200502239th UWI Response.pdf

ORIGiNAL
Dean 1. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
ioe~mcqevitt - miller .com
HECEIVEB ILED
LnnS fEB22 PM 3=35
JO lfO PUBliC
UTILITIES COMMISSION
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-
NINTH RESPONSE OF UWlD
TO STAFF'S PRODUCTION
REQ VESTS
COMES NOW United Water Idaho Inc. ("United"
, "
the Company ) and responds to
Request Numbers 97, 99, 104, 105 , 108 and 112 of Staffs Third Production Requests; Request
Numbers 141 and 142 of Staffs Fourth Production Requests; and Request Numbers 152, 157
158, 159 and 160 of Staffs Fifth Production Request..
Dated this ~-L day of February, 2005.
McDEVITT & MILLER LLP
Dean J. iller
Attorneys for United Water Idaho Inc.
NINTH RESPONSE OF UWID TO STAFF'S PRODUCTION REQUESTS-1
CERTIFICATE OF SERVICE
I hereby certify that on thP~y of February, 2005, I caused to be served, via the method(s) indicated below, trueand correct copies of the foregoing document, upon:
Brad M. Purdy
Attorney for the Community Action Partnership
Association of Idaho
2019 North 17th Street
Boise, Idaho 83702
Fax: [phone]
bm urd hotmai1.com
William M. Eddie
Advocates for the West
O. Box 1612-83701
1320 West Franklin Street
Boise, Idaho 83702
Fax: [phone]
billed~ieiIDrmci.net
Bill Sedivy
Idaho Rivers United
O. Box 633
Boise, Idaho 83701
Fax: [phone]
iruiIDidjlhori vers. org
Sharon Ullman
9627 West Desert Avenue
Boise, Idaho 83709
Fax: [phone]
~haron uiIDcab leone.net
Chuck Mickelson
Boise City Public Works
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]~soniIDcityo tboise. org
Douglas K. Strickling
Boise City Attorney s Office
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]~ingiIDc it yo fboise. org
Scott L. Campbell
Moffatt Thomas
101 South Capitol Blvd., 10th Floor
O. Box 829-83701-0829
Boise, Idaho 83702
Fax: [phone]
~ciIDmoffatt.com
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R!~J~r
D TO S~FF~ PRODUCTION REQUESTS-2
REGEIVEB
UNITED WATER IDAHd:-IYt~~
CASE UWI
~f1MTHIRD PRODUCTION REQUEST OF " I " 16rf~TAFF
10/;:10 PUBLIC
UTiliTiES COMMJSStL)tl
Preparer/Recordholder/Sponsoring Witness: Scott Rhead
Telephone: [phone]
Title: Managing Engineer
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?
RESPONSE NO. 97:
The wells that will be treated with phosphate in the winter are: Bethel; Hillcrest;
Hilton; Taggart and Vista. The area served by these wells in the winter is
generally the Central and Eastern First bench service area. (An area roughly
bounded by Federal Way on the East, 1-184 on the West, the Second bench
terrace on the South , and the First bench terrace, or Crescent Rim Drive, on the
North) .
None of these wells will be used any less in the winter as a result of the CWTP
being on-line. Water produced by CWTP will primarily serve the Columbia,
Barber, and Gowen service areas, with some lesser flows to the Main and First
Bench service areas. The wells listed above provide pressure and supply to the
Eastern and Central First Bench service areas during the winter.
United Water does not track discolored water complaints by chemical
composition, i.e. iron and manganese. Discolored water complaints can be
caused by a wide variety of circumstances including: main breaks, fire hydrant
use (fire flows or filling construction/street sweeper trucks), flow and pressure
changes in the distribution system , customer internal plumbing problems,
sprinkler system blow-outs, standby wells turning on to meet emergency
pressure demands, and iron and manganese sequestering effectiveness. The
record of United Water s discolored water complaints in the winter for the past
three years is summarized on the attached form. Please recognize that these
complaints are not tracked by reason and only those complaints that result ina
field visit or a call back to resolve are logged.
UNITED WATER IDAHO INC.
CASE UWI-O4-
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/RecordholderlSponsoring Witness: Scott Rhead
Telephone: [phone]
Title: Managing Engineer
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?
RESPONSE NO. 99:
The reduction in chemical expenses has been estimated and provided in Mr.
Healy s direct testimony on page 17 , Adjustment No.16 where he indicates power
and chemical cost at nine designated wells will decrease on an annual basis
$139,580 as a result of CWTP operation. There will be no reduction in water
quality testing expense. All system wells will operate for more than sixty days,
thus they are not exempt from full historical monitoring in accordance with the
Idaho Department of Water Quality rules and regulations.
