2005030811th UWI Response Part 1.pdf

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Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
o. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
ioe~mcd~-miller.com
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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- W -04-
ELEVENTH RESPONSE OF UWlD
TO STAFF'S PRODUCTION
REQUESTS
COMES NOW United Water Idaho Inc. ("United"
, "
the Company ) and responds to
Request Numbers 115, 116, 119, 121 , 122 (confidential), 124, 126, 128, 133, 138 145, 146, 147
and 148 of Staffs Fourth Production Requests; Request Numbers 156 and 161 of Staffs Fifth
Production Request; and Number 186 of Staff s Sixth Production Request.
Dated this L~Y of March, 2005.
McDEVITT & MILLER LLP
Dean J. iller
Attorneys for United Water Idaho Inc.
ELEVENTH RESPONSE OF UWID TO STAFF'S PRODUCTION REQUESTS-1
CERTIFICATE OF SERVICE
I hereby certify that on th ay of March, 2005, I caused to be served, via the method(s) indicated below, true and
correct copies of the foregoing document, upon:
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S. Mail
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 hotmai1.com
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William M. Eddie
Advocates for the West
O. Box 1612-83701
1320 West Franklin Street
Boise, Idaho 83702
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Fax
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Email
Bill Sedivy
Idaho Rivers United
O. Box 633
Boise, Idaho 83701
Fax: [phone]
iru~idJ!.hori verso 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~cityofboise.org
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Email
Scott L. Campbell
Moffatt Thomas
101 South Capitol Blvd., 10th Floor
O. Box 829-83701-0829
Boise, Idaho 83702
Fax: [phone]
~c~moffatt.com
~~~
4~~Z;-ELEVE H RESPO D 0 STAfF'S PRODUCTION REQUESTS-2
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UNITED WATER IDAHO INC.
CASE UWI-O4-
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness:Scott Rhead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO. 115:
Once UWI had selected COM to design and build the CWTP , what incentive did
COM have to keep the Guaranteed Maximum Price as low as possible? Please
provide all documentation , including any subcontractor bids and material or
equipment quotes, used by COM in the preparation of the final GMP. Was the
Target Cost of Work provided by COM in its proposal a factor considered in
establishing the Guaranteed Maximum Price? If so, how?
RESPONSE NO. 115:
The incentive to keep the GMP as low as possible was explained in Response
No. 114 and No. 119.The GMP dated January 28, 2004 and totaling $16,844 458
was developed from quotes of subcontractors and vendors in addition to tasks
planned for self-performance by COM. The selected group was chosen from the
subcontractor quotation list previously provided in response No.1? The non-
binding Target Cost of Work provided at the time of proposal had no connection
or relevance in establishing the final GMP.
UNITED WATER IDAHO INC.
CASE UWI-W-O4-
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness:Scott Rhead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO. 116:
In response to Staff Request No. 17 in which Staff asked for the Company to
provide evidence of competitive bidding between subcontractors, UWI provided
three pages summarizing subcontractor quotations for 18 different construction
categories. In a format similar to that used in Request No. 17 , please provide a
more detailed summary that lists all major construction tasks and
materials/equipment procurement, that identifies which bids were accepted, and
that shows amounts paid for tasks self-performed by COM. Please show a total
for all bids accepted, plus all work self-performed by COM , plus a total and
description for all other project costs, and reconcile any difference between this
amount and the Guaranteed Maximum Price.
RESPONSE NO. 116:
The final GMP dated January 28, 2004 provides all of the available detail. The
final GMP document was provided in the response to Production Request No.
15. The final GMP was incorporated into contract amendment #1 dated February
, 2004 and included as well in the response to Production Request No.15. Each
work section is identified with associated descriptions, man-hours, labor
material , equipment and subcontractor if known. Some lines or sections have
numerous vendors and subcontractors that result in the cost shown for that work
section (Le.: section 11000). As the job progressed COM found that it was not
cost effective to self perform the work originally planned to be self performed and
shown in the final GMP (Le. in section 16000 COM $1 650,543 vs. Automation
Electronics bid of $1 524 389).
A finalline-by-line cost reconciliation of actual costs compared toGMP costs is
not yet available due to the fact the project is not completed. The Company and
COM expect to obtain and provide this specific detail by April 15th. The GMP
appears to be more than adequate due to favorable conditions.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FOURTH PRODUCTION REQUEST OF THE COMMISSION 51 AFF
Preparer/Recordholder/Sponsoring Witness:Scott Rhead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO. 119:
Section 6.1 of the design-build contract with COM provides that if the actual
Cost of the Work and Design-Build Fee is less than the Guaranteed Maximum
Price, the savings shall be 1000/0 to UWI. What incentive does COM have to
complete the project at less than the GMP? Why didn t UWI agree to share any
savings with COM?
