200605053rd staff request to UWI.pdf

WELDON B. STUTZMAN
DONOY 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-
THIRD 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 FRIDAY, MAY 19, 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.
THIRD PRODUCTION REQUEST
TO UNITED WATER
MAY 5, 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.
Request No. 47: Please provide the service level for the customer service call center by month
for calendar year 2005. "Service level" is the percentage of calls answered within a certain number
seconds, e.g. 80% of calls answered within 20 seconds.
Request No. 48: Please provide a United Water Resources Inc. organizational chart reflecting
its relationship to all affiliates operating in Idaho, including United Water Idaho, LeakGuard Inc.
Home Services and USB.
Request No. 49: Please provide the number of customers being billed on their United Water
Idaho billing for LeakGuard Inc. during the test year for this case.
Request No. 50: Provide a description of work performed by employees of United Water
Idaho or any of its affiliate employee contacts with respect to LeakGuard Inc.s PO Box 9537, Boise
ID 83707.
Request No. 51: Please provide a description and the written policy explaining how the
revenues are booked when United Water Idaho receives billing revenues from legacy customers for
LeakGuard.
Request No. 52: Please provide a description and the written policy explaining how the costs
are allocated between United Water Idaho and LeakGuard Inc. for billing United Water LeakGuard'
legacy customers, answering customer questions, and responding to complaints.
Request No. 53: United Water Idaho customer payments are mailed to a post office box in
Pittsburg, P A. LeakGuard Inc.' s applications and payments are mailed to a post office box in Boise
ID. Please provide the written policy, time reporting and accounting entries showing how the cost to
process the applications and payments are recorded.
Request No. 54: Please provide a list of the number of employees and their job categories or
job titles at United Water Idaho who answer questions or inquiries regarding water damage insurance
programs under LeakGuard Inc, or any name it may also be known by.
The following production request was originally provided to the Company as Audit Request
No. 69 due March 29 2006.
Request No. 55: It is Staffs understanding that the ($1 054 261) on J. Healy s Exhibit No.
Schedule 2, Page 2 of3, Line 56 represents the difference between the Company s Plant in Service
recorded on its balance sheet and the amount recorded in its Asset Management system. Please provide a
THIRD PRODUCTION REQUEST
TO UNITED WATER
MAY 5 2006
reconciliation between the two systems that describes the reason for this difference and provide copies of
any correcting adjustments that have been made to remedy this difference.
The following three production requests were originally provided to the Company as Audit
Request Nos. 90, 91 and 97 due April 25 , 2006.
Request No. 56: While on-site in New Jersey, it was mentioned that a couple PeopleSoft cases
were opened associated with asset management. Please provide any and all documentation associated with
these cases that includes a description of the issues for PeopleSoft to resolve, the financial and operational
effect of those issues, the resolution of those issues, the time and manner in which they were resolved and
the related costs as allocated to UWI.
Request No. 57: While on-site in New Jersey, it was mentioned that there was a list of over 70
issues with PeopleS oft associated with asset management. Please provide any and all documentation
associated with these issues that includes a description of the issues requiring resolution, the financial and
operational effect of those issues, the resolution of those issues, the time and manner in which they were
resolved and the related costs as allocated to UWI.
Request No. 58: Please recalculate the monthly book depreciation for the test year and provide
the associated excel spreadsheets with original formulas intact.
The following two production requests were originally provided to the Company as Audit
Request Nos. 102 and 103 due April 27, 2006.
Request No. 59: Please provide a schedule in electronic form (excel) with formulas intact that
calculates the revenue requirement impact from backcasting Plant in Service.
Request No. 60: In its Application, the Company has requested an additional approximately
$6 million in revenue requirement. Please provide a schedule in electronic form (excel) with formulas
intact that lists the major components and corresponding revenue requirement of that increase. Please
identify at least the revenue requirement associated with replacement of infrastructure (separated by
project type), backcasting Plant in Service, 13-month rate base average, Pension Expense and any
other components to the additional $6 million request. Please contact me (Patricia Harms J for further
clarification before beginning the Company s response to this request.
Dated at Boise, Idaho, this f7t0.-day of May 2006.
i1A-(j)(!k--, Weldon B. Stutzman
Donovan E. Walker
Deputy Attorneys General
Technical Staff: Tammie Estberg
Patricia Harms
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THIRD PRODUCTION REQUEST
TO UNITED WATER
MAY 5, 2006
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF MAY 2006 SERVED
THE FOREGOING THIRD 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:
WALTON HILL
UNITED WATER
200 OLD HOOK RD
HARRINGTON PARK NJ 07640
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
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SECRET AR
CERTIFICATE OF SERVICE