UNITED WATER IDAHO INC.
CASE UWI-04-
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/RecordholderlSponsoring Witness: Scott Rhead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO.04:
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.
RESPONSE NO.04:
As discussed in my direct testimony, pages 18 and 19, getting the design
complete and obtaining approvals was more difficult than expected. The original
RFP schedule did not anticipate this situation. The reasons associated with the
delay are listed as follows:
March 2003: The initial preliminary Gross Maximum Price (GMP) and
associated CWTP project scope was received from CDM and it
significantly exceeded the Company s project budget and expectations
that were based on the original Basis of Design report and budget.
March to June 2003: As a result the CWTP project design was
temporarily placed on hold and CDM was instructed to reassess the
project scope, design and cost estimates. During this period the Company
performed additional raw water quality research. This research showed
that the membrane material type originally picked would not adequately
meet water quality performance requirements. The Company was
particularly concerned about the occasional spiking of iron and aluminum
concentrations contained in the raw water during the springtime runoff and
in storage releases by the Bureau of Reclamation. The original membrane
filter manufacturer s filter cleaning process did not remove the metals once
they penetrated the filter fibers. Eventually, the original membrane filter
order was cancelled and the Company sought bids from an alternate
supplier who had a filter system in actual use at other locations that had
demonstrated effectiveness at removing these metals. Due to the change
in the membrane filter supplier, the Idaho Department of Environmental
Quality requested time to evaluate and consider the newly selected
membrane filters, since they had never been pilot tested on source water
from the Boise River.
July to September 2003: The Company and COM reassessed the overall
project scope and budget and the Company requested COM to modify the
CWTP design and resubmit a new GMP in alignment with the revised
Company expectation.
October 2003 to January 2004: The design of CWTP was further
developed and competitive sub-contractor packages were assembled.
Also, initial building permits were obtained.
January to February 2004: The final GMP workshop and scope
negotiations were concluded with an acceptance price that complied with
the approved Company budget.
June 1,2004 was then impossible to meet. An aggressive schedule of 16-1/2
months was agreed upon and completion was reset at July 1, 2005 in order to be
available for peak season demand.
UNITED WATER IDAHO INC.
CASE UWI-04-04
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness: Scott Rhead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO.05:
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.
RESPONSE NO.05:
Please refer to direct testimony of Scott Rhead on page 16, beginning at line 14
for the question and associated response. The primary driver of this decision
was contractor experience in this type of construction. The project benefits are
explained on page 17 , lines 1-8. This is also further explained as provided in
direct testimony of A.T. Wallace on page 5, lines 18-23 and on page 6 , lines 1-
14.
Additional information on this construction method can be found in Document
Number FOO103 , published by the Design-Build Education and Research
Foundation s Research Report. The report cites a 1997 US Department of
Commerce report stating that the design-build system of project delivery is used
in at least 250/0 of the non-residential construction market and its use is rapidly
increasing. Many, if not all , of the benefits cited by Company Witnesses Rhead
and Wallace are supported in this document as well as statistical information
summarizing comparative results of studies of hundreds of projects using the
different methods. One of the studies performed in the US (included 351
projects) shows that the unit cost of a project was 60/0 less than using the design-
bid-build, the construction speed was 120/0 faster and the delivery speed was
330/0 faster.
The design-build benefits and risks can be summarized as follows:
Benefits:
Sole source of responsibility
Reduction of project duration
Errors and omissions claims reduction
Alignment of design and construction professionals
Early cost certainty
Risks:
Requires non-traditional procurement techniques
Requires more complete and rapid upfront decision making
UNITED WATER IDAHO INC.
CASE UWI-04-
THIRD PRODUCTION REQUEST OF THE COMMISSION Sf AFF
Preparer/Recordholder/Sponsoring Witness: Scott Rhead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO.08:
Please provide a detailed itemization of costs by category or task of the
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, project management, overheads
and AFUDC were computed.
RESPONSE NO.08:
The CWTP GMP includes costs for the construction of three major elements of
the overall project, the water treatment plant, the 1.2 million gallon clearwell and
the raw water pumpstation. United segregated these projects into three separate
capital expenditure authorizations for administrative purposes, treatment plant
C02BO02 , clearwell C03EO01 and the pumpstation C04BOO2. As a result
the $16,844 498 GMP amount is for the combined costs for these three projects.
The $18 201 714 is the total cost projection for the treatment plant only.
The attached spreadsheet shows how the GMP was apportioned to the three
projects plus projections for other costs, such as, other contractor/equipment
materials and supplies, United Water payroll , payroll and construction overheads,
AFUDC and contingency allowances. There are no contingency allowances for
the clearwell project as it was completed in 2004 and actual costs are known.