RESPONSE NO. 119:
The incentives for completing the project costs below the GMP have previously
been discussed in Response No. 114 and 115. The contractor is paid their fee
independent of total project cost. Any cost savings accrue to the benefit of the
Company and ultimately the customer. Additionally, savings achieved through
COM's efforts serve to enhance their reputation for performing work within or
below budget expectations. The Company provided aggressive management
throughout the project in order to take advantage of savings ideas and to control
costs.
UNITED WATER IDAHO INC.
CAS E UWI-W -04-
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/RecordholderlSponsoring Witness:Scott Rhead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO. 121:
The results of the August 2001 Leopold DAF Pilot Plant Study indicate that OAF
pretreatment significantly increased the treatment capacity of the UF membrane
filtration module used for the study; consequently, less membrane filter area
would be needed if DAF pretreatment was employed. In addition, one of the
proposals received by UWI for the CWTP recommended the use of DAF, citing a
net savings in construction costs due to a reduction in required membrane area.
Please provide a copy of any economic or other analysis used by UWI to decide
not to employ DAF in the treatment process. Demonstrate that the cost savings
not to include DAF pretreatment outweigh the increased cost of additional
membrane filter area.
RESPONSE NO. 121:
A copy of the CDM pricing analysis of the DAF treatment option is attached. This
analysis demonstrates that while use of DAF pretreatment was anticipated to
reduce the cost of the membrane system by $250,000, there would be a net
increase in cost to the project of over $625 000 to include the OAF facilities.
United Water also determined that as an alternative to pretreatment, potential
reductions in membrane system production could be mitigated by increasing the
frequency of membrane backwash and cleaning, or by temporarily increasing
production from other sources. United Water determined that these potential
operational impacts would be brief and manageable.
Attorney s Certificate
The undersigned certifies that he is the attorney for the Applicant, that he is familiar
with the material attached hereto, and in good faith believes that said material is exempt
from inspection by the general public pursuant to the Idaho Trade Secrets Act, Idaho
Code, 48/802 ct seq. and/or the Idaho Public Records Act, Idaho Code 9/337 et seq.
Dean J. Miller
Attorney for Applicant
NFID ENTIAL
ATTACHMENTS
UNITED WATER IDAHO INC.
CASEUWI-W-O4-
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Aecordholder/Sponsoring Witness:Scott Ahead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO. 124:
What is the expected replacement cost of the ultra filtration membranes?
RESPONSE NO. 124:
The expected replacement cost of the membranes is difficult to predict due to
evolving technology and emerging improvements in expected life. At the present
time United Water believes the best way to estimate this cost is to evaluate the
warranty and replacement information as attached. USFilter states they will
replace the membranes for $700 per module, or the prevailing list price
whichever is lower. Assuming the membranes have a seven year life and no
other factors change, the replacement cost would be: ($700/module) x (112
modules per mgd) x (6 mgd capacity) = $470,400.
UNITED WATER IDAHO INC.
CASE UWI-O4-04
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Aecordholder/Sponsoring Witness:Scott Ahead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO. 126:
Please explain and give specific examples of how COM controls costs and stays
within budget on the construction and materials/equipment procurement for the
CWTP.
RESPONSE NO. 126:
All major equipment, supplies, and subcontractors were procured via lowest
qualified bid. The costs are tracked weekly on COMs cost accounting system.
All changed conditions are tracked and negotiated and contingency items are
tracked monthly. No unauthorized changed conditions are allowed for payment
without having the change order signed off by 2 COM senior staff. This allows a
review of the plans and specifications to confirm that the change conditions are
justified. COM has been able to disallow many of the requested change orders
by working with the design engineers and referencing the plans and
specification. Examples of COM controlling costs include:
During the excavation of the basins extensive rock was identified in a
corner of one basin even though the area had been cleared by the
geotech investigation. After initially using excavators to remove the rock
COM evaluated the cost to blast the areas and discovered that the cost
could be reduced by over $40 000. The blasting option was then done
thereby reducing the amount of contingency used.
. COM reduced cost of offsite soil disposal by over $30,000 by negotiating
with the adjacent property owner who needed the soil for fill in a previously
excavated area. The soil was then transported to the nearby location and
disposed of for the cost of compaction vs. paying a disposal fee.
