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HomeMy WebLinkAbout200412232nd Request of Staff to United Water.pdf' ., .- \! r: :. \ .1 L ~) ' ~...--.. 0: Y 1 L:, WELDON B. STUTZMAN DONOVAN E. WALKER DEPUTY ATTORNEYS GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0318 AND (208) 334-0357 IDAHO BAR NO. 3283 AND 5921 . i r: ". ... r,n,q nr:r ? M'i \\: ijU'i u\~r:;.. . """, U T\Ll llE.~); cU1"\;'f\~~S\ON 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 AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO. SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO UNITED WATER IDAHO INC. CASE NO. UWI-04- The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Weldon B. Stutzman, Deputy Attorney General, requests that United Water Idaho Inc. (United Water; Company) provide the following documents and information on or before THURSDAY JANUARY 13, 2005. The Staff requests the Company place special priority on answering these requests as soon as possible. In recognition that some questions require less time to answer than others, Staff asks that the Company file responses in batches as they are completed rather than wait for the most time-intensive questions to be finished. The Company is reminded that responses pursuant to Commission Rules of Procedure mUst include the name and phone number of the person preparing the document, and the name location and phone number of the record holder. Reference IDAP A 31.01.01.228. SECOND PRODUCTION REQUEST TO UNITED WATER DECEMBER 23 , 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, and the name and telephone number of the person preparing the documents. Please identify 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 if need be. Request No. 38: Please provide an estimate of the costs that would be incurred if United Water billed monthly instead ofbi-monthly. Provide a breakdown of these costs by category, including categories such as personnel, vehicles, bill preparation, mailing, accounting, etc. How would the estimate be affected if monthly billing were performed only during the summer season? Request No. 39: Would it be possible for United Water to continue to read meters bi- monthly but bill customers monthly in the summer by, for example, billing for only half of the metered consumption? Please explain how this could be accomplished or why it could not. Request No. 40: Has United Water investigated the cost and feasibility of implementing automated meter reading in its system? If so , please provide a copy of any reports, studies or cost estimates associated with such an investigation. Request No. 41: Has United Water investigated the cost and feasibility of implementing on-line billing and payment options? If so, please provide a copy of any reports, studies or cost estimates associated with such an investigation. Request No. 42: If United Water is granted an increase as proposed, how does United Water propose to mitigate the customer impacts of higher summertime bills? Request No. 43: Please provide a copy of the Company s water conservation plan. Please identify and describe any changes in the plan since 1993 , and identify and describe any water conservation programs or efforts not contained in the plan. Request No. 44: Please assess and quantify the impact of United Water s water conservation program on system peak hourly, system peak daily, and system annual consumption. SECOND PRODUCTION REQUEST TO UNITED WATER DECEMBER 23, 2004 Request No. 45: Please provide a list of all water rights (applications, permits or exchanges) acquired by United Water since the last rate case. For each water right acquired provide the water right number, the quantity of the right, whether the right is for surface water or groundwater, the amount paid to acquire the right, the place where the water right is authorized to be used and a brief description of the purpose of the right (e., to supply the CWTP, a right associated with a specific well, etc.). Please include similar information for any water rights transfers that have been executed since the last rate case. Request No. 46: Please describe the water right transfer application now pending before the Idaho Department of Water Resources. What is the purpose of the transfer and what will be the effect of the transfer if approved? What is the status of the transfer application and when does United Water expect a ruling on the application? Request No. 47: Please provide a schedule to supplement Healy Exhibit No., page showing the rate base totals as were approved in United Water s last rate case ($98 862 937) and the additions to rate base requested in this case ($140 062 546) for each of the 11 lines shown in the Exhibit. Please include a column in this schedule that lists the rate base approved in the last rate case and a column for each year s change in rate base for lines 1 through lIon Exhibit No. 1. Please provide detailed descriptions of the plant additions and retirements and the underlying reasons for the additions and retirements. Request No. 48: Please prepare a supporting schedule of