20050415UWI 1st production request to staff.pdf

ORIGINAL
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
ioe~mcdmtt-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-O4-
FIRST PRODUCTION REQUEST
OF UNITED WATER IDAHO INC.
TO THE COMMISSION STAFF
United Water Idaho Inc. (United), by and through its attorney of record, Dean J. Miller of
the firm of McDevitt & Miller LLP, requests that the Staff of the Idaho Public Utilities
Commission (Staff) provide the following documents and information and responses to requests
for admissions on or before April 29, 2005. United requests that Staffplace special priority on
answering these requests as soon as possible. In recognition that some questions require less
time to answer than others, United asks that Staff file responses in batches as they are completed
rather than wait for the most time-intensive questions to be finished.
Staff 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. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Staff 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.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
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.
The following Requests are in reference to Mr. English's Testimony.
Request No.1: Please refer to page 7, line 21 through page 8 , line 8 of Mr. English'
testimony. Please provide a copy of the Department of Labor s Bureau of Labor Statistics Wage
and Salary Compensation Survey released in August 2004 to which Mr. English refers.
Please highlight within the Survey the hourly wage references Mr. English refers
to: $17.75 per hour, $16.63 per hour and $15.58 per hour.
Mr. English refers to the 2003 average base wage of United Water employees as
$23.25 cents per hour. Please provide all details of this calculation. Please
indicate if this calculation included both hourly and exempt employees. If exempt
employees are included in Mr. English's calculation, please provide the rationale
for expressing an exempt salaried employee annual salary in terms of an hourly
wage.
Request No.2: Please refer to page 11 , line 19 through page 12, line 25 of Mr. English'
testimony. Mr. English states starting on line 21 that "at the time of the filing of this testimony,
the position of Public Relations Manager is still vacant". Please refer to the Company s first
update of Staff Production Request No. 198, filed on April 4, 2005, where the Company updated
it's adjustment to Payroll to 0 & M expense pursuant to the March 4, 2005 meeting with Staff
members. Please also refer to the e-mail sent from Mr. Healy to Mr. English dated March 28
2005 in which Excel files documenting the revisions made to Payroll expense and Health Care
expense were documented.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
Did the payroll file indicate that the Public Relations Manager position was filled
and the new employee would begin his assignment on April 18 at a starting salary
of $56 500?
Please indicate in your reference to Mr. Healy s direct testimony, page 8, where
the term "lobbying" is included in the characterization of the Public Relations
Manager job duties.
Please reference the term "lobbying" in the newspaper ads referenced in Mr.
English's testimony, page 12, lines 11 to 14.
Finally, did the Staff request that the Company provide a copy of the job
description for the position of Public Affairs Manager?
Request No.3: Please refer to page 32, line 6 through 10 and Adjustment No. 11
Exhibit No. 108, Schedule 11 of Mr. English's testimony.
Please provide all workpapers in electronic format that produce the $260 042
reduction of purchased power expense.
If the calculation of Mr. English's adjustment removes the PCA component from
known and measurable power rates, please provide the rationale for doing so.
Request No.4: Please refer to Adjustment No. 11 , Exhibit No. 108, Schedule 11 of Mr.
English's testimony which reduces purchased power expense by $260 042 from the Company
requested level of expense. Please also refer to Mr. Sterling s testimony, Exhibit No. 122, page
of4.
What is the purpose of two adjustments made to the same expense? Mr. English
reduces the Company s requested power expense from $1 756 803 to $1,496 761.
Please reconcile Mr. English's adjustment with Mr. Sterling s which seems to
increase the test year level of expense up to the same $1 496 761.
Request No.5: Please refer to page 36, lines 6 through 17 of Mr. English's testimony.
Mr. English refers to the Kelly Blue Book wholesale value of vehicles United Water will be
disposing of in 2005 to be $53 300, as opposed to United Waters estimate of$31,442. Please
copy the pertinent pages from the Kelly Blue Book and indicate how the $53 300 was derived.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
Did Mr. English physically inspect the vehicles in question to ascertain for himself their
condition, mileage, options, etc.
