20051227Objection, requests exhibit D.pdf

McDevitt & Miller LLP
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November 30, 2005 CG(Q)~W
Via Hand Delivery
Jean Jewell, Secretary
, Idaho Public Utilities Commission
472 West WashingtOn Street
Boise, Idaho 83702
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Re: United Water Idaho Inc.---Notice of Intent to File General Rate Case
Dear Ms. Jewell:
Pursuant to IPUCRP 122, the Commission is hereby notified that United Water IdahoInc., ('"United Water " the "Company ) intends to file a general rate case on or after February 1
2006.
For the convenience of the Commission and Staff, the following information regardingthe intended filing is also provided:
As directed by the CormIrission in Order No. 29838, rate base will be calculated using a
13 month average methodology. This is without prejudice to United Water s right to pursue theappeal to the Idaho Supreme Court pending in Case No. UWI,04'4.
The filing will propose a test year consisting of six month actual data (ending October 31
2005) and sL'I: month projected data. The E~~2osed test ~ar will b M~y 200~ throl.!gtLAp-.nl2006. --
The filing will propose that any increase in revenue awarded by the Commission be
spread across existing rate elements on a uniform percentage basis. United Water will notpropose any change to the current rate design. In light of this, and because the Company s costof service was recently reviewed in Case No. UWI,04,, the filing will request a waiver of
IPUCRP 121( e) which requires that a cost of service study accompany a general rate case
application.
Similarly, because the Company s cost of capital was recently reviewed and resolved by
settlement in Case No. UWI,W,04,, the filing will propose that the Company s cost of equityestablished in tha t case be used in the intended filing. Cost of debt would be the actual cost, asdetermined by the same methodology utilized in the UWI, W,04'04 case. Accordingly,testimony of a separate cost of capital witness will not be presented.
EXHIBIT D
Jean Jewell, Secretary
November 30, 2005
Page 2
In general, the purpose of the intended filing is to update the Company s rate making
calculations to conform with the requirements of Order No. 29838 and to provide revenues
sufficient to allow the Company the opportunity to earn a reasonable return. United Water will
not introduce issues it believes to be new or controversial. Accordingly, the Company will
request that the case be processed on an expedited basis, to the extent that can be accomplished
consistent with the Commission s audit and public participation responsibilities.
Very Truly Yours
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Dean J. Miller
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United Water Idaho Inc.