000.
b.The property is owned by ACHD. No bids have been requested for the work yet,
so the exact amount of the contribution is unknown. Veolia shows the portion
that will be contributed by ACHD in Production Request #12. ACHD needs the
portion of the pipeline that will be connected to the interconnect for their normal
service at the property (regardless of whether the interconnect is ever
constructed). The legal arrangement with ACHD will be the typical Mainline
Extension Contract with Veolia. In addition, an easement is in place for the
interconnect facility, please see the Attachment (PR10_Attachment_Easement-
Interconnect.pdf)
VEO-W-23-02
IPUC Staff PR No. 10
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VEOLIA WATER IDAHO, INC.
CASE VEO-W-23-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: C. Cooper
REQUEST NO. 11:
The Company’s response to Production Request No. 2 stated that no cost-benefit
comparison was completed. Please list and quantify the benefits that the Company believes will
be provided.
RESPONSE NO. 11:
There are many important benefits to having the interconnect with the City of Meridian in
place, including the following:
1.Cooperation with and support of a neighboring water system.
2.Low cost emergency water supply, beyond the redundancy that Veolia already
provides per Idaho Department of Environmental Quality requirements.
3.Adds additional reliability for the Veolia water system.
VEO-W-23-02
IPUC Staff PR No. 11
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