After the electrical inspector enforced newly established regulations
requiring UL listing on certain electrical panels, COM held firm denying a
change order for UL listing on the process panels. The panels were
supplied by one of the subcontractors; COM stated that the contract
required that the panels meet state and local regulations even though the
specific requirement for UL listing was not contracted. This saved
approximately $12,000 in costs.
. CDM contracted directly with the basin shotcrete subcontractor after
discovering the civil subcontractor had marked the work up 200/0. The
over all savings was close to $50,000 because on the cost plus fixed fee
contract COM did not mark up the shotcrete subcontractor s cost.
During the installation of the castellated beams, CDM allowed the beam
coating to take place on site saving nearly $6,000 in transportation costs.
During the procurement of the pumps, COM negotiated a special price
with the pump vendor by choosing one vendor for all the pumps after
confirming that the vendor could supply pumps that met the requirements.
This saved over $80,000 based on the original quotes from multiple
vendors.
In nearly every aspect of the construction there is some area where COM has
value engineered or negotiated savings for United Water during the plant
construction.
UNITED WATER IDAHO INC.
CASE UWI-W-O4-
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness:Scott Rhead
Telephone: [phone]
Title: Managing Engineer
REQUEST NO. 128:
CDM's proposal states that it eliminated at least seven major systems as
presented in the 2002 Basis of Design Report. Please identify which of these
systems were ultimately eliminated in the final plant design. Estimate any
reduction in costs as a result of elimination of such systems.
RESPONSE NO. 128:
The table below identifies the 5 major systems presented in the 2002 Basis of
Design Report that were ultimately eliminated in the final plant design, along with
the associated cost that would have been incurred, based on the Basis of Design
Report cost estimates. Two of the major systems were utilized.
Major System Estimated Savings
Inlet Structure $260,000
DAF 820,000
Membrane Feed Pump Station $884 000
Washwater Equalization Basins $260,000
UV Disinfection $910,000
UNITED WATER IDAHO INC.
CASE UWI-O4-04
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
REQUEST NO. 133:
Preparer/Aecordholder/Sponsoring Witness:Scott Ahead
Telephone: [phone]
Title: Managing Engineer
Of the total COM contract amount (GMP) of $16,844 498 what amount or
percentage was subject to competitive bidding by contractors or competitivematerials and equipment procurement?
RESPONSE NO. 133:
The project can be broken down approximately as follows (based on the GMP):
Mate rials
Subcontractors
Engineering
CM/GCs
Tax/Bonds/Ins
Fixed Fee
Escalation
Miscellaneous
Conti nge ncy
$ 3, 112,000
$ 7,448,000
$ 1 940,000
$ 1 930,000
$ 603,000
$ 888,000
$ 107 000
$ 266,500
$ 550,000
$16,844 498
Based on the above costs, the materials and subcontractors ($10,560,000) were
competitively bid after the selection of the O/B contractor. The engineering was
competitively procured during the initial selection process. The engineering (both
design and construction) was approximately 120/0 of the projects costs - this is
less than the normal 80/0 for design and 80/0 for construction. The fixed fee was
also competitively procured as part of the initial selection. The fixed fee value
represents approximately 60/0 markup for the construction, which is low for work
with this level of risk. The CM/GCs represent approximately 12 % of the project
costs, which is standard for a construction project. After the GMP was put in
place and the project started the CM and GCs were negotiated down whenever
possible. As an example the rate for vehicles was reduced from $800/mo to
$500/mo after United Water evaluated the market rate. Also a local
superintendent was substituted for one from out of town after the local
superintendents qualifications were established saving the cost of per diem.
COM has also been able to ramp the CM activities up and down depending on
the level of effort required. The escalation estimate of less that 1 % is low for any
multi-year construction project and is especially low given the nature of the
exploding costs of raw materials, especially steel , seen over the past 2 years.
The contingency was strongly negotiated during the GMP contracting phase and.
represents approximately 40/0 which is low given the amount of risk COM took on
with the project. COM competitively procures both Bonding and Insurance rates
to be sure they are competitive in the market. Based on their size and history
COM receives extremely competitive rates. Of the total $16,844,498 contract
amount, United Water believes that 900/0 of the value was competitively procured
either through the initial process, the bidding for materials and subcontractors, or
management of the contract by United Water.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Recordholder/Sponsoring Witness:Jeremiah Healy
Telephone: [phone]
Title: Coordinator of Planning and Rates
REQUEST NO. 138:
Please provide the job description and starting wages for a Senior Technical
Analyst.
RESPONSE NO. 138:
Starting wages for a Senior Technical Analyst as of March 2003 were $81,500.
