20240215VEO to Staff 1-5.pdf

VEOLIA WATER IDAHO INC.’S RESPONSE TO STAFF’S FIRST PRODUCTION REQUEST PAGE 1 OF 2
18214795.1)
Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorneys for Veolia Water Idaho, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE CITY OF EAGLE
AND VEOLIA WATER IDAHO’S JOINT
APPLICATION TO AMEND VEOLIA
WATER IDAHO’S CERTIFICATE OF
PUBLIC CONVENIENCE AND NECESSITY
Case No. VEO-W-23-05

VEOLIA WATER IDAHO, INC.’S RESPONSE
TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF
Veolia Water Idaho, Inc. submits the following response to the First Production Request
of the Commission Staff to Veolia Water Idaho, Inc. dated January 26, 2024.
DATED: February 15, 2024.

By:_____________________________
Preston N. Carter
Givens Pursley LLP
Attorneys for Veolia Water Idaho, Inc.

RECEIVED
Thursday, February 15, 2024 10:11:01 AM
IDAHO PUBLIC
UTILITIES COMMISSION

VEOLIA WATER IDAHO INC.’S RESPONSE TO STAFF’S FIRST PRODUCTION REQUEST PAGE 2 OF 2
18214795.1)
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT on February 15, 2024 I caused a true and correct copy of the
foregoing to be served upon the following parties as indicated below:

Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
[e-mail]

Email
U.S. Mail
Fax
Hand Delivery

Norman M. Semanko
Parsons Behle & Latimer
800 W. Main Street
Suite 1300
Boise, ID 83702
[e-mail]

Email
U.S. Mail
Fax
Hand Delivery

The City of Eagle
Mayor Brad Pike
660 E. Civic Lane
PO Box 1520
Eagle, ID 83616
[e-mail]

Email
U.S. Mail
Fax
Hand Delivery

Preston N. Carter

~
□ □ □
/ ~ ~
VEOLIA WATER IDAHO, INC.
CASE VEO-W-23-05
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cathy Cooper
REQUEST NO. 1:
Please provide the legal descriptions for the two areas (Area 4 and the Eagle Skate Park)
the Company is requesting to be removed from its Certified Service Area.
RESPONSE NO. 1:
The Eagle Skate Park is not within Veolia’s Certificated Service Area. The legal
description for Area 4 is included on pages 3 and 4 of the attached document.
VEO-W-23-05
IPUC Staff PR 1
Page 1 of 1
LEGAL DESCRIPTION
Page 1 OF 1

August 3, 2022
Project No.: 122092
EXHIBIT “A”

VEOLIA WATER
EAGLE WATER COMPANY SERVICE AREA DESCRIPTION

A parcel located in Sections 2, 3, 7, 8, 9, 10, 11, 14, 15, 16, 17 and 22 of Township 4 North, Range 1 East,
Boise Meridian, City of Eagle, Ada County, Idaho, being more particularly described as follows:

Commencing at the Section Corner common to Sections 7, 8, 17 and 18 of said Township 4 North,
Range 1 East, said point being the POINT OF BEGINNING;