Request No.6: Please refer to page 37, lines 7 through 23 of Mr. English's testimony,
and his adjustment Exhibit No., Schedule 19 pertaining to Customer Information System
Expense. Company Witness Healy, in his testimony and workpapers, utilizes test year customer
bills produced (460 978) and past due notices produced (85 839) to derive a ratio of 0.186211
past due notices for every customer bill issued. Mr. Healy then estimated customer bills
annualized for the estimated May, 31 2005 customer count to be 475 995 and, by application of
the test year ratio, he estimated past due notices to be 18.6211 % of total bills or 88 635. Mr.
English adjusts the past due notice count back to the test year level, stating "it would be
impossible to determine the exact amount of' that will be mailed in any given year . Please state
the factual basis for using an estimated bill count and at the same time using a test year based
volume of past due notices same accounting adjustment. To "state the factual basis" means to
state each and every fact and opinion supporting the adjustment and provide all supporting
documentation.
Request No.7: Please refer to page 37, line 24 through page 38, line 11 of Mr. English'
testimony and his corresponding Exhibit 108, Schedule 20, adjustment to Customer Outside
Collection Expense, in which he reduces the Company s proposed level of expense from $79,465
to $49 450 or by $30 015. Also, please refer to Company Witness Healy s Exhibit No.3
Schedule 1 , page 20 of 34. On line 6 of Witness Healy s adjustment, he indicates a price per unit
for lock box transactions of $0.2344. When multiplied by an anticipated 346 19110ckbox
transactions (line 5) the total price is $81 147. Please see line 13 of Witness Healy s adjustment
where he lowers the totallockbox price by $30 000. When subtracted from the above-mentioned
gross lockbox price of $81 147, the result is $51 147. When this result is divided by 346 191
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-4
lockbox transactions, it derives a unit price of $0.1477. Please admit that due to the way the
Company presented it's adjustment, and due to the Company s Response to Staff Production
Request No. 172, Mr. English is inadvertently duplicating an adjustment that Company Witness
Healy has already made and Mr. English's adjustment should be reversed.
Request No.8: Please refer to pages 41 through 45 of Mr. English's testimony regarding
the Company s relocation policy.
Please state the factual basis for the assertion that the "Company s relocation
policy is excessive . To "state the factual basis" means to state each and every
fact and opinion supporting the assertion and provide all supporting
documentation.
Please state the factual basis for the assertion that" pertaining to this specific
individual position, the Company could have hired locally or promoted from
within . To "state the factual basis" means to state each and every fact and
opinion supporting the assertion and provide all supporting documentation.
Request No.9: Please refer to page 47, lines 13 through 23 of Mr. English's testimony.
Mr. English states
, "
pursuant to Commission precedent, the Company removed from test year
expenses $14 005 for charitable contributions, country club dues and the lobbying portion of
industry association dues. Staff recognizes the Company s attempt to comply with previous
Commission Orders, however a review of Company s expenses indicates that the Company did
not remove all of these costs. Specifically, the Company spent $3 800 on scholarships and
sponsorships and $11 833 on Company sponsored events such as golf tournaments, Christmas
parties, and Fourth of July parties during the test year
Please provide the Company with the specific Commission Orders Mr. English
relies upon in determining these expenses must be disallowed.
In particular, please produce a United Water Idaho or Boise Water Corporation
order of recent vintage that would have alerted the Company that such expenses
are not appropriate for recovery.
Request No. 10: Please refer to Mr. English's testimony regarding adjustment of test
year legal expense on pages 51 and 52, through line 20. Mr. English accepts the Company
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
adjustment to legal expense, then identifies three specific legal matters ($2 818 related to the
disposition of Carriage Hill, $248 related to the Cartwright Tank removal and $7 980 related to
Idaho Power s operation of the Danskin Power Plant) amounting to $11 046, which he
characterizes as "extraordinary, non-recurring incidents
Please produce a legal bill that contains any reference to a legal matter pertaining
to the operation of Idaho Power s Danskin Power Plant.
Please explain how a $248 legal matter can be construed as an "extraordinary
event.
Did Mr. English review the Company s recent historical legal expense and
attempt to determine a normalized level?
