20070117Staff to UWI 1-15.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
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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
APPROVAL OF ITS WATER
CONSERVATION PLAN AND FOR
APPROVAL OF A SURCHARGE.
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 infonnation on or before
WEDNESDAY, JANUARY 31 , 2007.
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.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of infonnation used in calculations, and the name and telephone number of the person
FIRST PRODUCTION REQUEST
TO UNITED WATER
JANUARY 17 2007
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.1: Please explain and provide a schedule to reconcile the proposed rider
funding dollars and the current level of conservation expenditures included in rates. Include also
a discussion of the following with this reconciliation:
a) Identify the level of the expenditures for the current conservation program that is
included in rates.
b) For any amortizations related to existing conservation programs, identify unamortized
balance at December 31 2006 and the monthly amortization amount.
Request No.2: What tests or analysis will be used to detennine whether United Water
Idaho s conservation program is cost effective; that is, that measurable benefits equal or exceed
its costs?
Request No.3: How will the new conservation plan encourage efficient water use by all
customers residential, irrigation and commercial?
Request No.4: Please explain how the new conservation plan identifies high-volume
. users who place the highest strain on the water supply system. Have you targeted programs to
proportionately assign increasing utility costs and future water development costs to these
customers?
Request No.5: Please provide the detailed sub-account numbers and titles that will be
assigned to the new conservation plans balancing account.
Request No.6: Please provide a sample of how the proposed rider will be identified on
the customers' bill.
FIRST PRODUCTION REQUEST
TO UNITED WATER
JANUARY 17 2007
Request No.7: Please provide the Company s analysis for unaccounted-for water.
Request No.8: What is the Company s ongoing percentage target for unaccounted-for
water?
Request No.9: For the last three years, please provide results of residential and
commercial water audits including: recommended action, remedial action taken by the Company,
and effect of water audits on individual customer consumption.
Request No. 10: The Conservation Plan does not discuss alternative rate structures as
potential conservation measures. If these measures were not considered, please explain why not.
Request No. 11: The Plan does not discuss restrictions on outdoor water use, by either
hour or day (e.g. no irrigation between llam and 6pm, odd/even day restrictions). Please
explain why these types of measures were not considered.
Request No. 12: The Plan does not discuss time of use, other than seasonality. Was
time of use considered, and if not, why not? Would programs or pricing structures that shift
irrigation or other water usage to the night-time benefit the system?
Request No. 13: If one examines the distribution of the ranking scores for the screening
of potential conservation measures, there does not seem to be a logical break in the distribution
between scores of 17 and 16, but such a break does occur between 14 and 13. There are 34
potential conservation measures with scores of 14, 15 and 16 that were eliminated from further
consideration in the screening phase, and 16 measures with a score of 17. Considering the
subjectivity of the voting in the screening process, this is a relatively minor, and probably
insignificant, difference. Was any further analysis conducted on these 34 measures? If not
why?
FIRST PRODUCTION REQUEST
TO UNITED WATER
JANUARY 17 2007
Request No. 14: What was the criteria used to detennine the cut-offpoint of 17 points
for the screening process?
Request No. 15: Is the infonnation readily available to detennine cost/benefit ratios for
these 34 screened out measures? If not, is infonnation readily available from other utility efforts
that would indicate whether any of these 34 measures are likely to have similar cost/benefit
profiles to any of the measures that had cost benefit ratios greater than one in this analysis?
Dated at Boise, Idaho, this /1
rJA.v day of January 2007.
Weldon B. Stutzman
Deputy Attorneys General
Technical Staff: Tom McKeown
Wayne Hart
Michael Darrington
i:umisc/prodreq/uwiwO6.5wstmwh prod req 1
FIRST PRODUCTION REQUEST
TO UNITED WATER
JANUARY 17 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF JANUARY 2007
SERVED THE 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:
GREGORYP. WYATT
UNITED WATER IDAHO IN
PO BOX 190420
BOISE ID 83719-0420
DEAN J MILLER ESQ
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
SECRET Y
CERTIFICATE OF SERVICE