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Home My WebLink About20071108Staff to UWI 1-42.pdfDONOV AN E. WALKER DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0312 IDAHO BAR NO. 5921 RECEIVE LOOi NOV -8 AN 8: 32 iDAHO PUBLIC UT!LITIES COMfAISSIOi. 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. TO IMPLEMENT A PROGRAM OF MONTHLY BILLING AND FOR RECOVERY OF COSTSASSOCIATED THEREWITH. CASE NO. UWI-07- 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 Donovan E. Walker, Deputy Attorney General, requests that United Water Idaho Inc. (United Water; Company) provide the following answers, documents and lor information as soon as possible and in any event no later than THURSDAY, DECEMBER 6, 2007. Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder. See IDAP A 31.01.01.228.02. 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. Id. FIRST PRODUCTION REQUEST TO UNITED WATER NOVEMBER 8, 2007 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. Request No.1: Please provide copies of the contracts for all services, including billing, with UBS. Request No.2: Please describe the selection process used in obtaining the billing services now provided by UBS. Request No.3: Please describe any and all connections or affiliations between UBS and United Water Idaho or any ofthe corporate affiliates of United Water Idaho. Request No.4: Please describe the ownership ofUBS, and identify any individuals owning more than 2% of both UBS and any corporate affiliate of United Water Idaho. Request No.5: Please identify any individuals ~ho are employees or directors for UBS who are also employees or directors of any corporate affiliate of United Water Idaho. Request No.6: Please describe in detail the services provided by vendor UBS. Request No.7: Please describe the services to be provided by the four (4) additional customer service representatives identified in the Company s Application that would be required if monthly billing were implemented. Request No.8: How many customer service representatives does the Company currently employ? Request No.9: Please identify the process and any formulas and inputs or assumptions used to calculate the estimated reductions in bad debt expenses identified on line 25 of Exhibit No.1 in Mr. Wyatt's direct testimony. FIRST PRODUCTION REQUEST TO UNITED WATER NOVEMBER 8 , 2007 Request No. 10: Please identify the process and any formulas and inputs or assumptions used to calculate the estimated imputed reduction in working capital due to improved cash flow identified on line 26 of Exhibit No.1 in Mr. Wyatt's direct testimony. Request No. 11: Please identify the process and any formulas and inputs or assumptions used in estimating each of the costs identified on Exhibit No. I in Mr. Wyatt's direct testimony. Request No. 12: Please describe any services provided to United Water Idaho by Mellon Bank, US Bank, and Credit Data. Provide copies of any contracts for services provided by these vendors. Request No. 13: Please identify any other outside firms, including those that may be corporate affiliates of United Water Idaho, that provide any services to United Water Idaho that are expected to be either increased or decreased if the Company implements monthly billing. Describe in detail the nature and current costs of those services, and provide any contracts that may apply to such services. Request No. 14: Please identify any amounts paid to United Water Idaho by outside firms , including corporate affiliates, for including material in billings sent to United Water Idaho customers, i., bill stuffers for LeakGuard, etc. Request No. 15: Please provide a copy of the recent study prepared by United Water and/or United Water Idaho regarding the feasibility of converting to automated meter reading. Request No. 16: Does the Company anticipate converting to automated meter reading? If so, when? If not, why not? Request No. 17: What is the normal replacementlretirement schedule for water 'meters used by the Company? FIRST PRODUCTION REQUEST TO UNITED WATER NOVEMBER 8 , 2007 Request No. 18: By year, how many meters were replaced in 2005 , 2006, and YTD 20077 Request No. 19: By year, how many new meters were set for newly connected customers in 2005 , 2006 and YTD 20077 Request No. 20: When did the Company start offering electronic bill presentment and electronic payment options to its customers? Request No. 21: How many customers currently receive their bills electronically? Request No. 22: How many customers currently pay their bills electronically? How many customers pay under a debit payment agreement? Request No. 23: For each of the past three (3) years (2005, 2006 and YTD 2007), how many complaints has the Company received about the following subjects: (1) bi-monthly billing; (2) high bills; (3) service line leaks; and (4) problems associated with dual irrigation systems? Request No. 24: For each ofthe past three (3) years (2005, 2006 and YTD 2007), how many requests has the Company received for