The job description is as follows:
Role Summary: Seasoned technologist providing advanced technical
leadership; mentors junior staff with responsibility for their technical development.
Technical Expertise- Breadth and Depth: Possesses broad knowledge of
multiple processes and/or technical/scientific disciplines, and can address
problems or projects that require an understanding of the interrelationship of
these processes or disciplines. Provides technical leadership in their area(s) of
specialization. May be called to testify before regulators or represent United
Water before regulatory bodies.
Business Knowledge: Demonstrates advanced expertise in the company
processes, business strategies and trends in the industry. Seen as a
knowledgeable industry expert, such that they may provide expert testimony.
Problem Solving: Leads efforts to address problems related to complex
processes and systems, which may require the integration of knowledge from
multiple processes and technical disciplines. Can resolve nearly all problems
either directly or through a network of experts they have developed.
Project Role: Leads larger more complex projects, typically involving multiple
vendors, multiple technical disciplines, the use of outside experts, and that may
last for a year or more. Can produce complete project plans, and contribute to a
business case for a project.
Customer Role: Serves as a key point of contact for customers, negotiating
terms and conditions and committing to results. Educates customer~ on technical
aspects of work. Participates in the project planning process, putting together an
RFP, contributing to the project plan, and/or development of proposals.
Communication Skills: Can produce complete project plans, and contribute to a
business case for a project. Communicates work status to customers and
management proactively, managing expectations effectively. Forms productive
networks with internal and external customers and the vendor community.
Qualifications: Typically requires ten or more years of experience and a
Bachelor s Degree in a relevant scientific/technical discipline or equivalent.
Advanced degree desirable.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
REQUEST NO. 145:
Preparer:Mark Gennari
Telephone[phone]
Title: Director of Regulatory Business
Please provide copies of the 2003 and 2004 Form 1 OK for all affiliated entities
that file.
RESPONSE NO. 145:
The only publicly traded company is Suez and as a foreign owned company it
doesn t have a requirement to file a 10K. However, Suez does file a Form 20F
which can be found on the Suez web site (www.suez.com) under Investor
information. The latest available Form 20 F is for 2003 and consists of 311
pages.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Mark Gennari
Telephone: [phone]
Title: Director - Regulatory Business
REQUEST NO. 146:
The following two paragraphs provide some detailed background that pertain to Questions
146 through 148:
On October 2004, President Bush signed into law the American Jobs Creation Act of
2004. This act includes tax relief for domestic manufacturers by providing tax deduction up to
percent (when fully phased in) of the lesser of qualified production activities income as defined
in the act or 2) taxable income (after the deduction for the utilization of any net operating loss
carry forwards).
For instance, liGas, electricity and water. Qualified domestic production gross receipts
(QOPGR) include gross receipts from the production in the United States of electricity, gas and
potable water, but exclude gross receipts from the transmission of these items...
Activities included in the production of potable water include the acquisition, collection and
storage of raw (untreated) water as well as the transportation of raw water to, and the treatment
of raw water at, treatment facility. However, gross receipts attributable to the storage of potable
water or the delivery of potable water to customers do not give rise to QOPGR. A taxpayer that
both produces and distributes potable water must properly allocate gross receipts between
qualifying and non-qualifying domestic production gross receipts (H.R. Conf. Rep. No. 108~755).
(Tax Legislation 2004; American Jobs Creation Act of 2004; Law, Explanation and Analysis; CCH
Editorial Staff Publication; pages 88-89)
Has United Water Idaho or its parent corporation(s) done any investigation or
research to ascertain how this act applies to the Company or its parentcorporation?
RESPONSE NO. 146:
This provision will apply to United Water Idaho. However, at this time United
Water Idaho is still in the process of determining how it will separate gross
receipts from production vs. gross receipts from distribution and storage.
Guidance will be provided through U.S. Treasury Regulations that have yet to be
released.
UNITED WATER IDAHO INC.
CASE UWI-W-O4-
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Mark Gennari
Telephone: [phone]
Title: Director - Regulatory Business
REQUEST NO. 147:
The following two paragraphs provide some detailed background that pertain to Questions
146 through 148:
On October 22, 2004, President Bush signed into law the American Jobs Creation Act of
2004. This act includes tax relief for domestic manufacturers by providing tax deduction up to
percent (when fully phased in) of the lesser of qualified production activities income as defined
in the act or 2) taxable income (after the deduction for the utilization of any net operating loss
carry forwards).
For instance, "Gas, electricity and water. Qualified domestic production gross receipts
(QDPGR) include gross receipts from the production in the United States of electricity, gas and
potable water, but exclude gross receipts from the transmission of these items...