Request No. 11: Please refer to Mr. English's testimony, page 32, lines 10 through 22
referring to deferred power cost. Mr. English states "that because the Company was awarded a
carrying charge on the deferred balance, Staff has removed the deferred balance from rate base.
Please cite the specific language in Commission Order No. 28800 issued in Case UWI-01-
that awards the Company a carrying charge on the accrual of deferred power.
The following Requests are in reference to Ms. Stockton s testimony
Request No. 12: Please refer to page 10, lines 15 to 24 of Ms. Stockton s testimony.
Ms. Stockton indicates that the Company needs to stop accruing AFUDC on projects that are
included in rate base but are not yet placed in service at the time rates become effective. Please
explain the rationale and logic supporting Ms. Stockton s assertion that the Company must stop
accruing AFUDC on the full CWIP balance, while the Company earns a return on only 1/13 of
its investment.
Request No. 13: Please refer to page 6, lines 23 and 24 of Ms. Stockton s testimony.
Please state the factual basis for the assertion that the Company is incorrectly applying SF
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
109. To "state the factual basis, means to state each and every fact and opinion supporting the
assertion and to provide all supporting documentation.
Request No. 14: Please refer to Exhibit No.1 05 included in the testimony of Ms.
Stockton. On line 8, Ms. Stockton refers to Staff s calculation of tax depreciation of
$15 545 339. Please provide all workpapers that support this calculation.
The following Requests are in reference to Ms. Hall's Testimony.
direct testimony.
direct testimony.
Request No. 15: Please refer to page 5 lines 5 through 8 of Ms. Hall's direct testimony.
Please provide all documents from ratings agencies, Le., Standard & Poor
Moody , Fitch, etc., which supports Ms. Hall's assertion that United Water
Idaho, Inc. has a current' A' credit rating.
Request No. 16: Please refer to page 13, line 21 through page 14, line 5 of Ms. Hall'
What is the Company , i., United Water Idaho Inc.s bond rating.
Please provide all documents from ratings agencies, i., Standard & Poor
Moody , Fitch, etc., in support of Ms. Hall's response to part (a).
Request No. 17: Please refer to page 14, line 24 through page 15, line 4 of Ms. Hall'
Ms. Hall discusses the market risk of her sample water utilities. Please provide a
complete and detailed discussion of the specific business risks of United Water
Idaho, Inc. relative to these sample water utilities.
Please provide all empirical analyses conducted or reviewed by Ms. Hall which
supports her response to part (a).
Please provide all source documents, electronic spreadsheets and calculations
supporting Ms. Hall's response to part (a).
Request No. 18: To the extent not provided elsewhere in response to these discovery
requests, please provide copies of all workpapers (electronic and paper), electronic spreadsheets
(with formulas intact), source documents, and publications utilized by Ms. Hall in preparing her
direct testimony and accompanying schedules.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
The following Requests are in reference to Ms. Carlock's Testimony.
direct testimony.
Request No. 19: Please refer to page 7, line 21 through page 8, line 4 of Ms. Carlock'
Please provide all empirical analyses conducted by or reviewed by Ms. Carlock
which support her assertion that United Water Idaho, Inc.s investment risk will
be less following the outcome of the current case because of the inclusion of the
Columbia Water Treatment Plant in rate base as if it were in service for the full
year. Please provide all source documents, electronic spreadsheets and
calculations supporting these analyses.
Please provide the identity of the "other utilities" referenced on page 8, line 2.
Please provide all empirical analyses conducted by or reviewed by Ms. Carlock
which support her assertion that "(t)he investment risk for UWI will still be lower
than for other utilities even though the Staff recommends the average of monthly
averages rate base instead of the forecasted year-end rate base proposed by the
Company." Please provide all source documents, electronic spreadsheets and
calculations supporting these analyses.
Does the inclusion of the CWTP in rate base in full (not averaged) reduce the
investment risk for UWI? Please provide the rational for your answer.
Does the Staffs rate base averaging increase the investment risk for UWI? Please
provide the rational for your answer.
