20050415UWI 1st production request to IRU.pdf

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Dean 1. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
joe~mcdevitt -miner .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-O4-
FIRST PRODUCTION REQUEST
OF UNITED WATER IDAHO INC.
TO IDAHO RIVERS UNITED
United Water Idaho Inc. (United), by and through its attorney of record, Dean J. Miller of
the firm of McDevitt & Miller LLP, requests that Idaho Rivers United (IRU) provide the
following documents and information on or before April 29, 2005.
This Production Request is to be considered as continuing, and IRU is requested to
provide, by way of supplementary response, 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.
F or 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.
The following Requests are in reference to Mr. Wojcik's testimony.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO IDAHO RIVERS UNITED-
Request No.1: Please refer to Mr. Wojcik's testimony, page 4, lines 19 - 20.
Please provide all factual evidence that United Water is seeking to gather most of
its revenue increase via the bi-monthly fixed service increase.
Please identify the dollar amounts of revenue increase requested that stem from
the fixed-charge component and the volumetric component of the proposed $6.
million increase.
Request No.2: Please refer to page 5, lines 9-10 of Mr. Wojcik's testimony. Please
provide all factual evidence that the current winter/summer rate structure
, "
does not effectively
promote efficient water use during the period of peak use
Request No.3: In Mr. Wojcik's testimony on page 5, line 17 to page 6, line 2, Mr.
Wojcik laments that a "relatively few high-volume customers are more expensive for the utility
to serve , and that "it would be unfair to pass on the costs by these relatively few customers to
those who use more modest amounts.
Please identify what is meant by the terms "high-volume customers" and "more
modest amounts.
Please identify who are the customers and how many of them there are that fit the
definitions of high-volume and more modest.
Please identify how many of these referenced high-volume customers reside in a
portion of the United's system that will be receiving water supplied by the new
Columbia Water Treatment Plant.
Request No.4: Please refer to page 7, lines 15-16 of Mr. Wojcik's testimony.
Please provide all factual evidence that increasing block rate designs maintain a
stable flow of revenue for the utility to cover its increasing costs.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO IDAHO RIVERS UNITED-
Please provide factual evidence that a dramatic change in rate structure to a three
tiered, inclining rate block tariff will not destabilize United's revenues in the year
such rates are placed into effect.
Please provide all factual evidence to substantiate that revenue stability would be
assured in ensuing years assuming the inclining rate block structure is employed
as suggested.
Request No.5: With a three-tiered, inclining rate block structure as recommended in
Mr. Wocjik's testimony, what would be the impact on United's revenues if water consumption
by customers was lowered by 15% from test year levels due to a more rainy and cooler summer
than normal?
Request No.6: Please refer to page 8, line 12 of Mr. Wojcik's testimony. Please provide
copies of all "widely used studies on water usage" relied upon as the basis for Mr. Wojcik'
estimate of per capita indoor water use.
Request No.7: Please refer to page 9, lines 5-6 of Mr. Wojcik's testimony. Please
provide all factual evidence to support the claim that "it is more likely that this very low
customer group is more correlated to single-occupant households than low-income households.
Also, please provide all factual evidence that supports the inference that single-occupant
households are not low-income households.
Request No.8: Referencing Mr. Wocjik's discussion that begins on page 9, line 13.
What usage levels would be priced at higher rate blocks.
Please identify how it will be possible to accurately assess "average customer use
patterns in summer months.
Please identify how United would identify what constitutes an "efficiently-
watered average landscaped yard in UWI's service area.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO IDAHO RIVERS UNITED-
Please identify what are the definitions of "efficiently-watered"
, "
common
vegetation choices , and "average lot size or irrigable area per customer" for the
United Water system.
Request No.9: Please refer to page 12, lines 8-9 of Mr. Wojcik's testimony. Please
provide all information regarding the compatibility of the $55 in-home usage monitoring device
implemented in Aurora, Colorado with the current metering system used in the United Water
system. To your knowledge is the Aurora device compatible at the same cost?
Request No. 10: In Mr. Wojcik's testimony he cites the City of Albuquerque, New
Mexico as an example of a city that has used a comprehensive conservation program as a
primary cost-effective future supply source. If Mr. Wojcik is suggesting that Boise could
achieve similar results as Albuquerque if a similar program were initiated, please provide data
for the past ten (10) years that compares temperature and precipitation rates during the period of
May through September for the cities of Boise, Idaho and Albuquerque, New Mexico.
Dated this day of April, 2005.
McDEVITT & MILLER LLP
Dean J. Miller
Attorneys for United Water Idaho Inc.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO IDAHO RIVERS UNITED-4
CERTIFICATE OF SERVICE
I hereby certify that on th y of April, 2005, \ caused to be served, via the methodes) indicated below, true and
correct copies of the foregoing docu ent, upon:
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Brad M. Purdy
Attorney for the Community Action Partnership
Association of Idaho
2019 North 17th Street
Boise, Idaho 83702
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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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Bill Sedivy
Idaho Rivers United
O. Box 633
Boise, Idaho 83701
Fax: [phone]
iru~id~horivers.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]
cm i eke lson~cityo tboise. org
Douglas K. Strickling
Boise City Attorney s Office
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]
~ ing~cityofPoise.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~mof:fatt.com
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~RODUCT Q E OF ~AHO INC. TO IDAHO RIVERS UNITED-5
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