200412141st Request of Staff to United Water.pdf

WELDON B. STUTZMAN
DONOY AN E. WALKER
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone] AND [phone]
IDAHO BAR NO. 3283 AND 5921
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
CEI VED
7nnr "'oj" L'/;J-LIce Pi"1 3: 07
UTi; iT ;;;
' .,-.~ ,-
,I.-, I Ii-,) Ci !t"iV;j~('.i;j'"JdVN
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.
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
Weldon B. Stutzman, Deputy Attorney General, requests that United Water Idaho Inc. (United
Water; Company) provide the following documents and information on or before TUESDAY,
JANUARY 4 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 IDAPA 31.01.01.228.
FIRST PRODUCTION REQUEST
TO UNITED WATER
DECEMBER 14 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.
The following production requests are in reference to Greg Wyatt's testimony:
Request No.1: Please explain why UWI is increasing its investment in the Bali Hai and
Maple Hills wells when both appear to have relatively poor water quality.
Request No.2: Please discuss whether the $3.5 million spent to add storage facilities to
the former South County system was considered in the purchase of the system by UWI. Was the
purchase price of the South County system adjusted to account for needed additions of storage
facilities? Please provide analysis showing why additional storage facilities were needed in the
South County area.
The following production requests are in reference to Scott Rhead's testimony:
Request No.3: Please provide a copy of pertinent sections of any reports or analysis
from the Treasure Valley Hydrologic Project to support your testimony on Southeast Boise
groundwater conditions.
Request No.4: Reference p., lines 13-21. On what is the Company relying to
project/expect future growth south of the airport? How much growth is expected and over what
time frame? Which customers/areas are now generally being served by well facilities developed
as part of the Southeast Boise Water Supply project? Is there currently capability to pump more
water from these wells?
Request No.5: Reference p. 7, lines 1-13. Provide any studies or analysis to support the
testimony concerning the "strength" of the aquifer system and its inability to produce water for
export to another area.
Request No.6: Please explain or theorize why peak day demand for 2004 was so much
less than for the previous four years as shown on page 9 of your testimony.
FIRST PRODUCTION REQUEST
TO UNITED WATER
DECEMBER 14, 2004
Request No.7: Reference p. 11 , lines 8-10. Please provide reports, correspondence or
other information documenting DEQ's "adoption of a program to allow compliance by source
management and concentration averaging." Identify those UWI wells that currently do not meet
arsenic limits.
Request No.8: Does UWI currently have any plans to implement Aquifer Storage and
Recharge using water from the CWTP? If so, please describe or provide a copy of those plans.
Request No.9: Reference p. 12, lines 14-23 and page 13 , lines 1-3. Please provide a
copy of the 1/8/02 Basis of Design Report.
Request No. 10: Will all portions of the Columbia Water Treatment Plant be operational
by March 2005? Ifnot, which portions will not be operational?
Request No. 11: Are there portions of the CWTP that have been oversized to
accommodate future expansion? What is the current capacity of the plant in MGD? How much
can the plant be expanded?
Request No. 12: Will the CWTP initially have the capability for pretreatment and
ultraviolet disinfection? If not, are there plans to add these treatment processes in the future?
What would cause these processes to be necessary in the future?
Request No. 13: Please provide any evaluations, analysis, comparisons, etc. used to
develop the planning cost estimates (capital and O&M) for membrane filtration and granular
media as stated on page 14, lines 13-22 and page 15, lines 1-2 of your testimony.
Request No. 14: Please provide a copy of the 4/22/02 Request for Proposals, a list of the
invited proposers, a copy of the four proposals received, a copy of the 6/18/02 final CDM
proposal, and a copy of the 9/20/02 contract with CDM.
Request No. 15: Please provide a copy of any document, agreement or correspondence
between UWI and CDM documenting the 1/14/04 guaranteed maximum price.
Request No. 16: What incentives does CDM have to complete the project at less than
the GMP?
Request No. 17: Please provide evidence of competitive bidding between
subcontractors.
Request No. 18: Please reconcile the difference between the guaranteed maximum price
of$16 844 498 as stated on page 20, line 3 and the amount of$18 201 714 shown on Exhibit 8
page 1.
Request No. 19: When will the final actual costs of the CWTP be known? How is UWI
proposing to establish rates in this case if the actual costs of the CWTP are not known until after
an order is issued? What if the final actual cost is less than the guaranteed maximum price?