The costs shown, other than the COM GMP, reflect actual costs through
December 31, 2004 plus the projected costs to complete the project.
The computation of inspection labor, project management, overheads and
AFUDC, plus contingencies are as follows:
United Water Payroll: This reflects an overall estimate for the combined work of a
number of United Water employees on this project. There is no specific
breakdown by employee or department in the development of this estimate. The
tasks include inspection labor and project management along with a significant
effort for training. The discussion below summarizes the work and highlights the
personnel involved:
Inspection Labor: Labor is primarily by United Water pipeline inspectors
for the installation of yard piping. Also, labor by United Water IT personnel
is needed for the selection and installation of control and communication
equipment. The inspection for the three major projects is included in the
COM contract.
Project Management: Labor by engineering manager and engineering
staff for matters such as, contract issues, invoicing, design and
coordination with other contractors and utilities.
Training Labor: This involves the United Water Production Department
from the department manager to the operators. This is a new process for
United Water that requires additional orientation. Also, coordination and
training for SCADA control system technicians is critical.
Overheads: The overheads amount reflects the combination of payroll and
construction overheads. Payroll overheads averaged approximately 800/0 over
the period of construction and construction overheads averaged about 70/0, which
are applied against all costs, other than AFUDC, in the month the costs are
booked.
AFUDC: AFUDC is compounded on a monthly basis against all construction
costs to date plus the cumulative AFUDC to date. The AFUDC rate is 11.620/0
per year, or a monthly rate of 0.9680/0.
Contingencies: This is the allowance for omissions and contingency cost in the
planning of a project. The more defined the project is the lower the contingency
and vice versa. As a project proceeds, the contingency allowance is generally
consumed as needed to a greater or lesser degree. In the case of the CWTP
clearwell and pumpstation , the original contingency allowance was less than 50/0.
Much of that has been applied as the project progressed , reducing the remaining
amount to the levels shown on the attachment.
UNITED WATER IDAHO INC.
CASE UWI-O4-
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness: Scott Rhead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO. 112:
Has UWI ever used a design-build process before? If so, please identify the
projects on which it was used.
RESPONSE NO. 112:
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. However, this is not the first time United
Water has employed this method of construction and United Water Idaho has
benefited from the expertise of its Technical Services group in the Company
Management and Services Company in this area. United Water has used this
construction process in its New York utility Company, is currently contracting in
this manner for two of its treatment plants in its Pennsylvania utility which are
expected to start construction within a couple of months and has used this
method in its non regulated contract operations with municipalities in Wisconsin
Indiana and Texas.
UNITED W ATERIDAHO INC.
CASE UWI-04-04
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness:Jeremiah Healy
Telephone: [phone]
Title: Coordinator of Planning and Rates
REQUEST NO. 141:
Please provide the number of employees employed by United Water Idaho, Inc.
on December 31 , 1999-2004. Please identify the total number, the number of full-
time employees and the number of part-time employees at each date.
RESPONSE NO. 141:
United Water employed the following number of part-time employees, full-time
employees, and vacancies had on December 31 of the respective years:
Year-End Part-Time Full-Time Vacancies Total
Employees Employees Positions
2004
2003
2002
2001
2000 100
1999 100 100
UNITED WATER IDAHO INC.
CASE UWI-O4-
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/RecordholderlSponsoring Witness:Jeremiah Healy
Telephone: [phone]
Title: Coordinator of Planning and Rates
REQUEST NO. 142:
Related to the attachment to Audit Request No., page 2, please provide the
individual detail for each retirement on line 18.
RESPONSE NO. 142:
The line 18 amounts represent debt that was retired because of its relatively high
cost and because the Company had available cash to retire the debt at that time.
The issues are as follows: Prudential 10.050/0 issue retired in January 2002 with a
premium of $4 044 582 associated with the retirement, Prudential 9.570/0 issue
retired in 2002 with a premium of $3,339,559, and the Jacksonville issue retired
in February 2002 with a premium of $240 000. The total of these three premiums
was $7 624,141 which is being amortized over a period of approximately 22
years at a rate of $28,416 per month, or $340,992 annually. This debt was not
refinanced or replaced.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness:Jeremiah Healy
Telephone: [phone]
Title: Coordinator of Planning and Rates
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.