Activities included in the production of potable water include the acquisition, collection and
storage of raw (untreated) water, as well as the transportation of raw water to, and the treatment
of raw water at, treatment facility. However, gross receipts attributable to the storage of potable
water or the delivery of potable water to customers do not give rise to QDPGR. taxpayer that
both produces and distributes potable water must properly allocate gross receipts between
qualifying and non-qualifying domestic production gross receipts (H.R. Conf. Rep. No. 108-755).
(Tax Legislation 2004; American Jobs Creation Act of 2004; Law, Explanation and Analysis; CCH
Editorial Staff Publication; pages 88-89)
Please provide a schedule and a description of how this Act applies to the
Company, and/or its parent; and a schedule showing the financial impact and
how it was calculated.
RESPONSE NO. 147:
It is premature to determine how the domestic production deduction will impact
United Water Idaho because the U.S. Treasury has yet to promulgate regulations
that will give guidance on how to allocate between gross receipts from production
and gross receipts from distributions.
UNITED WATER IDAHO INC.
CASE UWI-W-O4-04
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Mark Gennari
Telephone:[phone]
Title: Director - Regulatory Business
REQUEST NO. 148:
The following two paragraphs provide some detailed background that pertain to Questions 146
through 148:
On October 22, 2004, President Bush signed into law the American Jobs Creation Act of 2004.
This act includes tax relief for domestic manufacturers by providing a tax deduction up to percent (when
fully phased in) of the lesser of qualified production activities income" as defined in the act or 2) taxable
income (after the deduction for the utilization of any net operating loss carry forwards).
For instance, "Gas, electricity and water. Qualified domestic production gross receipts (QOPGR)
include gross receipts from the production in the United States of electricity, gas and potable water, but
exclude gross receipts from the transmission of these items...
Activities included in the production of potable water include the acquisition, collection and storage of raw
(untreated) water, as well as the transportation of raw water to, and the treatment of raw water at, a
treatment facility. However, gross receipts attributable to the storage of potable water or the delivery of
potable water to customers do not give rise to QOPGR. A taxpayer that both produces and distributes
potable water must properly allocate gross receipts between qualifying and non-qualifying domestic
production gross receipts (H.R. Conf. Rep. No. 108-755). (Tax Legislation 2004; American Jobs Creation
Act of 2004; Law, Explanation and Analysis; CCH Editorial Staff Publication; pages 88-89)
Specifically, please provide the following associated with the production credit
American Jobs Creation Act of 2004 , Code Sec. 199, attributable for the actual
conduct of business:
a) Provide a detailed schedule showing the calculation of the new
production credit for 2005 and 2006 as it relates to the Marden
Treatment Plant and the Columbia Treatment Plant. Please
calculate even if you haven t reflected the credit in this filing.
b) Provide detailed workpapers including an electronic version with
formulas intact.
c) If the credit is already included in the filing please reference the
appropriate adjustments and accounts.
RESPONSE NO. 148:
As stated in the Company s responses to Production Request No.s 147 and 148,
it is premature to make such a calculation before the U.S. Treasury or the IRS
provides guidance in this area.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Mark Gennari
Telephone: [phone]
Title: Director of Regulatory Business
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.
RESPONSE NO. 156:
No investor expenses of United Water Resources Inc.s parent company are
allocated to United Water Idaho and therefore none are being requested to berecovered in rates.
UNITED WATER IDAHO INC.
CASE UWI-W-O4-
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Mark Gennari
Telephone:[phone]
Title: Director of Regulatory Business
REQUEST NO. 161:.
Please provide copies of all written correspondence between the Company
actuaries and United Water and any of its affiliates from January 1 2002 tocurrent date.
RESPONSE NO. 161:
The Company doesn t regularly correspond with its actuary. Most of the
correspondence relates to the issuance of the actuary s estimate and analysis of
the Company s financial status of the pension plan. Correspondence in the form
of a series of questions and answers from the Company about the pension plan
were provided and are contained within the five years of actuarial reports
provided in response to Audit Request No. 58. Additionally, there is
correspondence with the Actuary in the form of contribution/funding letters to our
Treasury group. Those letters are attached herein. Beyond this, there are verbal
special requests made for special studies or information requests that are usually
rate case related and specific to requests made by the Commissions in the
Company s other jurisdictions.
UNITED WATER IDAHO INC.
CASE NO. UWI-O4-04
FIFTH PRODUCTION REQUEST
IPUC STAFF
ATTACHMENT TO
RESPONSE TO
REQUEST NO. 161
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