Thence westerly on the Section line common to said Sections 7 and 18 to the East 1/16th Corner
common to said Sections 7 and 18;
Thence northerly on the north-south 1/16th line of the Southeast One Quarter of said Section 7
to the Southeast 1/16th Corner of said Section 7;
Thence easterly on the east-west 1/16th line of the Southeast One Quarter of said Section 7 to
the South 1/16th Corner common to said Sections7 and 8;
Thence northerly on the Section line common to said Sections 7 and 8 to the North 1/16th
Corner common to said Sections 7 and 8, said point being the Southwest corner of Covenant Hill
Subdivision, recorded in Book 95 of Plats at Page 11635 of Ada County Records;
Thence on the east-west 1/16th line of the Northwest One Quarter of said Section 8 to a point on
the centerline of the New Dry Creek Canal;
Thence southeasterly on the centerline of the New Dry Creek Canal to the Southeast corner of
said Covenant Hill Subdivision, said point being a point on west boundary line of Downing
Downs Subdivision No. 3, recorded in Book 28 of Plats at Page 1771 of Ada County Records;
Thence northerly on the westerly boundary line of said Downing Downs Subdivision No. 3 and
said line extended to the West 1/16th Corner common to Sections 5 and 8, said point being in
West Floating Feather Road;
Thence easterly on the Section Line common to Sections 5 and 8 to the Section Corner common
to Sections 4, 5, 8 and 9;
Thence easterly on the Section Line common to Sections 4 and 9 to the Section Corner common
to Sections 3, 4, 9 and 10;
Thence easterly on the Section Line common to Sections 3 and 10 to the Section Corner
common to Sections 2, 3, 10 and 11);
Thence easterly on the Section Line common to said Sections 2 and 11 to the One Quarter
Corner common to said Sections 2 and 11;
Thence southerly on the north-south mid-section line of said Section 11 to the Center One
Quarter Corner of said Section 11;
Thence easterly on the east-west mid-section line of said Section 11 to the Center-East 1/16th
Corner of said Section11, said corner also being the northeast corner of the Idaho Veterans
Cemetery, as same is shown on Record of Survey Number 9180 of Ada County Records;
~ w~ THE i II LAND ~~◄ GROUP
462 East Shore Drive, Suite 100, Eagle, Idaho 83616 208.939.4041 thelandgroupinc.com
August 3, 2022
Page 2

Site Planning • Landscape Architecture • Civil Engineering • Surveying
462 E. Shore Drive, Suite 100 • Eagle, Idaho 83616 • P 208.939.4041 • www.thelandgroupinc.com
Thence southwesterly, and southeasterly on the easterly boundary line of said Idaho Veterans
Cemetery to the centerline of the Farmers Union Canal;
Thence northwesterly on the centerline of the Farmers Union Canal to a point on the easterly
boundary line of that parcel of land as shown on Record of Survey Number 10056 of Ada County
Records;
Thence southerly on the easterly boundary line of said parcel of land as shown on Record of
Survey Number 10056 to the southeast corner of said Parcel;
Thence westerly on the southerly boundary line of said Record of Survey Number 10056 Parcel
and said line extended to a point on the west Line of said Section 11;
Thence southerly on the west Line of said Section 11 to the Section Corner common to Said
Sections 10, 11, 14 and 15;
Thence southerly on the Section line common to said Sections 11 and 14 to the West 1/16th
Corner common to said Sections 11 and 14;
Thence southerly on the north-south 1/16th line of the Northwest Quarter of said Section 14 to
the Northwest 1/16th corner of said Section 14, said point being on the northerly boundary line
of Randall Acres Subdivision No. 8, recorded in Book 13 of Plats at Page 805 of Ada County
Records;
Thence westerly on the northerly boundary line of Randall Acres Subdivision No. 8 to the
northeast corner of Lot 12, Block 1 of said Randall Acres Subdivision No. 8;
Thence southerly on the easterly lot line of said Lot 12 and said line extended to a point on the
north line of Block 2 of said Randall Acres Subdivision No. 8;
Thence westerly on the north line of said Block 2 to the northeast corner of Lot 15, Block 2 of
said Subdivision No. 8;
Thence southerly on the easterly lot line of Lots 15 and 36, Block 2 and said line extended to a
point on the northerly line of Block 3 of said Subdivision No. 8;
Thence westerly on the north line of said Block 3 to the northeast corner of Lot 6, Block 3 of said
Subdivision No. 8;
Thence southerly on the east line of said Lot 6 to and said line extended to a point on the
northerly boundary line of Randall Acres Subdivision Number 9, recorded in Book 13 of Plats at
Page 807 of Ada County Records;
Thence westerly on the northerly boundary line of said Randall Acres Subdivision Number 9 to
the northeast corner of Lot 12, Block 4 of said Randall Acres Subdivision Number 9;
Thence southerly on the east line of said Lot 12, Block 4 and said line extended to a point on the
northerly line of Block 3 of said Randall Acres Subdivision Number 9;
Thence easterly on the north line of said Block 3 to the northeast corner of Lot 29, Block 3 of
said Subdivision Number 9;
Thence southerly on the east line of said Lot 29, Block 3 to the southeast corner of said Lot 29
which point is common to the northeast corner of Lot 9, of said Block 3;
Thence southerly on the east line of said Lot 9, Block 3 and said line extended to the north line
of Block 2 of said Randall Acres Subdivision Number 9;
Thence easterly on the north line of said Block 2 to the northeast corner of Lot 32, Block 2 of
said Subdivision Number 9;
Thence southerly on the easterly lot line of Lot 32 and Lot 6 of said Block 2 and said line
extended to a point on the northerly line of Block 1 of said Randall Acres Subdivision Number 9;
August 3, 2022
Page 3