If the new rates reflect a rate base that does not include plant actually in service at
the time the new rates are effective, all else being equal will UWI have the
opportunity to earn the allowed rate of return? If your answer is yes, state the
factual basis therefore.
Request No. 20: Please refer to page 8, lines 13 through 16 of Ms. Carlock's direct
testimony. Please provide the following:
The identity of the companies utilized by Ms. Carlock in her Comparable
Earnings method.
A copy of the source documents, electronic spreadsheets and calculations relied
upon by Ms. Carlock in developing the "reasonable return on equity attributed to
United Water Idaho (of) 9.5% - 10.5% under the Comparable Earnings method.
Request No. 21: Please refer to page 10, line 25 through page 11 , line 5 of Ms.
Carlock's direct testimony.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
testimony.
testimony.
testimony.
Please provide all source documents, electronic spreadsheets and calculations
supporting Ms. Carlock's conclusion of the cost of equity for United Water Idaho
Inc. using the Discounted Cash Flow method of between 8% and 10.5%.
Please identify the "various time intervals" referenced on line 2 of page 11 of Ms.
Carlock's direct testimony.
Please identify the companies relied upon for the dividend yield of 3.4% to 3.
and growth rate of 5% to 6% referenced in lines 4 and 5 of page 8.
Request No. 22: Please refer to page 10, lines 13 through 19 of Ms. Carlock's direct
Please provide all source documents, electronic spreadsheets and calculations
supporting Ms. Carlock's conclusion of expected growth rate of 5% to 6%
referenced on line 14 of page 8.
Request No. 23: Please refer to page 12, lines 5 through 7 of Ms. Carlock's direct
Please provide all empirical analyses conducted by or reviewed by Ms. Carlock
which support her conclusion of a "point estimate of 10%" common equity cost
rate.
Please provide all source documents, electronic spreadsheets and calculations
supporting Ms. Carlock's response to part (a).
Request No. 24: Please refer to page 12, lines 10 through 13 of Ms. Carlock's direct
Please provide the "market data" referenced in line 11.
Please provide the identity of the "comparables , referenced in line 12, and the
data for the "comparables" relied upon by Ms. Carlock.
Please provide all data relied upon for and the identity of the companies in the
water utilities industry" referenced in line 13.
Please provide all empirical analyses conducted by or reviewed by Ms. Carlock
which support the "average risk characteristics" referenced in line 12.
i. Is it Ms. Carlock's testimony that United Water Idaho, Inc. is of average
risk relative to other water utilities? Why or why not? If yes, please
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
provide all empirical analyses conducted by or reviewed by Ms. Carlock
which support her response.
Request No. 25: To the extent not provided elsewhere in response to these discovery
requests, please provide copies of all workpapers (electronic and paper), electronic spreadsheets
(with formulas intact), source documents, and publications utilized by Ms. Carlock in preparing
her direct testimony and accompanying schedules.
The following Requests are in reference to Mr. Sterling s Testimony.
Request No. 26: Please refer to page 14, Line 13 through Page 15 , Line 5 of Mr.
Sterling s direct testimony. Given that United Water employed a competitive bidding process for
obtaining the design build contractor (Reference page 17, lines 5-9), and that virtually all
subcontractor work on the CWTP was competitively bid (Reference page 10, line 25 to page 11
line 1), please state the factual basis for the assertion that that the CWTP could have been
procured at a lower cost and that United Water did not obtain the best value for its customers.
To state etc
Request No. 27: Please refer to page 30, line 9 of Mr. Sterling s direct testimony.
Please state the factual basis for the assertion that 2.8 acres are currently unused. To "state the
factual basis" means to state each and every fact opinion and calculation used to arrive at the
figure of2.8 acres and to provide all supporting documentation.
Request No. 28: Please refer to page 30, line 21 of Mr. Sterling s direct testimony.
Please state the factual basis for the assertion that 3 200 square feet of floor spaces has no
apparent current use. To "state the factual basis" means to state each and every fact opinion and
calculation used to arrive at the figure of 3 200 and to provide all supporting documentation.