plant, contributions in aid of construction and customer advances for construction that includes the dollar amount by project by year for the plant, contributions and advances included in the last rate case through the test year proposed in this rate case. The totals on this schedule should match the totals on the schedule prepared in response to Production Request No. 47. If the totals do not match, please provide a reconciliation between the two schedules describing the reason and dollar amount for each difference. Request No. 49: Please describe and provide example of the entries utilized by the Company to record additions and retirements in Plant in Service. Please include within your description the entries to accumulated depreciation. Request No. 50: Please provide a schedule that individually identifies all retirements from Plant in Service that occurred during the test year by proj ect. Please include within this schedule the total book cost of each retirement, the total accumulated depreciation and the depreciation expense included within the test year for the retired plant. Request No. 51: Please provide all documentation related to the Columbia Water Treatment Plant costs. Please include accounting reports summarizing the costs (by date document number, dollar amount, account posted and payee), invoices, contracts/agreements contract payment requests, budget to actual project reports, any monitoring of costs reports, any internal or external review documents, cost estimates and proj ect reports provided to management. SECOND PRODUCTION REQUEST TO UNITED WATER DECEMBER 23, 2004 Request No. 52: Please provide all documentation related to the depreciation expense calculated for the Columbia Water Treatment Plant (CWTP). Please include all documentation regarding the reasoning for the depreciation rate applied for each component of the plant especially the membrane filters. For those filters, please provide the documentation supporting the statements in J. Healy s testimony regarding the useful life of these filters including any information that has been obtained since the date of this testimony. Please include: a. all information from the manufacturer regarding the filters b. all information provided by CDM Construction c. any information regarding how the filters are used in other plants such as the number of gallons treated by the plants using the filters, the quality and characteristics of the water filtered and its comparability to the water to be filtered by CWTP, and whether the Michigan plant replaced its filters in 2004. Request No. 53: Please provide a copy of the Company s employee relocation policy that includes a description of when relocation expenses will be paid, any cost limitations associated with those expenses and which employees are eligible for relocation expense reimbursement. Request No. 54: Please provide further details on the Company s proposal regarding assistance for low-income customers. How does United Water determine which customers are low income? Request No. 55: Please provide the Company s written record of complaints and requests for conferences from the year 2003 , kept pursuant to Rule 403 of the Commission Utility Customer Relations Rules (UCRR) IDAPA 31.21.01.403. Request No. 56: Please provide the number of disconnections due to non-payment for the past three years, listed by month. Request No. 57: What is the Company s policy with respect to responding to a customer s report of a leak on the customer s side of the meter? If the reported leak results in an unusually high bill, does the Company routinely adjust the bill? If so, how is the adjustment calculated? Are high bill complaints attributed to problems with the customer s separate irrigation system, is the policy the same? If not, please explain how such complaints are handled and how bill adjustments, if any, are handled. Request No. 58: Please provide a sample copy of the Rules Summary required by Rule 701 (UCRR) sent to customers served. Please explain how and when these customers are given the summary? Request No. 59: Please provide a sample copy of the form used as required by UCRR Rule 104 entitled Written Explanation for Denial of Service or Requirement of Deposit. SECOND PRODUCTION REQUEST TO UNITED WATER DECEMBER 23 2004 Request No. 60: Under what circumstances does United Water collect deposits? Request No. 61: Please provide a sample copy of the initial receipt for the first deposit installment as required by Rule 109 (UCRR). Provide a copy of the receipt for the second installment, if such receipt is different from the first. Request No. 62: Please provide sample bills that are current and NOT past due for customers. Request No. 63: Please provide a sample bill with a past due balance. Request No. 64: In accordance with Rule 206.03 (UCRR), please provide a sample copy of a Customer Notice that informs the customer of the Company s intent to: a) transfer an amount owed from a former service location, or 2) transfer an amount owed for another person bill. Request No. 65: Please provide a