200502147th Response to Requests.pdf

ORIGINAL
Dean J. Miller
McDEVITT & Mll.LER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
ioe~mcd~ -miller .com
Attorneys for Applicant
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u.Ttl\llES COMM1SS1ON
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-
SEVENTH RESPONSE OF UWID
TO STAFF'S PRODUCTION
REQUESTS
COMES NOW United Water Idaho Inc. ("United"
, "
the Company ) and responds to
Request Numbers 92 (confidential), 95 , 96, 103 , 106 (confidential), 109, 110, 111 (confidential)
and 113 of Staff s Third Production Requests.
Dated this day of February, 2005.
McDEVITT & MILLER LLP
SEVENTH RESPONSE OF UWID TO STAFF'S PRODUCTION REQUESTS-1
CERTIFICATE OF SERVICE
I hereby certify that on th
~~
day of February, 2005 , I caused to be served, via the methodes) indicated
below, true and correct copies of the foregoing document, upon:
Hand Delivered
S. Mail (jJ/'
Fax
Fed. Express
Email
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Brad M. Purdy
Attorney for the Community Action Partnership
Association of Idaho
2019 North 17th Street
Boise, Idaho 83702
Fax: [phone]
bm urd hotmail.com
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Fax
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William M. Eddie
Advocates for the West
O. Box 1612-83701
1320 West Franklin Street
Boise, Idaho 83702
Fax: [phone]
bilkililie~rmci.net
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Bill Sedivy
Idaho Rivers United
O. Box 633
Boise, Idaho 83701
Fax: [phone]
iru~i dlth ori vers. org
Sharon Ullman
9627 West Desert Avenue
Boise, Idaho 83709
Fax: [phone]
~haronu~caQJeone.net
Chuck Mickelson
Boise City Public Works
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]
~son~cityotboise.org
Douglas K. Strickling
Boise City Attorney s Office
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]
~ing~cityotboise.org
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Scott L. Campbell
Moffatt Thomas
101 South Capitol Blvd., 10th Floor
O. Box 829-83701-0829
Boise, Idaho 83702
Fax: [phone]
~c~moffatt.com
~UCTION REQUEST5-2
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~ -
UNITED WATER IDAHO INC.
CASE UWI-O4-
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness: Scott Ahead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO. 95:
Please provide information showing how the $4000 per month cost for a backup
electrical feeder for the CWTP was determined.
RESPONSE NO. 95:
This $4 000 amount was a preliminary estimate from Idaho Power Company,
received on June 7 , 2004. It indicated the combined monthly backup power
supply costs for the water treatment plant and the raw water pump station.
The monthly cost is based upon Idaho Power Company s Schedule 46 for
Alternate Distribution Service. There are three fees included under this
schedule, capacity charge, mileage charge and facilities charge. Schedule 46
indicates:
Capacity Charge:
Mileage Charge:
Facilities Charge:
$1.30 per contracted kW of capacity
$0.005 per kW per tenth of a mile in excess of 1.7 miles
The automatic switching device will be owned , operated , and
maintained by the Company in consideration of the
Customer paying to the Company a Facilities Charge of 1.
percent per month times the Company s investment in suchfacilities.
The contracted capacity for the CWTP is 846 kW and the capacity for the pump
station is 884 kW. Both facilities are approximately 3.5 miles from the substation
resulting in the mileage charge calculated upon 18 tenths of a mile (3.5 - 1.7 =
8). The automatic switchgear for both sites is estimated at about $38,000.
Under the above criteria and site-specific conditions, the monthly charges are
projected as follows:
Columbia Water Treatment Plant
Capacity Charge:
Mileage Charge:
Facilities Charge:
846 x $1.30 = $1 099.
$0.005 x 846 x 18 = $76.
017 x $38,000 = $646.
Total CWTP monthly charge = $1 821.
Raw Water Pump Station
Capacity Charge:
Mileage Charge:
Facilities Charge:
884 x $1.30 = $1 149.
$0.005 x 884 x 18 = $79.
017 x $38 000 = $646.
Total pump station monthly charge = $1 874.
Combined cost for Alternate Distribution Service = $3 696.70 per month
UNITED W ATERIDAHO INC.
CASE UWI-O4-04
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness:Jeremiah Healy
Telephone: [phone]
Title: Coordinator of Planning and Rates
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 workpapers showing how the $1 550,000 deferral amount as
May 31 , 2005 was computed or estimated.
RESPONSE NO. 96:
The Response to Audit Request No. 69 is attached as responsive to this
production request.
...
UNITED WATER IDAHO INC.
CASE NO. UWI-W-O4-04
THIRD PRODUCTION REQUEST
IPUC STAFF
TT A C H MEN T
RESPONSE TO
REQUEST NO. 96
...
UNITED WATER IDAHO INC.
CASE UWI-W..O4..04
FIRST AUDIT REQUEST OF THE COMMISSION STAFF
Preparer: ~eremiahHealy
[phone]
Company Witness: ~eremiah Healy
[phone]
REQUEST NO. 69:
Regarding Healy s Adjustment No. 12 for deferred power expense 5, the
workpapers accompanying testimony show computation of deferred power
expenses and interest through July 2004 totaling $1,363,240. Please provide
workpapers showing how the $1 550,000 deferred amount as of May, 31 2005
was computed or estimated. If any portions of the workpapers are Excel files,
please provide a copy of these electronic files.