implementation of monthly billing? Request No. 25: For each of the past three (3) years (2005 , 2006 and YTD 2007), what is the total dollar amount associated with leak adjustments given to customers by the Company? Request No. 26: Please provide the current bill cycle schedule. Request No. 27: What is the normal time interval between meter reading and customer billing? FIRST PRODUCTION REQUEST TO UNITED WATER NOVEMBER 8 , 2007 Request No. 28: Please explain how the Company determined the number of additional customer notices that will be generated as referenced in Company Exhibit No., line 21? Request No. 29: Please provide a copy of all the customer communications inserts sent to customers in the last two years. Please provide with each insert the date sent to the customers and the purpose for the insert. Request No. 30: Please describe or provide copies ofthe additional bill inserts referenced in Company Exhibit No., line 24, that will be distributed if monthly billing is approved. Request No. 31: Please provide the number of incoming calls handled by the customer service call center by month for each of the past three (3) years (2005 , 2006, and YTD 2007). Request No. 32: Please provide the service level for the customer service call center by month for each of the past three (3) years (2005, 2006 and YTD 2007). "Service level" is the percentage of calls answered within a certain number of seconds, e., 80% of calls answered within 20 seconds. Request No. 33: Please provide the Company s performance objectives for handling incoming calls. Request No. 34: Please provide all the documentation on cost and prices charged by any affiliate of United Water that is included in the cost estimate for this case. Request No. 35: Please provide the following for pension costs: a) All documentation showing that the pension costs to the new employees would be equal to the average employee cost. b) Are individual pension costs different for employees who earn different annual salaries/wages? FIRST PRODUCTION REQUEST TO UNITED WATER NOVEMBER 8, 2007 c) Please provide the annual pension cost of the Company per employee per dollar of salary/wages earned. Request No. 36: Please provide the following for post retirement health care: a) All documentation showing that the post retirement health care cost would be equal to the average employee cost. b) Please include any actuarial studies that show what the discounted present value cost of the additional employees for this post retirement health care cost. c) Please reference the section and page numbers related to this discussion. d) Please state to whom this expense is paid. e) Who is the trustee of these funds? f) Please provide any studies or reports showing the current actuarial justification for these costs. Request No. 37: Please provide all documentation showing that the additional cost for the long-term disability insurance is equal to the average cost for each employee. Is the cost of the insurance dependent upon the level ofthe employee s compensation? Request No. 38: Please provide all documentation showing how the total amount of administrative costs of $32 040 for 401k, VEBA, Med. Open enrollment & Actuarial Services was determined. Request No. 39: Please provide all documentation showing how the total cost of ADP payroll, HRIS , Health & Welfare Cost in the amount of$17 237.35 was determined. Request No. 40: Please provide the following related to training: a) All documentation showing that the average cost of $426.90 per employee for corporate training fees was determined. b) Please explain why the actual costs of corporate training are spread evenly over all employees. FIRST PRODUCTION REQUEST TO UNITED WATER NOVEMBER 8, 2007 c) Are the actual costs of training each employee the same? d) Please provide any studies or documentation showing that training each employee is the same, or any studies showing that the cost of training different employees is different. Request No. 41: Please provide all documentation justifying and supporting UBS' increase in costs from $0.72 per bill to $0.93 per bill. Please provide an explanation why the additional bills should cost more to provide to the customers than the current bills. Request No. 42: Please provide a copy of the current Corporate Organizational Chart showing all affiliates. Respectfully submitted this 1 day of November 2007. iJJc !i0-- Donovan E. Walker Deputy Attorney General Technical Staff: Wayne Hart!l - 7, 9 - 14 Daniel Klein/8 , 15 - 33 Joe Leckie/34 - 42 i:umisc:prodreq/uwiwO7.4dwwhdk prl FIRST PRODUCTION REQUEST TO UNITED WATER NOVEMBER 8, 2007 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 8TH DAY OF NOVEMBER 2007 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO UNITED WATER IDAHO INC., IN CASE NO. UWI-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: GREGORYP. WYATT UNITED WATER IDAHO INC PO BOX 190420 BOISE ID 83719-0420 DEAN J MILLER ESQ McDEVITT & MILLER LLP PO BOX 2564 BOISE ID 83701 CERTIFICATE OF SERVICE