The URL can be used to link to this page

Home My WebLink About200502186th Production Request.pdfWELDON B. STUTZMAN DONOVAN 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 ECE ,\lED FILED 1..::.... ..... 1005 FEE II Pi~' 4: I jJ LJ l~ U d Lie UTiliTIES GOt-1f-ltSSlON 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- SIXTH 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 FRIDAY, MARCH 11,2005. 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 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. IDAP A 31.01.01.228. SIXTH PRODUCTION REQUEST TO UNITED WATER FEBRUARY 18 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. 162: Regarding Witness Healy s workpapers for the Company Adjustment No. 17, Transportation Expense, the Lease Disposal value of$31,442 listed on page 1 of 3 has a description of "See Attached Spreadsheet". This spreadsheet does not appear to be a part of Mr. Healy s workpapers. Please provide the spreadsheet illustrating how the $31,442 in lease disposal was calculated. Request No. 163: Please provide the total number of United Water Idaho customers as of December 31 for the years 2000, 2001 , 2002, 2003 and 2004. Request No. 164: Please provide the hourly wage as of December 31 2004 for the employee who was promoted to Chief Operator, as described in the Company s response to Audit Request No. 73. Please also include the position from which this person was promoted the starting wage for this position, and if this position was also filled internally. Request No. 165: Please provide any contracts with, or proposals from, any insurance providers that substantiate the requested increases in HMO Blue Insurance Plan, United Health Care Choice Plus Plans, and the Dental and Vision Coverage. These contracts and proposals should tie to the monthly pro forma calculations provided in Mr. Healy s workpapers for Company Adjustment No.3. If the amounts are different than what is provided in Mr. Healy workpapers, please give a detailed explanation of the difference and provide a reconciliation between the amounts. Request No. 166: Please illustrate how the expenses for Group Term Life Insurance coverage and Long-Term Disability coverage are allocated from the corporate level to United Water Idaho. Please include within your response each expense at the corporate level, the allocator used to derive the UWID expense, and the components of each allocator. Request No. 167: Please illustrate how pension expense is allocated from the corporate level to United Water Idaho. Please include within your response the pension expense at the SIXTH PRODUCTION REQUEST TO UNITED WATER FEBRUARY 18 2005 corporate level, the allocator used to derive the UWID expense, and the components of the allocator. Request No. 168: Please provide a list of all tank paintings done in the last 20 years. The list should include the date the tank was painted and the location of the tank. Request No. 169: Please list the annual outside laboratory water testing expense for each year of the years 1994 through 2004. Please respond in a format similar to page 1 of Mr. Healy s workpapers for Company Adjustment No. 14. Request No. 170: Please provide a copy of the invoice from "Utility Billing Services for the month of December 2004. Request No. 171: Please illustrate how the 72.73% test year level of lock box transactions was calculated in Company Adjustment No. 20. Please include within your response each component of the calculation in an Excel file with all formulas intact. Request No. 172: Please provide the price per unit of lock box transactions as of December 31 , 2004. Request No. 173: Please illustrate how casualty insurance, property insurance and worker s compensation insurance are allocated from the corporate level directly to United Water Idaho. Please include within your response the components of each allocator and show the calculation. Request No. 174: Please provide a narrative to describe why there were three large credits to account 924000 (Property Insurance) during the test year as shown on Mr. Healy workpapers for Adjustment No. 26, page 5 of 5. Please provide the source documents to verify the amounts. Request No. 175: Please provide a detailed narrative justifying the near 50% increase requested for corporate and local IT support. Please include in your response all components of this increase and include all contracts or agreements. Request No. 176: Please provide a comparison of actual expenses to budgeted amounts for the months of August through December 2004 for Accounts 921400 (IT Supplies and Expenses) and 923140 (Outside Services-IT). If these accounts no longer exist due to accounting software changes, please show comparative accounts. Request No. 177: Please provide a list showing all consultants who performed services for United Water Idaho for the years 2001 - 2004. Show services performed, amounts paid, and accounts charged. Request No. 178: Provide an itemized listing, in electronic format, that shows item purchased, date, vendor and amounts for the fiscal year ended July 31 2004 and, separately, for the current fiscal year through the most recent date available for each of the following accounts: SIXTH PRODUCTION REQUEST TO UNITED WATER FEBRUARY 18, 2005 a. Expenses Charged to Account 921 - Office Supplies & Expensesb. Expenses charged to account 923 - Outside Servicesc. Expenses charged to Account 930 - Miscellaneous General Expensesd. Account 935 - Maintenance of General Plant Also show the amounts for each account the Company requests to recover in the proposed test year. Request No. 179: Please provide a list of all professional and social memberships and organizational dues United Water Idaho paid during the test year. This list should include, but is not limited to, the following: Chambers of Commerce, country clubs, lobbying organizations, professional organizations for employees, Idaho Association of Commerce & Industry, and the National Association of Water Companies. For each organization, show the date and amount paid, account used and the service or benefit United