20091104UWI to Staff 25-26, 30, 32.pdf

McDevitt & Miller LLP
Lawyers
November 4, 2009
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0'4 -4 l\' 2.i \ 6innq N, Chas. F. McDevitt
'0 ~..iH(. 'i ?l..)f:'J..~':.\;~. lirt\l~ (Joe) Miler\ r\'~ rt." '\ " ,n;;.í\'~c' r, ;\~~r, '., '-'\lí\U i:,).'"~J .~
[phone]
[phone] (Fax)
420 W. Bannock Street
P.O. Box 2564.83701
Boise, Idaho 83702
Via Hand Delivery
Jean Jewell, Secreta
Idao Public Utities Commssion
472 W. Washigton St.
Boise, Idaho 83720
Re: Case No. UWI-W-09-01
General Rate Case Fil
Dear Ms. Jewell:
Enclosed for fig, please fid an orial and thee (3) copies of United Water Idaho's Sixth
Response to Commssion S~f~s First Pro~u~tion Request No.'s~25, 26(ÍJI 30, and 32. Also
enclosed are thee cd's contag the Exhbits. " - ~
Because of its volumous natue, only one (1) copy of the Response t Request N eds).s being
fied. Additional copies can be made avaible, if requied.
Kidly retu a fie staped copy to me.
Very Truy Yours,
McDevitt & Mier IL~L
#-;is iS i~ay~,o i
CONFIDENTAL .
Dean J. Mier
DJM/hh
End.
.
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]
joe~mcdevitt-miler.com
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Attorneys for United Water Idaho Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF) CASE NO. UW-W-09-01
UNITED WATER IDAHO INC., FOR )
AUTHORITY TO INCREASE ITS RATES AND ~
CHARGES FOR WATER SERVICE IN THE ) ATTORNEY CERTIFICATIONSTATE OF IDAHO )
)
Pursuat to RP 233, the undersigned certifies that the material accompanying the atthed
Response to Staffs Production Request No. 28, contans information that is a trade secret and
confdential in natue and is exempt from public inspection, examination or copying.
DATED ths ~day of November, 2009.
:~WQDAH,O me.em J. Miler
McDevitt & Miler LLP
420 West Banock
Boise, Idaho 83702
P: 208.343.7500
F: 208.336.6912
Attorney for United Water Idaho Inc.
ATTORNEY CERTIFICATION-l
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]
joe~mcdevitt-mi1er.com
f~ ir. \6
1U~9t\Q~ -4
Attorneys for United Water Idaho Inc.
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 FOR WATER SERVICE IN THE )STATE OF IDAHO )
)
CASE NO. UW-W-09-01
UNTED WATER IDAHO INC'S
SIXTH RESPONSE TO
COMMSSION STAFF'S FIRST
PRODUCTION REQUEST
United Water Idao Inc, ("United Water") by and through its undersigned attorneys,
hereby submits its Sixth Response to the Commission Stafs First Production Request N~
...."'_........,..,.~-25, 2~ 30, and 32.~. -,-"
"",,,.-'"
'/'DATED ths ~day of November, 2009.
."...".""..'
/,c./tJ~ITED WATER IDAHO INC.
BY~~~'
ean J. Miler
McDevitt & Miler LLP
420 West Banock
Boise, Idaho 83702
P: 208.343.7500
F: 208.336.6912
Attorney for United Water
UNITED WATER IDAHO INC'S SIXTH RESPONSE TO COMMISSION STAFF'S FIRST
PRODUCTION REQUESTS- 1
CERTIFICATE OF SERVICE
I hereby certify that on the ~ day of November, 2009, I caused to be served, via the
method(s) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secretar
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
jjewell~puc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
bmpurdy($otmail.com
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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UNITED WATER IDAHO INC'S SIXm RESPONSE TO COMMISSION STAFF'S FIRST
PRODUCTION REQUESTS- 2
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
lSECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Charles E. Loy
REQUEST NO. 25:
Similar to what occured in 1989, where aparent 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 futue
customer growt and usage in the test year?
RESPONSE NO. 25:
The Company has not performed any significant customer reclassifications since the last rate
case.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
PreparerlSponsoring Witness: Charles E. Loy
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
growt and usage. Please provide the corresponding analysis in electronic executable format.
RESPONSE NO. 26:
The Company made no acquisitions during the test year or in the recent past. There were two
small non-contiguous system divestitues in the recent past. The first (UWI-W-07-05) was
closed on Janua 11, 2008, which is outside of the test year. The second (UWI- W -08-02) was
closed on October 28, 2008, which is parially in the test year. However, because the customer
growt adjustment anualizes the test year end customers, the revenue impacts of
both
divestitues are removed from the test year revenues.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: James Linn
REQUEST NO. 30:
Please provide a detailed description of all tax positions held by the Company that are reflected
in its ta retus.
RESPONSE NO. 30:
The Company did not take any uncertin tax positions within its Federal or Idaho State income
tax retus for 2006,2007, and 2008 tax years. All tax positions taen in the return are highly
certain positions as allowed by law under Subtitle A of the 1986 Internal Revenue Code (as
amended) and the Idaho Code, 1 947 (as amended), Title 63.
UNTED WATER IDAHO INC,
CASE UWI-W-09-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kevin Doherty
REQUEST NO. 32:
Staf has received the Company's response to Production Request No. 21 in which the Company
provided an electronic copy of the advance and refund spreadsheet maintaned 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 refund spreadsheet
maintained by the Company for the period from the time of the last general rate case to the
timefre (2009-2014) of the spreadsheet aleady provided.
RESPONSE NO. 32:
Please refer to the attached Excel fie for the requested inormation.