20071211UWI to Staff 34-36.pdf

McDevitt & Miller LLP
Lawyers
[phone]
[phone] (Fax)
420 W. Bannock Street .£l \ G pr\ 4: 51
P.o. Box 2564-831iil 0 .v
Boise, Idaho 83702
Chas. F. McDevitt
Dean J. (Joe) Miler
December 10, 2007
l'a Hand Delivery
Jean Jewell, Secretary
Idaho Public Utilties Commission
472 W. Washington St.
Boise, Idaho 83720
Re: Case No. UWI-W-07-04
Dear Ms. Jewell:
Enclosed for fiing in the above matter please find three (3) copies of United Water Idaho's
Responses to Commission Staffs First Production Requests, No's 34, 35 and 36.
An additional copy of the document and this letter is included for return to me with your fie
stamp thereon.
Very Truly Yours,~er~
DJM/hh
Enclosures
ORIGINAL
Dean J. Miler (ISB No. 1968)
MCDEVITT & MILLER LLP
420 West Banock Street
P.O. BOX 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
joeWlmcdevitt-mier .com
;;f1yioi:r 10L:tJUi~i, .4: 51
Attorney for United Water Idaho Inc.
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 COSTS )ASSOCIATED THEREWITH )
)
CASE NO. UWI-W-07-04
UNITED WATER IDAHO INC'S
RESPONSE TO COMMISSION
STAFF'S FIRST PRODUCTION
REQUESTS
United Water Idaho Inc, ("United Watet') by and though its undersigned attrneys,
hereby submits its Responses to the Commission Staffs First Production Requests No.'s 34, 35,
and 36.
DATED this \ \) day of December, 2007.
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S FIRT PRODUCTION
REQUESTS-l
CERTIFICATE OF SERVICE
I hereby ceify that on the ~y of December, 2007, I caused to be sered by the
methodes) indicated below, a tre and correct copy of the foregoing document, upon:
Jean Jewell, Secreta
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
jjewell(ãuc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Donovan Walker
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S FIRST PRODUCTION
REQUESTS-2
UNITED WATER IDAHO INC.
CASE UWI.W.07.04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Record holder: Jeremiah Healy
Sponsoring Witness: Greg Wyatt
Telephone: [phone]
Title: General Manager
REQUEST NO. 34:
Please provide all the documentation on cost and prices charged by any affliate
of United Water that is included in the cost estimate for this case.
RESPONSE:
The average cost per employee related to training included in this case was
based on twelve months ended August 2007 actual costs ($38,783) allocated
from United Water Management & Services Company for United Water Idaho's
portion of corporate-wide training. Aside from this training cost, there is no cost
or prices charged by any affilate of United Water included in the cost estimate for
this case.
UNITED WATER IDAHO INC.
CASE UWI.W.07.04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Record holder: Jeremiah Healy
Sponsoring Witness: Greg Wyatt
Telephone: [phone]
Title: General Manager
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?
c) Please provide the annual pension cost of the Company per
dollar of salary/wages earned.
RESPONSE:
a) United Water Idaho's estimated per employee pension cost was
developed based on an average because an incremental
actuarial cost evaluation would have been costly and too many
variables are unknown; such as the age, gender, life expectancy,
etc. of the new employees.
b) Annual salary/wages is only one variable affecting individual
employee pension costs. Other factors, including gender, life
expectancy, etc. significantly affect the per employee cost. As
stated above we do not yet know those aspects of the new
employees simply because we have not yet hired them.
c) Based upon pension expense recorded on the books of the
Company for the twelve month period ended August 2007, in
accordance with FAS 87, which is $581,054, and the annualized
wages and salaries of the Company's full complement of
employees (92) as of the most recent pay date, $4,400,890, the
annual pension cost of the Company per dollar of salaries/wages
earned is $0.132.
."
UNITED WATER IDAHO INC.
CASE UWI-W-07 -04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Record holder: Jeremiah Healy
Sponsoring Witness: Greg Wyatt
Telephone: [phone]
Title: General Manager
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.
RESPONSE:
a) There is none.
b) No actuarial study was done solely for the additional employees.
c) Not Applicable
d) Payments are made to two Voluntary Employee Benefits Associations.
One VEBA is for the Bargaining Plan, the other for the Non Bargaining
Plan.
e) The Trustee is Diversified Financial Services
f) The Company has requested a digital file containing the most recent
actuarial valuation from Human Resources and it wil be forwarded to
Staff as soon as it is received.