RESPONSE NO. 69:
The $186,760 increase from the July 2004 total deferred power balance
363,240 to the May 31,2004 estimated balance of $1 550,000 was estimated
using the process and information described below without any fo r-mal workpape r
documentation. It was anticipated by the Company that this estimate would be
trued-up prior to hearings in this case.
Although January through July 2004 realized a deferred power ba lance increase
of only $77 663, it was known that the largest pumping months, and largest
deferred amounts, were yet to be recorded for 2004. In August 2004 the deferred
balance increased $38,279, in September 2004 it increased $36,483 and in
October 2004 it increased $28,249 to a total of $1 466,251. It was also known
that the actual kWh charge for Schedule 9S (the most significant rate schedule
for deferral purposes) was at a non-summer rate of 3.1823 cents pe r kWh
through May 2005, as opposed to the base rate of 2.6858 cents per kWh. The
resulting 0.4965 cents per kWh difference would significantly slow the deferral
growth, as it was the lowest differential since the Company received
authorization to defer excess power expense (the differential was 1 .8662 cents
per kWh at it's peak in 2002/2003).
UNITED WATER IDAHO INC.
CASE UWI-04-
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness: Scott Ahead
Telephone: [phone]
Title: Managing Enginee r
REQUEST NO.03:
Please explain how the capital costs as well as the ongoing operation and
maintenance costs for the Boise River raw water pumping plant have been or
being split between UWI and Micron.
RESPONSE NO.03:
The raw water pump station, including the river intake structure and the building,
was constructed on a 50/50 basis with United Water paying 500/0 of the
construction costs and Micron Technology Inc., the J. R. Simplot Company and
the Surprise Valley Partnership (hereinafter, Micron) paying the other 500/0. This
is consistent with previously filed testimony by Witness W. C. Linam, Direct
Testimony, UWI-97-6, page 11.
The apportionment of common operations costs for the pump station is also
based upon the 50/50 split. To date, those costs have primarily been limited to
insurance premiums and some landscaping maintenance costs.
Micron installed its own pumping equipment at its own cost at the time of the
original pump station construction and pays its own purchased power bills.
Similarly, United Water has installed its own pumping equipment, at its cost,
under project C04BO02, (see Exhibit 8 of Scott Rhead direct testimony). United
Water also has its own power transformer and meter so that its power use
totally separate from the Micron pumping system.
UNITED WATER IDAHO INC.
CASE UWI-04-04
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness: Scott Ahead
Telephone: [phone]
Title: Managing Engineer
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?
RESPONSE NO.09:
It is important to point out the distinction or difference between the capital
additions water right "work" ($146,483) and the on-going annual operations
expense shown in Healy Adjustment No.9. The purpose of the projected capital
addition of $146 483 for water rights was indicated in Scott Rhead's direct
testimony on page 25, lines 4-7. The actual cost is yet to be determined but at
this time it appears it will not reach the previous estimate. The major efforts and
accomplishments of this capital "work" are listed below:
Municipal transfer application now pending with Idaho Department of
Water Resources also discussed in Response No. 46
. New York Irrigation District entitlement approval and canal diversion
headwork'
Maple Hills #2 groundwater permits conditions
Filing and defense of the Company water rights portfolio submitted
required by the Snake River Basin adjudication (SRBA)
City of Kuna protest due to concerns of interference with Danskin Well.
Idaho Department of Corrections protest due to concerns of interference
with the Ten-Mile Ridge wells
Bureau of Reclamation draft contract review in preparation for renewal of
the 800 acre-foot discussed in Response No. 92 and No.01.
Final negotiations and lease documentation with South Boise Water also
discussed in Response No. 92
These efforts result in actual water that will be diverted at Marden and Columbia
WTP's in addition to defining, defending and preserving the existing water right
portfolio at other locations. The water right costs shown in Healy Exhibit No.9 are
on going annual operating expense tied to rental pool rates and Bureau of
Reclamation contract requirements.
The adequacy of the existing surface water portfolio to supply Marden and
Columbia is difficult to determine precisely. Overall and under most conditions
United Water believes it's portfolio of water rights is adequate to meet demand.
However, many of the rights and contracts have provisions for drought, outcome
uncertainties of SRBA, salmon augmentation requirements, Bureau of
Reclamation contract renewals, rental pool competition, or other contingencies.
This makes it imperative that United Water has sufficient water rights in case
these contingencies arise. All of these factors require that United Water have
water right options and flexibility to meet demand requirements in the event one
segment of the portfolio is not available or curtailed.
UNITED WATER IDAHO INC.
CASE UWI-O4-
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness: Scott Ahead
Telephone: [phone]
Title: Managing Enginee r
REQUEST NO. 110:
Please explain why the bonus for early completion provisions of the COM
contract were amended.
RESPONSE NO. 110:
As previously discussed in my response to Production Request No.1 04 , getting
the design and approvals delayed the start until February 2004. Getting the
project on-line and available to meet summer 2005 demand was critical. June 1
was established as the start of the 3D-day facility test date. This leaves little time
for system performance checks and start-up adjustments that are common with
projects of this magnitude. In an effort to motivate COM for more start up time
United Water chose to increase the incentive from $2 500/Day to $3,500/Day.
UNITED WATER IDAHO INC.
CASE UWI-W-04-04
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness: Scott Rhead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO. 113:
...
Has UWI ever entered into a construction agreement based on a "cost plus feebefore? If so, please identify the projects on which this type of agreement was
used.
RESPONSE NO. 113:
This is the first time United Water Idaho has completed a project using a
procurement format that identifies up-front fee , reimburses for cost, and
combines design-construction under one entity.
0 NFID ENTIAL
ATTACHMENTS