20091022Staff 24-32 to UWI.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
R.i:CE# i" '\ i._ l ,~l ."t.f
2009 OCT 22 PH 2: 00
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys 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 IN THE STATE OF IDAHO.
)
) CASE NO. UWI-W-09-1
)
)
) SECOND 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,
Kristine A. Sasser, Deputy Attorney General, requests that United Water Idaho (Company;
United Water; UWI) provide the following documents and information on or before
THURSDAY, NOVEMBER 12, 2009.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 OCTOBER 22, 2009
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 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 hearng if need be. Reference IDAP A
31.01.01.228.
In addition to the wrtten copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 24: What has Micron's usage been over the last three years? What is it
expected to be in the test year? Given Micron's usage volatilty, how has the Company estimated
futue usage? What, if any, modifications have been made to Micron test year consumption?
Please provide all assumptions used in establishing Micron test year consumption. Please
provide the analysis in electronic executable format.
REQUEST NO. 25: Similar to what occurred in 1989, where aparment buildings in the
service area were reclassified from residential to commercial, has the Company reclassified
customers since its last rate case? If yes, how has the reclassification of customers impacted the
Company's estimates of future customer growth and usage in the test year?
REQUEST NO. 26: Has the Company sold or acquired any new water systems in the
area? If yes, please describe the transactions and explain how they have impacted the Company's
test year estimates of customer growth and usage. Please provide the corresponding analysis in
electronic executable format.
REQUEST NO. 27: The Company states that "the cost of anual purchased water has
ranged from approximately $186,000 to $122,000 during the period from 2004-2009" (Rheed
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 OCTOBER 22, 2009
Testimony, page 4). Please provide the year-over-year historical purchased water expenses for
thè period in the format shown in Rheed's Exhibit No.5, page 1.
REQUEST NO. 28: Please provide copies of all federal and State income tax returns,
attachments, and related workpapers that identify accounts, amounts, and calculations used in
preparing the returs at the United Water Idaho business unit level and those that have been
consolidated for filing with the related taxing authorities for 2006, 2007, 2008 and 2009
(quarerly or other returns, if any) to date. Please include within your response the related
(supporting) electronic fies, such as Excel spreadsheets, with formulas intact calculating various
tax items such as depreciation.
REQUEST NO. 29: Please provide copies of federal and State quarerly and anual
payroll tax reports for the years ended 2006, 2007, 2008, 2009 to date and the related
workspapers that identify accounts, amounts and calculations used in preparing those reports.
Please include within your response the related (supporting) electronic fies, such as Excel
spreadsheets, with formulas intact.
REQUEST NO. 30: Please provide a detailed description of all tax positions held by the
Company that are reflected in its tax returs.
REQUEST NO. 31: Please provide a detailed description of all tax changes that have
occurred since the prior rate case to date. Please include within your response the reason for the
change (the specific provision/citation in the American Recovery and Reinvestment Act for
example), the type of change (bonus depreciation of X% extended, for example), the financial
effect of that change (the accounts that were charged/credited for tax puroses), the amounts
posted and/or calculated for tax puroses, the book/ta differences calculated (in dollars) and the
accounts where they were posted.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 OCTOBER 22, 2009
REQUEST NO. 32: Staff has received the Company's response to Production Request
No. 21 in which the Company provided an electronic copy ofthe advance and refund spreadsheet
maintained by the Company that is reconciled to the general ledger Account 25200. That fie
consists of one worksheet labeled 2009-2014. Please provide an electronic copy of the advance
and refud spreadsheet maintained by the Company for the period from the time of the last
general rate case to the timeframe (2009-2014) of the spreadsheet already provided.
r' "" tJ
Dated at Boise, Idaho, this oid day of October.
KAMi''b~i ao ~4JPIl
Kristine A. Sasser
Deputy Attorney General
Technical Staff: Matt Elar24-27
Patricia Harms/28-32
i:umisc:prodreqluwiw09.1 wsksmeph prod req 2.doc
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 OCTOBER 22, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF OCTOBER 2009,
SERVED THE FOREGOING SECOND 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(funitedwater.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(fmcdevitt-miler.com
,b~
SECRETARY
CERTIFICATE OF SERVICE