20090921Staff 1-23 to UWI.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Exprèss Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
RE" C'-I\!r: ni .. . t: \j L.. .","
20U9 SEP2 l PH 3: 30
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 IN THE STATE OF IDAHO.
)
) CASE NO. UWI-W-09-1
)
)
) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO UNITED WATER IDAHO
) INC.
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Weldon Stutzman, Deputy Attorney General, requests that United Water Idaho (Company;
United Water; UWI) provide the following documents and information on or before
TUESDAY, OCTOBER 13, 2009.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 SEPTEMBER 21, 2009
This Production Request is to be considered as continuing, and United Water is requested
to provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. 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
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: Please provide all case related exhibits and workpapers containing
schedules and/or numeric data in Microsoft Excel format with original formulas intact.
REQUEST NO.2: Please provide monthly trial balances in Microsoft Excel format for
the period beginning Januar 2007 to date. Please supplement the Company's response to this
request on a monthly basis.
REQUEST NO.3: Please provide a list of all adjusting and closing entries for the
December 31, 2007 and December 31, 2008 general ledger that includes the following: date of
the entry, accounts posted, amount of the entry, type of entry, business unit posted, and related
explanation for each entry.
REQUEST NO.4: Please provide a list of all policy, operations, accounting, and cost
allocation manuals affecting United Water Idaho (UWI), including a description of each manual
and documented set of procedures that includes the date the materials were last updated. Please
make these manuals and procedures available to Staff on-site at UWI.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 SEPTEMBER 21, 2009
REQUEST NO.5: Please provide copies of any employee newsletters issued during
2006 to date. Staff has the March/April 2006 edition of the United Water Idaho "Watermark
News" and the Januar 2006 edition of the United Water Suez "The Watermark" from the prior
general rate case.
REQUEST NO.6: Please provide on-site access to any internet!intranet or other
electronic communication to employees regarding Company operations, policies and procedures.
REQUEST NO.7: Please provide a copy of the most recent employee handbocl.
REQUEST NO.8: Please provide a list of and description of accounts, activities and
business unit numbering and how the Company used them during 2006 to date. Please include
with your response information of any planed changes to these accounts, activities and business
unit numbering and usage.
REQUEST NO.9: Please provide a schedule showing where each fuction of
management and accounting is located for the Company, including a description of each fuction
along with the name, position, location and Company identification of the person performing the
fuction. If a fuction is provided by another company, indicate the company providing the
service, the contact name, phone number and address, the maner in which the services are
performed and priced and how these transactions are reflected in UWI's operations and
accounting records.
REQUEST NO. 10: Please provide the contact name and number for on-site questions
regarding access to files, including but not limited to, budgets and their underlying
documentation, budget and operational variance reports, accounting invoices, Special Facilties
Agreements, vendor contracts, constrction files, customer bilings, accounts receivable and
other documentation pertinent to the Company's rate case fiing.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 SEPTEMBER 21, 2009
REQUEST NO. 11: Please provide a descriptive list of all reports, letters, and
memoranda prepared by the Company's Internal Audit (or similar) staff in 2006 to date which
documents areas reviewed by them. Please have the documents available for on-site review at
UWI offces. Please include with your response any reports that document reviews of
procedures that affect UWI even ifUWI was not the specific focus of the review (such as
corporate processes).
REQUEST NO. 12: Please provide a detailed schedule of any land or propert sales for
the Company in 2007,2008 and 2009 to date, including the date of the sale, description of the
sale, and the account and amounts posted for the sale.
REQUEST NO. 13: Please provide a detailed description of any land or property sales
planed but not yet executed for 2009 and 2010.
REQUEST NO. 14: Please provide a copy of the policy and procedures for overhead
loading including accounts and amounts used with related explanation as to their use in 2008 and
2009, including information of any changes planed to this process.
REQUEST NO. 15: Please provide a description of the method by which materials and
supplies are recorded and/or allocated to the accounting records in 2008 and 2009, including
information of any changes planed to this process.
REQUEST NO. 16: Please provide a schedule of amounts paid for injuries and damages
in 2006, 2007, 2008 and 2009 to date, including the accounts posted and the related explanations
for damages paid.
REQUEST NO. 17: Please provide a list of all capitalized leases associated with or
allocated to UWI for 2008 and 2009, including a detailed description of the lease, the amounts
and accounts posted for each.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 SEPTEMBER 21, 2009
REQUEST NO. 18: Please provide copies of any accounting adjustments proposed for
2007,2008 and 2009 (quarerly reviews, if any) during the external audit process that would be
recorded or otherwse allocated to UWI including those that were not recorded in the accounting
records due to immateriality.
REQUEST NO. 19: Please provide a schedule that lists all projects closed to Plant in
Service since 2006 that have an early incentive bonus, payor other similar provisions. Please
include with your schedule the following: project number, project description, project costs, date
project closed to Plant in Service, date plant considered in-service, early incentive amount paid,
date early incentive amount way paid, and justification for each early incentive amount paid.
REQUEST NO. 20: Please provide on-site access to (and photocopies when requested
of) the Constrction Work in Progress reports for each project added to Plant in Service since the
last rate case.
REQUEST NO. 21: Please provide an electronic copy in Microsoft Excel format (with
formulas intact) of the advance and refud spreadsheet maintained by the Company that is
reconciled to the general ledger accounts 25200.
REQUEST NO. 22: Please provide all reports and/or letters stating the outcome of any
federal and/or state tax return audits in 2006,2007,2008 and 2009 to date and the Company's
response. Please include with your response all taxes including income and sales tax.
REQUEST NO. 23: Please state whether the Company is currently undergoing any
federal and/or state tax retur audit. Please include whether the Company has been notified of
any such audits even if the audit is not yet underway.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 5 SEPTEMBER 21,2009
sr
Dated at Boise, Idaho, this .:l day of September.
Ln Wei on B. Stutzman
l7' Deputy Attorney General
Technical Staff: Patricia Hars/l-23
i:umisc:prodreqluwiw09. i wsksph prod reql.doc
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 6 SEPTEMBER 21, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21sT DAY OF SEPTEMBER 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO UNITED WATER IDAHO INC., IN CASE NO.
UWI-W-09-1 BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
KEVIN H. DOHERTY
UNITED WATER IDAHO INC
200 OLD HOOK ROAD
HARRINGTON PARK, NJ 07640
E-MAIL: Kevin.doherty(iunitedwater.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(imcdevitt-miler.com
~~
SECRETARY
CERTIFICATE OF SERVICE