20231116Staff 1-14 to VEO.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL 9:29IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720 LT
BOISE,IDAHO 83720-0074 MISSION
[phone]
IDAHO BAR NO.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF VEOLIA WATER )IDAHO,INC.'S APPLICATION FOR )CASE NO.VEO-W-23-04
APPROVAL OF FIRE HYDRANT )CONVEYANCE,INSTALLATION,AND )OPERATION AGREEMENT )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,
Michael Duval,Deputy Attorney General,requests that Veolia Water Idaho,Inc.("Company")
provide the followingdocuments and information as soon as possible,but no later than
THURSDAY,DECEMBER 7,2023.
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
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.1 NOVEMBER 16,2023
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 approximate annual maintenance costs of the
hydrants throughoutthe 20-yearperiod outlined in the Fire Hydrant Conveyance,Installation,
and Operation Agreement ("Agreement").Please provide supporting workpapers.
REQUESTNO.2:Please provide the estimated cost for construction of new hydrants
by year throughout the 20-year period,as described in the Agreement.Please provide supporting
workpapers.
REQUESTNO.3:As stated in the Agreement,"[i]f an Existing Hydrantis not
operational when inspected,it will go on a list of Existing Hydrants requiring replacement
("ReplacementList").Veolia will replace those hydrants on the Replacement List at Veolia's
cost,and once replaced,the hydrant will go on the Transfer List."Agreement at 2 (emphasis in
original).Please explain if Veolia will own the replaced hydrants if the Agreement is terminated.
REQUESTNO.4:As stated in the Agreement,"Veolia shall have no legal liability for
any Existing Hydrantnot replaced or installed by Veolia,apart from the obligations,terms,and
conditions set forth in this Agreement."Id.at 3.Please explain if the Company will be liable for
the hydrants that were transferred from the Transfer List after inspected.If not,please explain
why and who will be liable.
REQUESTNO.5:As stated in the Agreement,"Veolia will inspect a minimum of one-
fifth (1/5th)of the Existing Hydrants every year beginning on January 1 of the calendar year
after the Effective Date of this Agreement."Id.at 2.Please explain when the Company expects
to start inspecting existing hydrants and installingnew hydrants.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.2 NOVEMBER 16,2023
REQUESTNO.6:Please explain whether the Agreement applies to new housing
developmentswithin the WhitneyFire District.Please also answer the following:
a.Who typically pays for installation and operation and maintenance of the hydrants
in a new housing development,and where is this defined in current tariffs?
b.If a hydrantrequires a main line extension,who typically pays for the cost,and is
this treatment different under the Agreement?
REQUESTNO.7:Please provide the total number of privately owned and currently
owned fire hydrants by WhitneyFire District that will be transferred by this Agreement.
REQUESTNO.8:Please provide the total number of new fire hydrants that is expected
to be installed by this Agreement.
REQUESTNO.9:The Application states,"[u]pon approval of the Agreement,Veolia
intends to begin billing the owners of these privately owned hydrants in accordance with its
approved tariffs."Application at 4.Please respond to the followingabout the privatelyowned
hydrants:
a.Are these private hydrant owners currentlybeing charged for these hydrants?If
so,who is charging them,and what is the charge?Please explain if the charge
continues after approval of the Agreement;
b.Have the owners of the identified private hydrants been notified of this filing and
the impact it could have on them?If so,please provide the notification sent to the
owners;
c.Please confirm all the private hydrants will start being billed in accordance with
the Company's current Schedule No.4.If this is not correct,please provide the
Schedule the private hydrants will start taking service under;
d.Please provide the expected additional annual revenue;
e.Please explain the accounting treatment of the additional revenue;and
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.3 NOVEMBER 16,2023
f.Please explain if previous Fire Hydrant Agreements with other entities have
included private hydrants being billed under the Company's approved tariffs.If
private hydrants were not billed under the Company's approvedtariffs,please
explain why they were not.
REQUESTNO.10:Please provide a comparison of this Agreement and other similar
Fire HydrantAgreements.Please list any major differences in this Agreement compared to other
Agreements along with an explanation for the reason for any differences.
REQUESTNO.11:Please provide a map of the WhitneyFire District,the location of
any current hydrants or potentiallynew hydrants covered by the Agreement,the location of any
Company certificated service territoryboundaries within a mile of the Fire District,and any
areas within the Fire District not within the Company's certificated service territory.
REQUESTNO.12:Section 2 of the Agreement (Commission Approval as Condition
Precedent)states that Veolia needs Commission approval of the proposed recovery of costs
associated with ownership,operation,installation,and maintenance of all hydrants,and approval
of the accounting treatment of the associated costs.Please provide the proposed accounting
treatment for the costs associated with the ownership,operation,installation,and maintenance of
the hydrants from this Agreement.
REQUESTNO.13:Please provide the followingfor the hydrants currentlyowned by
Whitney Fire District:
a.Remaining life of all hydrants;
b.Original cost to install;
c.Remaining book value;and
d.If application,the depreciation rate used.
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.4 NOVEMBER 16,2023
REQUESTNO.14:If there is money being exchanged between WhitneyFire District
and Veolia Water of Idaho,please provide the amount and proposed journal entries.
DATED at Boise,Idaho,this day of November 2023.
Deputy AttorneyGeneral
i:umise:prodreq/VEO-W-23-04 PR#1
FIRST PRODUCTION REQUEST
TO VEOLIA WATER IDAHO,INC.5 NOVEMBER 16,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16*DAY OF NOVEMBER 2023,
SERVED THE FOREGOING FIRST PRODUCTIONS REQUESTOF THECOMMISSIONSTAFFTOVEOLIAWATERIDAHOLLC,IN CASE NO.VEO-W-
23-04,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]
Ida Elmasian
CERTIFICATE OF SERVICE