RESPONSE NO. 152:
The response to Audit Request No. 21 identifies several "pay at risk" programs
the Company currently has or previously had in place to provide incentive to
employees. On Mr. Healy s Exhibit No.3, Schedule 1 , Page 1 of 34 the following
lines capture the employee incentive programs the Company is requesting to be
included in rates in the current proceeding:
Line 10. Management Incentive Pay
Line 11. Non-Union Incentive Pay
Line 12. Union Incentive Pay
$74,775
$44 287
$14 400
$133,462Total Incentive Pay
Line 16. Test Year Derived O&M 74.64460/0
Total Incentive Pay Requested In Rates $ 99,622
The incentive programs indicated above potentially impact every employee in the
Company. On the Company s book's, when incentive pay is recorded, a portion
of that pay is charged to capital when appropriate, commensurate with an
employees job function. The balance is charged to operations and maintenance
accounts. Pro-forma payroll expense as presented in the case is not allocated to
individual expense accounts therefore it is not possible to identify incentive pay
beyond the category of payroll expense.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/RecordholderlSponsoring Witness:Jeremiah Healy
Telephone: [phone]
Title: Coordinator of Planning and Rates
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.
RESPONSE NO. 157:
Please see the attached schedule. For the test period August 2003 to July 2004
the schedule indicates that the Company expended $3,800 on scholarships &
sponsorships. This amount is requested to be recovered in rates. The schedule
further indicates that charitable contributions for the test period total $5 510. This
amount is specifically removed from rate consideration on Mr. Healy s Exhibit No.
3, Schedule 1 , Page 27 of 34, line number 3.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/RecordholderlSponsoring Witness:Jeremiah Healy
Telephone: [phone]
Title: Coordinator of Planning and Rates
REQUEST NO. 158:
Please provide the amount of the Company s response to Audit Request No. 41
that is being requesting 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.
RESPONSE NO. 158:
Please see the attached schedule. Audit Request No. 41 requested amounts
spent on Christmas parties, 4th of July parties, Company sponsored events such
as golf tournaments and all other similar events by calendar year. As indicated
on the attached schedule, $11 833 was spent on these events during the test
period. This also represents the amount being requested in rates in the current
case.
UNITED WATER IDAHO INC.
CAS.E UWI-O4-
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness:Jeremiah Healy
Telephone: [phone]
Title: Coordinator of Planning and Rates
REQUEST NO. 159:
Staff's 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.
RESPONSE NO. 159:
Please see the attached copies of travel and expense reports and associated
receipts for all managers for the period August 1 2003 through July 31, 2004.
UNITED WATER IDAHO INC.
CASE UWI-W-04-04
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness:Jeremiah Healy
Telephone: [phone]
Title: Coordinator of Planning and Rates
REQUEST NO. 160:
Please provide the Company s response to Audit Request No. 64 in Excel
format.
RESPONSE NO. 160:
On Wednesday February 16, 2005 Mr~ Healy e-mailed the response provided to
Audit Request No. 64, in Excel format, to all parties.
Healy, Jerry
Cc:
Subject:
Healy, Jerry
Wednesday, February 16, 2005 10:20 AM
Purdy, BradM.
; '
Eddie, William M:; 'Sedivy, Bill'
; '
Ullman, Sharon
; '
Mickelson, Chuck'
Strickling, Douglas K'
; '
Campbell, Scott L'
; '
Carlock, Terri'
Miller, Joe
United Water Idaho Rate Case Uwi-04-04:Response to IPUG Staff Production Request No.
160
From:
Sent:
To:
AR12-17-04 No
64.xls
To all parties: rather than waste CD's complying with Staff Production Request No. 160, please find the
responsive Excel file attached. Should you have any difficulty accessing the file, please let me know and I will make an
alternate arrangement.
UNITED WATER IDAHO INC.
CASE NO. UWI-O4-
THIRD PRODUCTION REQUEST
IPUC STAFF
ATTACHMENT TO
RESPONSE TO
REQUEST NO. 97
Discolored Water Complaints - Winter Months
2002 2003 2004
January
February
March
UNITED WATER IDAHO INC.
CASE NO. UWI-W-04-04
THIRD PRODUCTION REQUEST
IPUC STAFF
ATTACHMENT TO
RESPONSE TO
REQUEST NO.
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UNITED WATER IDAHO INC.
CASE NO. UWI-O4-
FIFTH PRODUCTION REQUEST
IPUC STAFF
TT A C H MEN T
RESPONSE TO
REQUEST NO. 157
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1
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N
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-
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1
20
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4

20
0
4

2
20
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4

3
20
0
4

4
06
0
06
0
06
0
06
0
06
0
06
0
06
0
06
0
06
0
06
0
06
0
UNITED WATER IDAHO INC.
CASE NO. UWI-W-O4-
FIFTH PRODUCTION REQUEST
IPUC STAFF
ATTACHMENT TO
RESPONSE TO
REQUEST NO. 159
FOR THE REMAINDER
THE RESPONSES WHICH
CONSIST LARGELY OF
PHOTOCOPIES OF
RECEIPTS , PLEASE
REFER TO THE FILE