200501193rd Request of Staff to United Water.pdf

WELDON B. STUTZMAN
DONOVAN 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
11 r:nfL.. (.. U l",,_.
FeEGEl\lEO
ZOOS JAM 19
tDj~ilD fjUBLIC
UTILITIES COMMISSION
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.
CASE NO. UWI-04-
THIRD 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 THURSDAY
FEBRUARY 10 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.
THIRD PRODUCTION REQUEST
TO UNITED WATER
JANUARY 19 2005
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 qu~stion, 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. 89: Reference Peseau Exhibit 14, Schedule 4, page 2. Please explain the
derivation or cite the source for the 0.435% allocation of annual consumption to Public Fire
Protection and the 0.065% allocation to Private Fire Protection.
Request No. 90: Reference Peseau Exhibit 14, Schedule 4, page 1. Are the Max Hour
Max Day and Avg Day pumping rates for Aug. '03 - July '04 as shown in the last table on page
of the exhibit monthly actuals, estimates, or computed values? If estimates or computed values
please describe or demonstrate how they were determined.
Request No. 91: Please describe the timing and nature of any planned future additions to
the CWTP.
Request No. 92: Please provide a copy of all leases, purchase agreements or other
contracts for water to supply the CWTP. For each lease, purchase or contract, summarize the
amountUWI has agreed to pay and the term of the agreement. Does UWI intend to renew each
agreement upon expiration? Does UWI intend to continue to lease or purchase water for the
CWTP or will it in the future transfer unused water rights from other locations in its system?
Request No. 93: Please provide a copy of the engineering estimates of operating costs
for the CWTP prepared by CDM.
Request No. 94: To the extent not provided in the above response, please provide
workpapers showing how the estimated power costs for the CWTP and raw water pumping plant
were computed.
Request No. 95: Please provide information showing how the $4000 per month cost for a
backup electrical feeder for the CWTP was determined.
Request No. 96: The workpapers provided for Adjustment No. 12 show computation of
deferred power expenses through July 2004 totaling $1 363 240. Please provide supplemental
THIRD PRODUCTION REQUEST
TO UNITED WATER
JANUARY 19 2005
workpapers showing how the $1 550 000 deferral amount as of May 31 2005 was computed or
estimated.
Request No. 97: Reference Healy, page 16, lines 13-18. Please list those wells that UWI
expects will be treated with phosphate in the winter. Will any of those wells be used less in the
winter once the CWTP is online? What is UWI's record of iron and manganese related
complaints in the winter for the past three years?
Request No. 98: Reference Healy Adjustment No. 14. Please provide a summary of the
water quality tests that UWI is required to perform. For each test, include the frequency and
cost. Describe the type of testing and frequency required under the Long Term 2 Surface Water
Treatment Rule.
Request No. 99: Reference Healy Adjustment Nos. 14 and 16. Will there be any
reduction in testing expenses or chemical expenses as a result of some wells being used less due
to the CWTP?
Request No. 100: Reference Adjustment No. 15. Please explain why T-
communication connections are necessary at the Marden and CWTP plants. What types of data
must be accessed or transmitted? What type of communication connection exists presently at the
Marden plant? Does UWI use T-l connections anywhere else in its system?
Request No. 101: Reference Adjustment No.9 workpapers. For the raw water purchase
labeled "SBMIC/Capitol View Lucky Peak " please explain why UWI used the minimum in
2004 but expects to use the entire volume in 2005. What has been the amount spent on this
purchase or lease for each of the past five years? Please provide a copy of this lease or purchase
agreement.
Request No. 102: Reference Adjustment No. 15. For the PRY communications
upgrades, please explain what these upgrades are, where they have been made, when they were
completed and how they are beneficial.
Request No. 103: Please explain how the capital costs as well as the ongoing operation
and maintenance costs of the Boise River raw water pumping plant have been or are being split
between UWI and Micron.
Request No. 104: Please explain why the scheduled completion date of the CWTP was
delayed from the June 1 2004 date specified in the RFP to July 1 , 2005 as specified in
Amendment No.1 to the CDM contract.
Request No. 105: Please explain why a different construction process was used for the
CWTP than for the Marden plant (Design-build vs. Design-bid-build).Please contrast the
advantages and disadvantages of Design-build vs. design-bid-build.
Request No. 106: The Target Cost of Work documents were not provided to Staff as
part of the four proposals provided in response to Request No. 14, yet the RFP clearly states that
THIRD PRODUCTION REQUEST
TO UNITED WATER
JANUARY 19 2005
the Target Cost of Work is a required element of the proposals. Please provide a copy of the
Target Cost of Work for each of the four proposals received by UWI. In addition, please provide
all additional documentation submitted by the proposers to document the assumptions and
. conditions used for the determination of the Target Cost of Work and the Fixed Fee. Please
explain how the Target Cost of Work was considered in the evaluation of the proposals. Provide
any updates that have been made to CDM's Target Cost of Work and explain the reasons for
each change.
Request No. 107: Please explain how UWI chose the firms invited to bid on the design
and construction of the CWTP.
Request No. 108: Please provide a detailed itemization of costs by category or task of
the $1 357 216 difference between the $16 844,498 GMP and the $18 201 714 projected total
cost of the CWTP (more detail than was provided in response to Request No. 18). Include any
assumptions made or workpapers showing how amounts for things such as inspection labor
proj ect management, overheads and AFUDC were computed.
Request No.1 09: Reference Rhead testimony page, lines 4-7. Please provide more
detail on how the $146,483 amount was determined and describe where these water rights are
being used. How are these water rights different than the water that will be acquired as shown in
Healy s Adjustment No.9? Are the contracts/leases included in Adjustment No.9 insufficient to
supply the needs at the CWTP? Are the existing water rights insufficient for the continued
operation of the Marden plant?
Request No. 110: Please explain why the bonus for early completion provisions of the
CDM contract were amended.
Request No. 111: Please provide a copy of the results ofUWI's evaluation of proposals
for the CWTP based on the established set of price and non-price factors as listed in the RFP.
Include the scores awarded to each proposal for each factor. Describe or document how the
price and non-price scores were used to determine the winning bidder. Also include copies of
any analysis, notes, correspondence, memoranda or other written documentation used in the
proposal evaluation process. Please identify all persons who served as part of the evaluation
team or who made recommendation regarding selection of the winning bidder.
Request No. 112: Has UWI ever used a design-build process before? If so, please
identify the projects on which it was used.
Request No. 113: Has UWI ever entered into a construction agreement based on a "cost
plus fee" before? If so, please identify the projects on which this type of agreement was used.
Request No. 114: Please explain why UWI used a "cost plus fee" type of construction
agreement for the CWTP.
THIRD PRODUCTION REQUEST
TO UNITED WATER
JANUARY 19 2005
Dated at Boise, Idaho, this it.;, day of January 2005.
Weldon B. Stutzman
Donovan E. Walker
Deputy Attorneys General
Technical Staff: Rick Sterling
i :umisc/prodreq/uwi wO4. 4 wsdwrps3
THIRD PRODUCTION REQUEST
TO UNITED WATER
JANUARY 19 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF JANUARY 2005
SERVED THE FOREGOING THIRD 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 ES
McD EVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
Jo f
SECRET
CERTIFICATE OF SERVICE