FIRST PRODUCTION REQUEST
TO UNITED WATER
DECEMBER 14, 2004
Request No. 20: Reference p. 21 , lines 5-7. What does "partially operational in March
2005" mean? What is meant by "full operation
Request No. 21: Reference Exhibit 11. What factors cause cost differences between the
plants listed? What factors cause the CWTP unit costs to be so much higher than the average?
Are the costs shown only for CDM projects?
Request No. 22: Reference Exhibit 12. Why are so few conventional plants listed?
Request No. 23: Reference p. 23, lines 11. Please reconcile the purchased raw water
cost with Healy Exhibit 3 , Schedule 1 , p. 9.
Request No. 24: Reference p. 23 , lines 14. Please reconcile the miscellaneous cost with
Healy Exhibit 3, Schedule 1 , p. 15.
Request No. 25: Reference p. 24, lines 1-5. Please elaborate on how the operation of
other wells will be affected by the operation of the CWTP. For example, how will redundancy
or backup capacity be affected by the CWTP and what costs are affected by redundancy and
backup capacity? Please explain the workpaper provided for Healy Exhibit 3, Schedule 1 , p. 16
(Adjustment No. 16) showing how the reduction in operating expenses for these wells of
$139 580 was computed.
Request No. 26: Reference Exhibit 8. For each project listed, please provide the
completion date, the in-service date, and the final cost. For any projects not yet completed
please provide the expected completion date and documentation of a contract for completion.
Request No. 27: Please explain why UWI is drilling a new well (Maple Hills #2) at the
same site as Maple Hills #1 when Maple Hills #1 requires substantial treatment according to
your testimony on page 25, lines 8-21. What assurance is there that the new well won t have
water quality just as poor as Maple Hills #1 and also require treatment? Were any other sites
considered?
Request No. 28: Reference p. 25, lines 4-7. Is this purchase of water rights for future
use or would these rights be used immediately? Are any of these water rights necessary for the
CWTP, or would they be used somewhere else?
The following production requests are in reference to A. T. Wallace s testimony:
Request No. 29: Please provide correspondence between UWI and CDM concerning
contract conditions, costs and the guaranteed maximum price as referred to on page 5, lines 1-
of your testimony.
FIRST PRODUCTION REQUEST
TO UNITED WATER
DECEMBER 14, 2004
The following production requests are in reference to Frank Gradilone s testimony:
Request No. 30: Please provide a copy of all files and worksheets used by witness
Gradilone to determine test year revenues and to make all adjustments described in his
testimony. Include weather normalization analysis. Please provide in an Excel format.
Request No. 31: Please provide information to support your assumption that 75% of
new customers use alternate sources for irrigation.
Request No. 32: Please explain why the weather normalization adjustment was positive
for residential and commercial customers but negative for public sector customers.
Request No. 33: Please provide the underlying data used to develop Exhibit 6, Schedule
, pages 1 and 3 (to the extent the data are not included in your response to Request No.1).
Request No. 34: Please describe what types of things constitute "unbilled revenues" as
discussed on Exhibit 6 , Schedule 2, page 13.
The following production requests are in reference to Dennis Peseau s testimony:
Request No. 35: Please provide a copy of the cost of service study completed and
discussed by witness Peseau. Include an electronic copy of any other spreadsheets used to derive
allocation or seasonalization factors or to complete any of the cost of service analysis. Please
provide in an Excel format.
Request No. 36: Please provide United Water s proposal to establish an "initial summer
consumption block" as discussed on page 8 of your testimony.
Request No. 37: Please explain why you believe seasonal rates "Assure a better price
signal to and promote conservation by customers than do inverted block rates" as stated on page
, lines 21-23 of your testimony.
Dated at Boise, Idaho, this P/i./..... day of December 2004,
Weldon B. Stutzman
Donovan E. Walker
Deputy Attorneys General
Technical Staff: Rick Sterling
i :umisc/prodreq/uwiwO4.4 wsps 1
FIRST PRODUCTION REQUEST
TO UNITED WATER
DECEMBER 14, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF DECEMBER 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:
MARK GENNARI
UNITED WATER
200 OLD HOOK RD
HARRINGTON PARK NJ 07640
DEAN J MILLER ESQ
McD EVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
CERTIFICATE OF SERVICE