Request No. 29:Please refer to page 32, lines 11 through 22. Please state the factual
basis for removing the effects of Idaho Power s PCA from the calculation of allowed electric
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
power expense. To "state the factual basis " means to state each and every fact and opinion
supporting the adjustment and to provide all supporting documentation and calculations.
testimony.
testimony.
Request No. 30: Please refer to page 34, lines 10 through 11 of Mr. Sterling s direct
Please identify the factual basis for the assertion that the "IMAP is intended to
preserve and protect water rights for future use." To "state the factual basis
means to state each and every fact and opinion supporting the assertion and to
provide all supporting documentation.
Does Mr. Sterling contend that the IMAP's exclusive purpose is to preserve and
protect water rights for future use? If the answer is anYthing other than an
unqualified yes, please identify every other purpose Mr. Sterling believes the
IMAP serves and state the factual basis therefore. To "state the factual basis
means to state each and every fact and opinion supporting the assertion and to
provide all supporting documentation.
Request No. 31: Please refer to page 34, lines 18 through 24 of Mr. Sterling s direct
Please state the factual basis for the assertion that permit no 63-312409 is
specifically for the purpose of ground water recharge." To "state the factual
basis " means to state each and every fact and opinion supporting the assertion
and to provide all supporting documentation.
Does Mr. Sterling contend that permit no. 63-31409 can be used only for the
purpose of ASR through ground water recharge? If the answer is anYthing other
than an unqualified yes, please identify every other purpose Mr. Sterling believes
permit no. 63-31409 can serve and state the factual basis therefore. To "state the
factual basis " means to state each and every fact and opinion supporting the
assertion and to provide all supporting documentation.
Request No. 32: Please refer to page 36, lines 15 through 18 of Mr. Sterling s direct
testimony. Please state the factual basis for the assertion that United Water expects to be able to
secure approximately "500 to 4 900" acre feet of water under these rights. To "state the factual
basis " means to state each and every fact and opinion supporting the assertion and to provide all
supporting documentation.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
Request No. 33: Please refer to page 37, lines 6 through 20 of Mr. Sterling s direct
testimony.
Does Mr. Sterling contend that a water right's monetary value is based
exclusively on the volume in acre feet authorized by the water right? If the
answer is anYthing other than an unqualified yes, please explain how Mr. Sterling
believes the monetary value of a water right should be calculated and the factual
basis therefore. To "state the factual basis " means to state each and every fact
and opinion supporting the assertion and to provide all supporting documentation.
Did Mr. Sterling review any comparable water right purchase and sale
transactions to determine whether the price United Water paid for the Initial Butte
water rights was in accordance with market prices? If so, please identify each
transaction, and, for each transaction, the price paid for the water right and the
basis upon which the price was calculated.
Request No. 34: Please refer to page 42, lines 1 through 25 of Mr. Sterling s testimony.
Please state the factual basis for your assertion that the Company s normal annual purchased
water expense should be less than the test year expense before CWTP and why you believe the
one signed contract will be sufficient water supply for CWTP in 2005 given that you admit that
United Water may have to purchase even higher levels of surface water supply in 2005 due to
poor water supply conditions. To "state the factual basis " means to state each and every fact
and opinion supporting the assertion and to provide all supporting documentation.
Request No. 35: Please refer to page 44, lines 10 through 12 of Mr. Sterling s direct
testimony. Please state the factual basis for removing the effects of Idaho Power s PCA from the
test year and from current rates applied to estimated usage. To "state the factual basis " means to
state each and every fact and opinion supporting the adjustment and to provide all supporting
documentation and calculations.
Request No. 36: Please refer to page 46, lines 23 through 25 of Mr. Sterling s direct
testimony. Please state the factual basis for the assertion that "the deferral was intended only to
provide temporary relief from the extremely high power costs resulting from the short-term
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
Western energy crisis." To "state the factual basis " means to state each and every fact and
opinion supporting the assertion and to provide all supporting documentation.
Request No. 37: Please refer to page 54, lines 16 through 25 of Mr. Sterling s direct
testimony.
Does Mr. Sterling contend that costs associated with customer meters vary with
the amount of water use? If so, state the factual basis therefore. To "state the
factual basis " means to state each and every fact and opinion supporting the
assertion and to provide all supporting documentation.