sample copy of the Notice left at the customer premises following disconnection of service for non-payment. Request No. 66: Please provide a sample copy of the Annual Rate Summary provided to customers as required by Rule 101 , Utility Customer Information Rules (UCIR) IDAPA 31.21.02.101. Request No. 67: Does the Company make available to customers a pre-printed form for the medical emergency certificate required by Rule 308 (UCRR)? If so, please provide a sample copy of the form. Request No. 68: For master-metered accounts and residents or occupants who are not customers but who are in jeopardy of losing service, please provide a sample copy of the Notice required by Rule 312 (UCRR). Request No. 69: Please provide a sample copy of the Seven Day Notice required by Rule 304 (UCRR) when the Company intends to terminate service under Rule 302. Request No. 70: Please provide a sample copy of the written Twenty-Four Hour Notice required under Rule 304 (UCRR). Request No. 71: Please provide a sample copy of any brochure or other printed material regarding the Company s Third-Party Notice program. How and when is this material provided to customers? Request No. 72: Are any of United Water s brochures, notices, forms, and bills available in Spanish or other languages? If so, please indicate the language( s) and information available. SECOND PRODUCTION REQUEST TO UNITED WATER DECEMBER 23, 2004 Request No. 73: If there is written material available in languages other than English how are customers made aware of their availability? Request No. 74: How many customer service representatives in the Customer Contact Center speak Spanish? Is there always a Spanish-speaking representative available during Call Center hours of operation? Request No. 75: What provisions are made for assisting customers who speak languages other than English or Spanish? Request No. 76: How many attempts are made to contact customers either in person or by telephone prior to disconnection as required by Rule 304.02 (UCRR)? Request No. 77: Under what circumstances would a personal visit be made to satisfy the requirements of Rule 304.02 (UCRR)? Request No. 78: Does the Company use an automated system to make outgoing calls to satisfy the requirements of Rule 304.02 (UCRR)? If so, during what hours are calls made to customers? Request No. 79: In compliance with Rule 304 (UCRR), when calling a customer for the Twenty-Four Hour Notice, what percentage of call attempts reach a live customer? Request No. 80: With the Company s automated telephone system, when a customer answering machine or voice mail picks up the call, does the automated system leave a message? If so, please provide the text of that message. Request No. 81: Does the Company routinely physically disconnect service after a customer requests closure of an account or disconnection of service? If so, what are the average and maximum intervals between receipt of the customer s requests and actual disconnection of service? Request No. 82: What percentage of out-of-cycle meter disconnections are completed within three calendar days? Four to five calendar days? More than five calendar days? Request No. 83: When meters are left on between occupants, is a reading always taken again when a new tenant moves in? If not, please explain how the Company determines whether to read the meter. Request No. 84: In situations where a meter is not physically disconnected between occupants, does the ending meter reading date given on bills for the departing customer correspond to the actual date the meter was read? Ifnot, please explain. SECOND PRODUCTION REQUEST TO UNITED WATER DECEMBER 23, 2004 Request No. 85: In situations where a meter is not physically disconnected between occupants, does the beginning meter reading date given on the bill for the new customer correspond to the actual date the meter was read following the customer s request to initiate service? If not, please explain. Request No. 86: How many out-of-cycle meter readings were taken in 2003 where service was not physically disconnected between occupants? Request No. 87: How many out-of-cycle meter readings were taken in 2003 where service was physically disconnected? Request No. 88: Does United Water handle customer calls for other entities? If so what are those other entities? Are the United Water complaint and inquiry calls tracked separately? If , please quantify calls by United Water complaints and inquiries and All Other entity calls. Dated at Boise, Idaho, this ~rJ day of December 2004. eldon B. Stutzman Donovan E. Walker Deputy Attorneys General Technical Staff: Rick Sterling Patricia Harms Carol Cooper i :umisc/prodreq/uwiwO4.4 wsdwpsccph2 SECOND PRODUCTION REQUEST TO UNITED WATER DECEMBER 23 , 2004 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 23rd DAY OF DECEMBER 2004 SERVED THE FOREGOING SECOND 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: MARK GENNARI UNITED WATER 200 OLD HOOK RD HARRINGTON PARK NJ 07640 DEAN J MILLERESQ McD EVITT & MILLER LLP PO BOX 2564 BOISE ID 83701 SECRETARY CERTIFICATE OF SERVICE