Water Idaho received. If any of these charges occur at the corporate level, please illustrate the calculation of amounts charged to United Water Idaho. Request No. 180: Please provide a costlbenefit analysis of the expenses associated with the Early Retirement Program and Enhanced Severance Program that the Company deferred and is now seeking to amortize in current rates. Request No. 181: Please provide all documents supporting the budgeted wage increases that the Company is requesting to recover in this case for non-union and exempt employees. Also provide all documents supporting the budgeted number of employees, including additional employees and associated salaries. Request No. 182: Please provide all documents supporting the budgeted levels of overtime, premium pay and other labor. What assumptions were used to derive these levels? Request No. 183: Please provide all documents supporting the rates used to escalate each labor group. What assumptions were used to derive the rates? Did the rates take into account employee turnover, retirements, etc.? If included, how were they incorporated? Request No. 184: Please provide the monthly line-by-line comparison of budgeted labor costs vs. actual labor costs for the period August 2004 to present. Request No. 185: Please provide copies of any employee newsletters issued during the period June 2003 to date. Request No. 186: Please provide a copy of all job postings and employment advertising from August 2004 to date. Request No. 187: Please provide a schedule of wage expense for 1999 through 2004. Show the proposed test year amounts. At a minimum, the schedules should provide details of SIXTH PRODUCTION REQUEST TO UNITED WATER FEBRUARY 18 2005 wage amounts, incentive payments, pension benefits, health insurance benefits, other benefits paYroll taxes, social security taxes and unemployment taxes by class of employees. Request No. 188: Please provide the average salary for employees during 1995-2003. Please provide the average amount of incentive pay for the same period. Request No. 189: Please provide a schedule showing each job title or classification, a brief description of the duties performed by each job classification and the salary ranges paid for each job classification. Request No. 190: Please provide a copy of the most recent employee handbook. Request No. 191: Please provide a written narrative that explains how the Company sets employee salaries, incentive payments and other employee benefits. Provide a copy of the salary surveys used to set employee salaries. Request No. 192: In response to Audit Request No.7 A the Company provided an organizational chart showing the parent company, all subsidiaries and affiliates, and the percentage of ownership of each. As a follow up to this response, please provide for 2003 and 2004: The Earnings Per Share (EPS) for Suez and identify the EPS Suez derives from each company listed on the organization chart. For United Water Idaho, please further characterize the EPS derived from regulated operations and that derived from non-regulated operations. Include within your response all sources and calculations associated with this information in both paper and electronic format (Excel, where applicable) with all formulas intact. Request No. 193: Please provide the accounting entries recording the following water right projects. Please include within your response the entries originally recording these water rights to Plant in Service and any entries that reclassified any items. Please state the amortization period for each water right, if any, and provide all amortization schedules for each water right. YEAR 2000 2000 2001 2003 2003 2003 2004 Total DESCRIPTION COOAO06 C99AO07 CO 1 AO05 C02A 102 C03AO01 C02AO03 C04A 102 Surface Water Rights Wilson Property Water Rights Water Rights Initial Butte Water Right Water Rig hts Water Rights Water Ri hts AMOUNT 119,486 $ 349 094 $ 135 295 $ 1 711 572 $ 430,824 $ 246 227 146,483 $ 3 138 982 SIXTH PRODUCTION REQUEST TO UNITED WATER FEBRUARY 18 2005 Request No. 194: Please provide the following for each project listed in Witness Rhead's Exhibit No. The costs of each project as of July 31 , 2004, as of December 31, 2004 and as of January 31 2005. A detailed description of the need for each project. An accounting, construction or other report by proj ect that includes all transactions posted to the proj ect, vendor paid, dollar amount posted, date posted, transaction description, account posted and document number for each period listed in above. Please provide the following information not previously provided in Production 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. 195: Please provide a detailed schedule listing the $245 000 in rate case cost components the Company has requested to be recovered through a three-year amortization in this current proceeding. Please provide all contracts and/or service agreements and copies of all invoices, other than legal. The response should total the $245 000 or provide a reconciliation of any differences. Copies of legal invoices have already been provided with the Company response to Production Request No. 134. Dated at Boise, Idaho, this day of February 2005. (;, Weldon B. St zman Donovan E. Walker Deputy Attorneys General Technical Staff: Patricia Harms Donn English i :umisc/prodreq/uwiwO4.4 wsdw6 SIXTH PRODUCTION REQUEST TO UNITED WATER FEBRUARY 18, 2005 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF FEBRUARY 2005 SERVED THE FOREGOING SIXTH 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 ill 83701 DOUGLAS K STRICKLING BOISE CITY ATTORNEY'S OFFICE 150 N CAPITOL BLVD. PO BOX 500 BOISE ill 83701 CHUCK MICKELSON CITY OF BOISE 150 N CAPITOL BLVD. PO BOX 500 BOISE ill 83701 WILLIAM M. EDDIE ADVOCATES FOR THE WEST PO BOX 1612 BOISE ID 83701 BILL SEDIVY ill AH 0 RIVERS UNITED PO BOX 633 BOISE ill 83701 BRAD M. PURDY ATTORNEY AT LAW 2019 N 17TH STREET BOISE ill 83702 SHARON ULLMAN 9627 W. DESERT AVE BOISE ill 83709 SCOTT L. CAMPBELL 101 S CAPITOL BLVD., 10TH FLOOR PO BOX 829 BOISE ill 83701 f/PSECRETAR CERTIFICATE OF SERVICE