Does Mr. Sterling contend that costs associated with customers services vary with
the amount of water use? If so, state the factual basis therefore. To "state the
factual basis " means to state each and every fact and opinion supporting the
assertion and to provide all supporting documentation.
If costs associated with meters and services do not vary with the amount of water
use, please state the economic rationale for recovering those costs through the
variable component of United's rates. To "state the economic rationale" means to
state each and every fact and opinion constituting an economic rationale and to
provide citations to any supporting economic literature.
These Requests are in reference to the testimony of Mr. Lobb.
Request No. 38: Please refer to page 6, lines 15 through 25 of Mr. Lobb's testimony and
to IPUC Order No. 29505, pg 7. Please provide all calculations and computations used to
determine the amount of $995 497 as a proxy for items not properly reflected under the matching
concept. Provide the same also in Excel electronic spreadsheet with all formulas intact.
Request No. 39: Please refer to page 7, lines 12 through 24 of Mr. Lobb's testimony.
Is it Mr. Lobb's contention that a 13 month average test year is proper for
every utility, regardless of size, rate of growth and other factors? If so
state the factual basis for said contention. To "state the factual basis
means to state each and every fact and opinion supporting the assertion
and provide all supporting documentation.
If it is Mr. Lobb's contention that the decision to employ a year end or
average rates base should be made on a case-by-case basis, please state
each and every fact and opinion that justifies use of an average rate base
for United Water in this case.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
Please admit that in every case since 1993 (1993: ON 25062; 1994: ON
25640: 1997: ON 27612; 2000; ON 28505). United Water proposed a
year end test year and the year end test year was not opposed by Staff.
If you have denied the preceding question, state the factual basis therefore.
To "state the factual basis" means to state each and every fact and opinion
supporting the assertion and provide all supporting documentation.
If you have admitted part (c), state each and every fact or opinion that
justifies sudden departure from a regulatory practice that has been in place
for more than 10 years.
Please admit that at no time prior to the filing of this case did Staff advise
the company that Staff was considering a change from the year end test
year convention to an average year convention.
If you have denied the preceding question, state the factual basis therefore.
To "state the factual basis" means to state each and every fact and opinion
supporting the assertion and provide all supporting documentation.
Please admit that the first time the company was alerted to Staff s intent to
change from a year end convention to an average year convention was
when the Company received Staffs pre-filed testimony.
If you have denied the preceding question, state the factual basis therefore.
To "state the factual basis" means to state each and every fact and opinion
supporting the assertion and provide all supporting documentation.
Request No. 40: Please admit that in the rate period following the Commission s order
in this case, the revenues produced by rates proposed by Staff will be insufficient to allow the
Company to earn a reasonable return on its investments in plant that is used and useful in service
to the public during the rate period.
If you have denied the previous question, state the factual basis therefore.
To "state the factual basis" means to state each and every fact and opinion
supporting your denial and to provide detailed calculations supporting
your contention that revenues will be sufficient to permit the opportunity
to earn a reasonable return on capital actually invested.
If you have admitted the previous question, please state a detailed legal
and policy justification for the proposition that a public utility should be
compelled to provide service to the public without just compensation.
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
Dated this tl day of April, 2005.
McDEVITT & MILLER LLP
FIRST PRODUCTION REQUEST OF UNITED WATER IDAHO INC. TO THE COMMISSION STAFF-
CERTIFICATE OF SERVICE
I hereby certify that on th~ay of April, 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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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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Bill Sedivy
ldahe--R:iver-s-lJnit-ed-.
O. Box 633
Boise, Idaho 83701
Fax: [phone]
iru~idJ!..horivers. org
Sharon Ullman
9627 West Desert Avenue
Boise, Idaho 83709
Fax: [phone]
~haronu~cableone.net
Chuck Mickelson
Boise City Public Works
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]
cmicke Ison~cityotPoise. org
Douglas K. Strickling
Boise City Attorney s Office
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]
~ing~cityotPoise.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~moffatt.com
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OF u dr~ INC. TO THE COMMISSION STAFF-