200501071st Response of UWI to Staff.pdf

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Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
ioe~mcd~-miller.com
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UTiLITIES CO !SSfON
Attorneys for Applicant
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-O4-
UWlD'S RESPONSE TO STAFF'
PRODUCTION REQUESTS
COMES NOW United Water Idaho Inc.
, ("
United"
, "
the Company ) and responds
to Request Nos. 30, 31 , 32, 33, 34, 35 and 37 of the Staffs First Production Request and also
responds to Request Nos. 56, 57, 59, 60, 61 , 62, 63 , 65, 67, 69, 70, 71 , 72, 73 , 74, 75, 76, 77, 78
79,80,85,86,, and 88 of the Second Production
iU~t
of the Commission Staff.
Dated this Jt2tlay of January, 2005.
McDEVITT & MILLER LLP
Dean J. Miller
Attorneys for United Water Idaho Inc.
UWID's RESPONSE TO STAFF'S PRODUCTION REQUESTS-1
UNITED WATER IDAHO INC.
CASE UWI-04-04
FI RST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Company Witness: Fran k G radilone III
Telephone: [phone]
REQUEST NO. 30:
Please provide a copy of all files and worksheets used by witness Gradilone
determine test year revenues and to make all adjustments described in his
testimony. nclude weather normalization analysis. Please provide in an Excel
format.
RESPONSE NO. 30:
Please see the attached electronic Excel spreadsheet containing all data used
the development of test year revenues and weather normalization.
UNITED WATER IDAHO INC.
CASE UWI-04-04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Prepare r: Scott Ahead
Sponsoring Witness: Grank Gradilone III
Telephone: (201 )-767-2845
REQUEST NO. 31 :
Please provide information to support your assumption that 750/0 of new
customers use alternate sources for irrigation.
RESPONSE NO. 31 :
One year of data from the time period of October of 2003 thru October 2004
indicates that 2 525 services were installed of which 1 941 have an alternate
source of water to irrigate their lawns. The number of services with alternate
irrigation divided by the total number of services installed (1 941 / 2,525 =
76.870/0) provides us with the assumption that approximately 750/0 of new
customers have an alternate source of water for irrigation.
UNITED WATER IDAHO INC.
CASE UWI-04-
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Company Witness: Frank Gradilone III
Telephone: [phone]
REQUEST NO. 32:
Please explain why the weather normalization adjustment was positive for
residential and commercial customers but negative for public sector customers.
RESPONSE NO. 32:
The weather normalizing adjustments for all three sectors were negative as
shown in the following attachment. Over the course of the rate year the actual
average temperature was lower than the long run normal temperature by about
degrees. The temperature coefficient was positive (as would be expected in the
regression analysis) and hence in each case the temperature portion of the
adjustment was negative. Likewise in terms of rainfall, the coefficient was
negative (again as expected) and the rainfall portion of the adjustment was also
negative in each case. Overall then, the weather adjustment for the residential
sector amounted to -169,212 KG, for the commercial sector it was -40,574 KG
and for the public sector -821 KG.
UNITED WATER IDAHO INC.
CASE UWI-04-
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Company Witness: Frank Gradilone III
Telephone: [phone]
REQUEST NO. 33:
Please provide the underlying data used to develop Exhibit 6, Schedule 3, pages
1 and 3 (to the extent the data are not included in your response to Request No.
1 ).
RESPONSE NO. 33:
Please refer to the Excel spreadsheet provided in the Company s response to
Request No. 30.
UNITED WATER IDAHO INC.
CASE UWI-04-
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Company Witness: Frank Gradilone III
Telephone: [phone]
REQUEST NO. 34:
Please describe what types of things constitute "unbilled revenues" as discussed
on Exhibit 6, Schedule 2 , page 13.
RESPONSE NO. 34:
Unbilled revenues represent revenues that the Company expects to receive from
customers that have not yet been billed. Since they do not represent actual
consumption , revenues billed or collected in the test year, the unbilled revenue
shown on the income statement is deducted before the analysis begins. In
assessing revenue for the pro forma year it is assumed that all consumption that
was projected to be used would be fully billed and collected in the rate year.
UNITED WATER IDAHO INC.
CASE UWI-04-
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer and Sponsoring Witness: Dennis E. Peseau
T elephone:503-370-9563
Title: President, URI
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 Excel format.
RESPONSE NO. 35:
Requested information has been sent via e-mail on January 7, 2005.
UNITED WATER IDAHO INC.
CASE UWI-04-
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer and Sponsoring Witness: Dennis E. Peseau
Telephone: [phone]
Title: President, URI
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 7, lines 21-23 of your testimony.
RESPONSE NO. 37:
Seasonal rates are believed to provide a better basis upon which to base
consumption decisions than do inverted rates largely because of reliable
information. Under inverted rates, a consumer only knows that he/she faces
higher rates when a specified block level of usage is exceeded. Within the billing
cycle, a consumer cannot be expected to know where his/her consumption to
date has fallen and therefore cannot know at what rate the next unit of water
consumption will be billed. This uncertainty makes it difficult to make reliable
consumption decisions regarding conservation or not.
Under seasonal rates, quantifiable differences in seasonal cost differences can
be estimated. These estimated cost differences can then be reflected in
seasonal rate differences. Once these seasonal rates are established, the
consumer has reasonable information and certainty in the form of seasonal price
signals that are the basis of consumption and conservation decisions.