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Home My WebLink About200503011st Production Request from City of Boise.pdfHE CEI VED ft". .......'" 12J b"~- ZUu5MAR - Fi1 2: 32 UTILITIES GOr1MISSJOt. :- : -- c-: t- ::, :--,- j f.it) nu !' UOLiG CARY B. COLAIANNI BOISE CITY ATTORNEY Douglas K. Strickling Assistant City Attorney BOISE CITY ATTORNEY'S OFFICE 150 N. Capitol Blvd. O. Box 500 Boise, ID 83701-0500 Telephone: (208)384-3870 Facsimile: (208)384-4454 Email: dstrickling~cityofboise.org Idaho State Bar No. 3230 Attorney for Boise City 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- W -04- CITY OF BOISE CITY'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO INC. The City of Boise City, by and through its attorney of record, Douglas K. Strickling, Assistant City Attorney, requests that United Water of Idaho, Inc. ("United Water ) provide the following documents and information. This Production Request is to be considered 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 work papers that provide detail or are the source of the information used in calculations, and the name and telephone number of the CITY OF BOISE CITY'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO INC. - Page 1 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. City of Boise Request No.1: Please explain why the Columbia Water Treatment Plant (CWTP) projected construction cost per gallon capacity remains at the high end of representative similar installations (Scott Rhead Direct Testimony-Exhibit 11) even after the postponement or deletion of multiple planned process elements. Please explain which treatment plant components were included in arriving at the $12.87 million 2005 capital cost used in the cost comparison. City of Boise Request No.2: The Response to Commission Staff No. 12 indicates that the installation of dissolved air flotation (DAF) pretreatment and ultraviolet (UV) disinfection may be required in the future. Please provide the ~ost current estimates for the installation of (DAF) pretreatment and (UV) disinfection if required. City of Boise Request No.3: Did design-build contract proposals for the construction of the CWTF include DAF pretreatment and UV disinfection in the target project budget numbers? If so, how did these DAF pretreatment and UV disinfection budget numbers influence the final selection of CDM? City of Boise Request No.4: It appears the estimated capital costs in the Basis of Design Report Table 3.3 (provided in Response to Commission Staff Production Request No. 9), were based upon 1991 cost levels (ENR Cost Index=4800). Please explain the basis for CITY OF BOISE CITY'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO INC. - Page 2 utilizing 1991 cost levels. Please explain the extent to which cost figures included in Table 3. impacted the decision to proceed with the CWTP project. To what extent, if any, were the estimates updated in developing final project budgets? Please compare the four design build cost proposal estimates to the Basis of Design Report estimates. City of Boise Request No.5: Related to Staff Production Request No. 133, please provide a listing of all subcontracts, materials, and equipment Items listed on the Property Invoice over $25 000 for the CWTP that were competitively bid and the criteria used for selection of the items. City of Boise Request No.6: When it becomes necessary to replace ultra-filtration membrane filters at the CWTP in 5 to 7 years, will multiple manufacturers be allowed to competitively bid on replacements or will this require purchase from the original manufacturer? City of Boise Request No.7: When it is necessary to expand the CWTP, will it be possible for multiple manufacturers to competitively bid on the ultra-filtration membrane filters or will this require purchase from the original manufacturer? City of Boise Request No.8: Please explain the criteria United Water intends to use in determining whether water will be supplied from the CWTP or from existing wells during periods of average or low water demand. Explain how rate payers will benefit from this proposed approach. CITY OF BOISE CITY'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO INC. - Page 3 City of Boise Request No.9: Please provide detail regarding location, length, pipe size whether bid or not, and cost breakdown, for the 16 miles of water mainline replaced at a cost of about $11 million, referred to in G. Wyatt's direct testimony p. 5, lines 8&9. City of Boise Request No.1 0: Please clarify how much of the 16 mile pipeline replacement has been accomplished on an emergency basis. Explain how this work was contracted. Please provide a sample contract form used for emergency construction. City of Boise Request No. 11: Please provide a summary of traditionally bid (non- emergency) portion of the 16 mile pipeline replacements including costs per foot for various pipe sizes, trench work, and surface restoration. Explain how this cost compares to the cost for emergency work. Please provide a sample contract form for non-emergency bid projects. City of Boise Request No. 12: Please explain the criteria used to decide if a pipeline should be repaired or replaced. Please provide a copy of the guidelines (adopted mainline repair and replacement plan) used by United Water to plan and administer mainline repairs and replacements. If annual budgets for mainline repair and replacement for Fiscal years 2000-2004 were established, please provide those. City of Boise Request No. 13: Please explain how United Water purchases pipeline materials. To what extent are these materials competitively bid? City of Boise Request No. 14: If materials are purchased through national contracts what percentage of the pipeline material is purchased from the national contracts and what percent is purchased locally? How do prices compare and to what extent do rate payers benefit from the various purchasing options? CITY OF BOISE CITY'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO INC. - Page 4 City of Boise Request No. 15: Please explain if there is a corporate markup or handling , charge on nationally purchased materials used by United Water. If so, what is the percentage of this markup and what is the basis for this markup? City of Boise Request No. 16: HoW does United Water select the contractor(s) for mainline extensions? Are competitive bids received? Does United Water contract with multiple contractors? If so, how many and what are their corporate names? Please summarize by name and dollar volume of work each contractor has completed for the period 2000 through 2004. DATED this d8'-~day of February, 2005. BOISE CITY ATTORNEY'S OFFICE Douglas I)l~ /Strickling Attorney lf6r Intervenor CITY OF BOISE CITY'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO INC. - Page 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have on this d~~day of February, 2005, served a copy of the CITY OF BOISE CITY'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO INC., Case No. UWI-04-04 upon the following parties of record in this proceeding, by mail 'a copy thereof, properly addressed with postage prepaid to the following: Weldon B. Stutzman Donovan E. Walker Deputy Attorneys General Idaho Public Utilities Commission O. Box 83720 Boise, ID 83720-0074 Scott L. Campbell 101 S. Capitol Blvd., 10th Floor O. Box 829 Boise, ID 83701 Mark Gennari United Water 200 Old Hook Road Harrington Park, NJ 07640-738 Chuck Mickelson City of Boise 150 N. Capitol Blvd. O. Box 500 Boise, ID 83701 Dean J. Miller McDevitt & Miller LLP 420 West Bannock St. O. Box 2564-73701 Boise, ID 83702 Bill Sedivy Idaho Rivers United O. Box 633 Boise, ID 83701 William E. Eddie Advocates for the West O. Box 1612 Boise, ID 83701 Sharon Ullman 9627 W. Desert Ave. Boise, ID 83709 Brad M. Purdy Attorney at Law 2019 N. 1 ih Street Boise, ID 83702 t-.' Douglas K. Strickling Attorney i. Intervenor Boise Cit CITY OF BOISE CITY'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO INC. - Page 6