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Home My WebLink About200408111st Request of Staff to United Water.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 IDAHO BAR NO. 1895 """ J (\ t t-,, ;: ~' '1 .~.....IL. ~~, 2004 f\lJG " Pi~1 2: ,": . () i) \3 Lie ,\ T t! I ' F S C 0 f~;1 f'~1 i S 51 O'H '-...; . .... - Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF UNITED WATER IDAHO INC., FOR AN AMENDMENT TO ITS CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY NO. ) 142 AND FOR AN ACCOUNTING ORDER. CASE NO. UWI-04- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO UNITED WATER IDAHO INC. The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Scott Woodbury, Deputy Attorney General, requests that United Water Idaho Inc. (United Water; Company) provide the following documents and information on or before FRIDAY SEPTEMBER 3, 2004. This Production Request is to be considered as continuing, and United Water 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 produced. Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder. For each item, please indicate the name of the person(s) preparing the answers , along with the job title of such person(s) and the witness who can sponsor the answer at hearing. FIRST PRODUCTION REQUEST TO UNITED WATER AUGUST 11 , 2004 Reference IDAP A 31.01.01.228. For documents provided please include the name and phone number of the person preparing the document, and the name, location and phone number of the record holder. For all responses to the following requests, please provide all workpapers, diskettes (3.5 in.) and all underlying formulas in Excel (version 5) language. Request No.1: Please indicate the relationship between United Water Idaho Inc. and United Water Works Inc. If affiliates, did the two entities share any directors and/or officers at the time of the Carriage Hill Design-Build Promissory Note execution? If so, please identify. Request No.2: Please provide copies of any and all written and electronic documentation, correspondence and memos not otherwise provided as part of the Application: A. Between Carriage Hill and United Water Works; B. Between Carriage Hill and United Water Idaho; C. Between United Water Idaho and United Water Works, and D. Between United Water Idaho and its corporate parent regarding (1) the Application s Exhibit A Design-Build Promissory Note; (2) the proposed Purchase Agreement between United Water Idaho and the City of Nampa (Application Exhibit C), and (3) the proposed payment of $350 000 in sale proceeds to United Water Works, Inc. Request No.3: Application Exhibit A Design-Build Promissory Note states in paragraph 5 that "holder may foreclose all liens securing payment hereof. A. Please indicate what liens, if any, or other forms of security, both recorded and unrecorded, exist to secure payment of the Design-Build Promissory Note. B. Please indicate whether Carriage Hill is now or was ever late in payment or in default under the Design-Build Promissory Note. If so, please provide detail and indicate what enforcement efforts were undertaken and/or waived by Water Works. Please provide copies of all related correspondence, memos, email, etc. both (1) between Carriage Hill and United Water Works; (2) between United Water Idaho Inc and United Water Works; and (3) United Water Idaho Inc. and its corporate parent. FIRST PRODUCTION REQUEST TO UNITED WATER AUGUST 11 , 2004 Request No.4: Please indicate whether pursuant to the Company s rules and regulations governing non-contiguous expansion (Rule 78-84) and pursuant to Rule 74-77 of the Company rules relating to water main extensions (special facilities), Carriage Hill contributed all water supply facilities, including well, to United Water Idaho Inc. Please indicate whether the facilities acquired by United Water from Carriage Hill are unencumbered by any liens or claims. Please provide copies of any studies regarding the appraised value of the distribution system, well, and any and all other physical plant used by United Water for service to Carriage Hill. Request No. A. Please indicate whether any system related Company and/or developer contributed water treatment or chlorination equipment was installed for water service to Carriage Hill. If so, please provide detail. B. Please indicate whether any other Company and/or developer contributed investment was made for the providing of water service to Carriage Hill. If so, please provide detail. Request No.6: Please provide revenues, expenses (depreciation & amortization expense, salaries, taxes, etc.) and rate base associated with this subdivision in a rate case format. Please provide workpapers and documents supporting these amounts and calculations. Request No.7: Please calculate the revenue requirement associated with the components of this sale as identified in Production Request Number 6. Please provide workpapers and documents supporting these calculations. Request No.8: Please provide a listing of assets being transferred in this sale and the associated cost, accumulated depreciation and net book value. Please provide workpapers and documents supporting these calculations. Request No.9: To the extent not previously provided, please provide a listing of the detail transactions in MJ Cost #2537 and 2842 identified in the Company s Exhibit E. Please also provide the justification for the inclusion of them within this sale. FIRST PRODUCTION REQUEST TO UNITED WATER AUGUST 11 , 2004 Request No. 10: To the extent not previously provided, please provide the detail of the legal and IPUC filing expenses" identified in the Company s Exhibit E. Please provide the justification for the inclusion of them within this sale. Request No. 11: Please describe and provide any agreement between United Water Idaho and United Water Works, Inc. for the reimbursement of legal and administration fees associated with this sale. If no such agreement exists, please explain why. Request No. 12: Please provide a listing by lot number of refunds paid and those payable related to the Carriage Hill subdivision. Request No. 13: Please provide a listing of the number of customers being transferred in this sale and the associated revenues collected in each of the last three years (2001 , 2002 and 2003) and year-to-date 2004. Please provide workpapers and documents supporting these calculations. Request No. 14: Please describe the reason for the refunds payable to Carriage Hill at closing identified in the Company s Exhibit E. Request No. 15: Please identify the legal basis upon which United Water Idaho stopped making refund payments to Carriage Hill, L. Request No. 16: Please provide a schedule listing the payment date(s) and amount(s) of the advances for construction identified in the Company s Exhibit E. Request No. 17: Please provide a schedule listing the payment date(s) and amount(s) of the contributions in aid of construction identified in the Company s Exhibit E. Request No. 18: Please provide an inception to date schedule of the United Water Works, Inc. loan with Carriage Hill, L.C. Please include within this schedule the payments FIRST PRODUCTION REQUEST TO UNITED WATER AUGUST 11 , 2004 made (date and amount), how those payments were applied to the loan principal and interest and the balance of the loan. Request No. 19: Please allocate the $375 000 system purchase price between payment of principal, interest, and premium. Please separately identify the amounts paid to United Water Works, Inc. and the Company. Dated at Boise, Idaho, this II day of August 2004. Technical Staff: Rick Sterling Patricia Harms Joe Leckie SW:i:umisc/prodreq/uwiwO4.3.swrpsphjl prod reg FIRST PRODUCTION REQUEST TO UNITED WATER AUGUST 11 , 2004 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF AUGUST 2004 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO UNITED WATER IDAHO INC., IN CASE NO. UWI-04-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE FOLLOWING: GREGORY P WYATT UNITED WATER IDAHO INC PO BOX 190420 BOISE, ID 83719-0420 DEAN J MILLER ESQ McDEVITT & MILLER LLP PO BOX 2564 BOISE ID 83701 SECRET CERTIFICATE OF SERVICE