Site Planning • Landscape Architecture • Civil Engineering • Surveying
462 E. Shore Drive, Suite 100 • Eagle, Idaho 83616 • P 208.939.4041 • www.thelandgroupinc.com
Thence easterly on the north line of said Block 1 to the northeast corner of Lot 29, Block 1 of
said Subdivision Number 9;
Thence southerly on the east line of said Lot 29, Block 1 to the southeast corner of said Lot 29,
Block 1 which point is common with the northeast corner of Lot 4, of said Block 1;
Thence westerly on the lot line common to said Lots 29 and 4 of said Block 1 to the northerly lot
corner common to Lots 3 and 4 of said Block 1;
Thence southerly on the lot line common to said Lots 3 and 4, Block 1 to the southerly lot corner
common to Lots 3 and 4 of said Block 1, said point being on the northerly right of way line of
West State Street;
Thence westerly on the northerly right of way line of West State Street to a point on the west
line of Section 14 of said of Township 4 North, Range 1 East;
Thence southerly on the west line of said Section 14 to the Section Corner common to said
Sections 14, 15, 22 and 23;
Thence Southerly on the west line of said Section 22 to a point on the centerline of the Boise
River;
Thence westerly on the meanderings of the centerline of the Boise River to the POINT OF
BEGINNING.

ALSO INCLUDING:

A parcel located in the Southwest Quarter of the Northwest Quarter of Section 4 of Township 4 North,
Range 1 East, Boise Meridian, City of Eagle, Ada County, Idaho, being more particularly described as
follows:

Commencing at the Section Corner common to Sections 4, 5, 8 and 9 of said Township 4 North, Range 1
East;
Thence northerly on the Section line common to said Sections 4 and 5 to the One Quarter Corner
common to said Sections 4 and 5, said point being the POINT OF BEGINNING;

Thence northerly on the Section line common to said Sections 4 and 5 to the North 1/16th
Corner common to said Sections 4 and 5;
Thence continuing northerly on the Section Line common to said Sections to the northwest
corner of Bighorn No. 2 Subdivision, recorded in Book 79 of Plats at Page 8470 of Ada County
Records;
Thence easterly on the north boundary line of said Bighorn No. 2 Subdivision to an angle point in
said boundary line, being the northerly corner common to Lots 3 and 6, Block 1 of said Bighorn
No. 2 Subdivision;
Thence northeasterly on the west boundary line of said Bighorn No. 2 Subdivision to an angle
point in said boundary line, being the northwest corner of Lot 8, Block 1 of said Bighorn No. 2
Subdivision;
Thence easterly on the north boundary line of said Bighorn No. 2 Subdivision to an angle point in
said boundary line, being the northeast corner of Lot 8, Block 1 of said Bighorn No. 2
Subdivision;

August 3, 2022
Page 4

Site Planning • Landscape Architecture • Civil Engineering • Surveying
462 E. Shore Drive, Suite 100 • Eagle, Idaho 83616 • P 208.939.4041 • www.thelandgroupinc.com
Thence southerly on the east boundary line of said Bighorn No. 2 Subdivision to an angle point
in said boundary line, being the Northwest 1/16th Corner of said Section 4;
Thence southerly on the north-south 1/16th Section line of the Northwest Quarter of said
Section 4 to the Center-West 1/16th Corner of said Section 4;
Thence westerly on the east-west mid-section line of said Section 4 to the POINT OF
BEGINNING.

PREPARED BY:
The Land Group, Inc.

