HomeMy WebLinkAbout200502095th Request of Staff to United Water.pdfWELDON B. STUTZMAN
DONOV AN 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
HECEIVED
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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.
FIFTH 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
WEDNESDAY, MARCH 2, 2005. These requests are follow-up questions to prior Audit
Requests and 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 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.
FIFTH PRODUCTION REQUEST
TO UNITED WATER
FEBRUARY 9, 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 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. 149: In follow-up to Audit Request 43, please provide copies of all
property tax assessments and/or bills received and/or paid during 2003 and 2004. Please include
copies of assessments from all taxing authorities, including the Boise-Kuna Irrigation District
the N amp a Meridian Irrigation District, the New York Irrigation District, the Ada County
Treasurer, the Canyon County Treasurer, and any other taxing authorities.
Request No. 150: In the response to Audit Request No. 43 , the Company states that
UWID received in 2003 a $43 000 credit from Ada County & Canyon County. Please provide
an explanation of the credit and a copy of the document showing how the credit was conveyed to
UWID.
Request No. 151: Following up on the Company s response to Audit Request No. 12
please provide a list of all expenses incurred by the Company in its def~nse of the cases listed in
the Company s response. Please include to whom the expenses were paid, date they were paid
account number that the expenses were charged to, and the case to which the expense was
applicable.
Request No. 152: Please provide all amounts included in the Company s response to
Audit Request No. 21 that the Company is requesting to be recovered in rates through this
current proceeding and the accounts to which those amounts are charged.
Request No. 153: The Company s response to Audit Request No. 62 indicates that the
Commission had previously approved in Case No. UWI-00-1 the amortization ofERP/ESP
costs. Please identify any orders issued by the Commission that specifically authorize this
amortization. The response should include the order number, the page number and the paragraph
number of the order.
Request No. 154: The Company s response to Audit Request No. 62 indicates that the
Commission had previously approved in Case No. UWI- W -00-1 the amortization of employee
relocation expenses. Please identify any orders issued by the Commission that specifically
FIFTH PRODUCTION REQUEST
TO UNITED WATER
FEBRUARY 9, 2005
authorize this amortization. The response should include the order number, the page number and
the paragraph number of the order.
Request No. 155: The Company s response to Audit Request No. 62 indicates that the
Commission had previously approved in Case No. UWI-00-1 the amortization of tank
painting costs. Please identify any orders issued by the Commission that specifically authorize
this amortization. The response should include the order number, the page number and the
paragraph number of the order.
Request No. 156: Please provide all investor expenses as described in Audit Request
No. 38 that were incurred by United Water Resources, Inc.s publicly traded parent company
during the test year that have been allocated to United Water Idaho and are being requested to be
recovered in rates. Include the total dollar amount, allocation percentage, basis for allocation
and Idaho amount.
Request No. 157: Please provide the amount of the Company s response to Audit
Request No. 40 that is being requested to be recovered in rates. The response should indicate the
account number to which the expense was charged and the date the expense was paid.
Request No. 158: Please provide the amount of the Company s response to Audit
Request No. 41 that is being requested to be recovered in rates. The response should indicate the
account number to which the expense was charged and the date the expense was paid.
Request No. 159: Staffs Audit Request No. 61 requested copies of all travel and
expense reports for all managers. The Company responded
, "
See the response to Audit Request
No.86." The Company s response to Audit Request No. 86 does not provide copies of all travel
and expense reports for all managers. Please provide copies of all travel and expense reports for
all managers from August 1 2003 through July 31 2004 for any amounts that the Company
seeks to recover in rates.
Request No. 160: Please provide the Company s response to Audit Request No. 64 in
Excel format.
Request No. 161: Please provide copies of all written correspondence between the
Company s actuaries and United Water and any of its affiliates from January 1 , 2002 to current
date.
FIFTH PRODUCTION REQUEST
TO UNITED WATER
FEBRUARY 9, 2005
Dated at Boise, Idaho, this '1~ day of February 2005.
:;? -
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Weldon B. Stutzman
Donovan E. Walker
Deputy Attorneys General
Technical Staff: Kathy Stockton
Donn English
i :umisc/prodreq/uwi wO4.4 wsdw5
FIFTH PRODUCTION REQUEST
TO UNITED WATER
FEBRUARY 9, 2005
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF FEBRUARY 2005
SERVED THE FOREGOING FIFTH 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
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ill 83701
DOUGLAS K STRICKLING
BOISE CITY ATTORNEY'S OFFICE
150 N CAPITOL BLVD.
PO BOX 500
BOISE ID 83701
CHUCK MICKELSON
CITY OF BOISE
150 N CAPITOL BLVD.
PO BOX 500
BOISE ID 83701
WILLIAM M. EDDIE
ADVOCATES FOR THE WEST
PO BOX 1612
BOISE ID 83701
BILL SEDIVY
ID AH 0 RIVERS UNITED
PO BOX 633
BOISE ID 83701
BRAD M. PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
SHARON ULLMAN
9627 W. DESERT AVE
BOISE ID 83709
SCOTT L. CAMPBELL
101 S CAPITOL BLVD., 10TH FLOOR
PO BOX 829
BOISE ID 83701
CERTIFICATE OF SERVICE