200603271st staff request to UWI.pdf

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WELDON B. STUTZMAN
DONOV AN E. WALKER
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone] AND [phone]
IDAHO BAR NO. 3283 AND 5921
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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-06-
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO UNITED WATER IDAHO
INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Weldon B. Stutzman, Deputy Attorney General, requests that United Water Idaho Inc. (United
Water; Company) provide the following documents and information on or before MONDAY
APRIL 17, 2006.
The Company 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 IDAP A 31.01.01.228.
This Production Request is to be considered as 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.
FIRST PRODUCTION REQUEST
TO UNITED WATER
MARCH 27 2006
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 production requests are in reference to Jerry Healy s testimony:
Request No.1: Please provide spreadsheets, workpapers or other information showing
the derivation of the total annual power expenses as shown in Expense Adjustment No.7 for wells
and boosters billed under Idaho Power Schedules 7 and 9S. Please provide in an electronic Excel
format.
The following production requests are in reference to Scott Rhead's testimony:
Request No.2: Please provide an updated copy of all leases, purchase agreements or
other contracts for water as shown on Exhibit 10. Please summarize the current status of each
lease, purchase agreement or contract for water and clearly indicate those that have already been
executed for 2006, those which are still pending, and the expected execution date of those which
are pending. When will all leases, purchase agreements or other contracts for 2006 be completed?
Request No.3: Please provide records showing the quantities of water treated daily by
the Columbia Water Treatment Plant from the date the plant went online until the present.
Request No.4: Please list and describe specific actions taken by CDM to achieve early
completion of the CWTP.
Request No.5: IfUWI desired to have the Columbia Water Treatment Plant (CWTP)
construction and testing complete by early April 2005, please explain why UWI did not require
an April 2005 completion date in the original contract, with no provisions for an early
completion bonus.
Request No.6: On what date does UWI estimate that CDM would have completed
construction and testing of the CWTP had no early completion incentive been offered?
Request No.7: What was the amount of the bonus paid to CDM for early completion?
Did CDM earn the maximum bonus possible under the early completion incentive provisions of
the contract for the CWTP?
FIRST PRODUCTION REQUEST
TO UNITED WATER
MARCH 27, 2006
Request No.8: What criteria or standards were used to determine the official
completion date of the CWTP for purposes of determining eligibility and computing the early
completion bonus paid to CDM?
Request No.9: Please list and describe all work on the CWTP completed after the
official completion date for purposes of determining eligibility and computing the early
completion bonus paid to CDM. Was CDM or any of its subcontractors paid for any work
completed after the official completion date?
Request No. 10: Were progress payments made to CDM based on the actual costs
incurred by CDM during a period, or were the payments made for predetermined amounts
regardless of CDM' s actual costs?
Request No. 11: Why would CDM agree to complete the project early and receive a
bonus of$3 500 per day if the alternative was to complete the project according to the original
schedule and be paid $5 191 per day? Wouldn t CDM have received $1 691 more per day if it
completed the project according to the original schedule?
Request No. 12: Besides the $3 500 per day early completion incentive, what other
incentives did CDM have to complete the project early?
Request No. 13: On page 5, line 22 through page 6, line 3 of your direct testimony, you
state " Yes. Included in the CDM contract was an allowance for project management costs
computed on a per diem basis. These costs are shown on Exhibit 8 , page 1 of 1 and total $5 191
per day. These costs are charged to the project each day up to the date of substantial completion
so long as the guaranteed maximum price is not exceeded." The document shown in Exhibit 8
does not appear in the CDM contract provided to Staff in Case No. UWI-04-, nor in CDM'
proposal to UWI. Please provide a copy of the document from which Exhibit 8 was extracted.
In addition, please provide any supporting documentation to back up the statements in your
testimony reference above.
Request No. 14: Assuming project management costs of$5 191 per day had been
charged and that construction of the CWTP had not been completed early, on what date would
the Guaranteed Maximum Price have been equaled?
Request No. 15: On page 8, lines 5-, you state "The Snake and Boise River runoff
forecast is expected to be sufficient to allow the exchange of surface water between the river
basins as established by the Company s Initial Butte and Wilson Farm Water right purchases.
Please state the amount of water the Company expects to be able to exchange in 2006 for both
the Initial Butte and Wilson Farm water rights.
Request No. 16: Exhibit 8 includes 1 300 acre-feet of a total of2 745 acre-feet of the
Wilson rights, and 4 200 acre-feet of a total of 9 247 acre-feet of the Initial Butte water rights.
Are these the amounts the Company expects it will be able to exchange in a normal water year?
FIRST PRODUCTION REQUEST
TO UNITED WATER
MARCH 27 2006
Request No. 17: The total volume of water available for use by UWI in a normal year
appears to be 16 854 acre-feet (Rhead Exhibit 10). The information provided on rebuttal in Case
No. UWI-04-4 (Rhead Exhibit No. 16 , Schedule 7) shows a total normal volume of water
available to be 13 454 acre-feet. Both exhibits include a note stating that the Marden Water
Treatment Plant and the Columbia Water Treatment Plant need approximately 12 000 to 13 000
acre- feet to operate at summer peak capacity. Please identify and describe additional water
purchases or leases since the UWI - W -04-4 case and explain why the additional amounts are
needed. For example, given that 2006 is likely to be a much better water year, explain why UWI
has acquired 3,400 more acre-feet of water in 2006 than were acquired in 2004, and why UWI
needs to acquire more water through lease and rental in 2006 than in 2004 when it expects to be
able to exchange Snake River water in 2006 that could not be exchanged in 2004.
Request No. 18: Does UWI expect to need to acquire water from the Basin 63 Rental
Pool in years when it will be able to exchange Wilson Farm and Initial Butte Snake River water?
Does UWI believe it needs to acquire Basin 63 Rental Pool water in a normal year? If so, how
much?
Dated at Boise, Idaho, thiscJlfA..day of March 2006.
eldon B. Stutzman
Donovan E. Walker
Deputy Attorneys General
Technical Staff: Rick Sterling
i :umisc/prodreq/uwiwO6.2wsps I
FIRST PRODUCTION REQUEST
TO UNITED WATER
MARCH 27, 2006
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF MARCH 2006
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO UNITED WATER IDAHO INC.IN CASE NO.
UWI-06-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
w ALTON HILL
UNITED WATER
200 OLD HOOK RD
HARRINGTON PARK NJ 07640
DEAN JMILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ill 83701
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CERTIFICATE OF SERVICE