James R. Washburn
8-3-2022
VEOLIA WATER IDAHO, INC.
CASE VEO-W-23-05
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cathy Cooper
REQUEST NO. 2:
Attachment 9 included with the Application provides a projected customer cost
comparison for 23 customers. On page 4 of the application, it states Area 4 currently includes 25
current Veolia customers. Please explain the reason for the different number of customers
between Attachment 9 and the Application.
RESPONSE NO. 2:
There are 25 meters associated with Area 4, but three meters are located at one address.
Subtracting two of the three results in the count of 23 customers. The application qualifies the
customer count based on number of service connections.
VEO-W-23-05
IPUC Staff PR 2
Page 1 of 1
VEOLIA WATER IDAHO, INC.
CASE VEO-W-23-05
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jarmila Cary
REQUEST NO. 3:
Please provide the proposed journal entries to remove the Company owned assets from
its books.
RESPONSE NO. 3:
The journal entry to remove the fully depreciated Company owned assets from its books
would be to debit to Accumulated Depreciation and credit Plant in Service for the original asset
cost of $47,530.16. These are assets recorded during the Eagle Water Company acquisition,
whose book value was fully offset by Accumulated Depreciation.
DR. 10800 Accumulated Depreciation $47,530.16
CR. 10100 Utility Plant in Service ($47,530.16)
The journal entry to remove Company owned assets from its books which were installed
since the Eagle Water Company acquisition, which are not yet fully depreciated, would be to
debit the Impairment account for the current Net Book Value (NBV or original cost less
accumulated depreciation), debit Accumulated Depreciation and credit Plant in Service for the
original asset cost.
DR. 71225 Impairment - Other $10,554.24*
DR. 10800 Accumulated Depreciation $ 520.44*
CR. 10100 Utility Plant in Service ($11,074.68)
*The impairment amount and estimated accumulated depreciation reflected is calculated
as of January 2024 and subject to change when the journal entry is recorded.

VEO-W-23-05
IPUC Staff PR 3
Page 1 of 1
VEOLIA WATER IDAHO, INC.
CASE VEO-W-23-05
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jarmila Cary
REQUEST NO. 4:
Is there any deferred income tax associated with the assets proposed to be transferred in
this case? If so, please provide the proposed journal entries and amounts to be removed.
RESPONSE NO. 4:
The deferred tax impact associated with removing Company owned assets from its books
would be immaterial due to the amount of the Net Tax Basis. The assets which are not fully
depreciated and were installed since the Eagle Water Company acquisition, have an Original
Cost of $11,074.68 and an estimated Net Tax Basis of $10,410. The related deferred tax would
be immaterial based on analysis and determination by the Company’s Tax Director.
VEO-W-23-05
IPUC Staff PR 4
Page 1 of 1
VEOLIA WATER IDAHO, INC.
CASE VEO-W-23-05
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cathy Cooper
REQUEST NO. 5:
Attachment 8 outlines a service connection at 70 W. Floating Feather Road as a customer
of the Company. It appears the property is not within the Company’s certificate of public
convenience and necessity (“CPCN”) No. 143 and not within City of Eagle’s boundaries. Please
answer the following:
a. Is the property included in CPCN No. 143?
b. Attachment 8, cell I36 states that Eagle Water Company connected the customer in
2022. Why did it connect the property after Order No. 35247?
c. Are there more than one service points, off of Eagle Road or off of Floating Feather
Road, that services 70 W. Floating Feather Road? If so, please identify each location.
RESPONSE NO. 5:
This service is paid for by the City of Eagle, but the water is for the owner of 70 W.
Floating Feather Road. Our understanding is that the City is paying the water bill as a condition
of a water right proceeding where the City impacted the homeowner’s well.
a. The service at 70 W. Floating Feather Road is not in CPCN No. 143, but is a
contiguous property to the certificated service area.
b. It’s correct that Eagle Water Company (EWC) did the construction work, EWC had
already been paid to install the service prior to close of the acquisition, and they did
the construction work in early 2022 with a Veolia Inspector on site to observe the
installation.
c. There is only one service point to 70 W. Floating Feather Road - off of Eagle Road.
VEO-W-23-05
IPUC Staff PR 5
Page 1 of 1