20091106Staff 80-119 to UWI.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
POBOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
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KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
POBOX 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
)
)
) FOURTH 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,
Krstine A. Sasser, Deputy Attorney General, requests that United Water Idaho (Company;
United Water; UWI) provide the following documents and information on or before FRIDAY,
NOVEMBER 27,2009.
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 NOVEMBER 6, 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 will 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. 80: Please provide executable electronic copies of all Test Year
Purchased Power Expenses used to generate the following Workpapers: WPI 1. 1.8.6 Boosters-
107, WPI 1.1.8.7 Boosters-109S, WPI 1.1.8.8 Wells-107, and WPI 1.1.8.9 Wells-109S.
REQUEST NO. 81: Similar to "WP12.4.4 Cust Counts", please provide executable
electronic copies of the customer count by month and class (i.e. - residential, commercial, public
authority, and misc.) for the period May 2009 through September 2009.
REQUEST NO. 82: Please provide executable electronic copies ofthe customer usages
by month and class (i.e. - residential, commercial, public authority, and misc.) for the period
Januar 2005 through September 2009. Please list separately the monthly usage of Micron for
the period January 2005 through September 2009.
REQUEST NO. 83: Please provide an explanation and all executable electronic
workpapers ilustrating how the "Benefit of Enernoc Demand Response Program" was estimated
to determine the Total Pro Forma Purchased Power Expense shown in Loy's Exhibit No. 11,
Schedule 1, page 8.
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 NOVEMBER 6, 2009
REQUEST NO. 84: For the Danskin system sale to the City of Kuna and the Belmont
Heights system sale to the City of Nampa, please provide the following for each system:
a. number of customers by month for the 24 months prior to the sale,
b. total monthly system consumption for the 24 months prior to the sale,
c. the date on which UW stopped billing customers.
REQUEST NO. 85: Please provide an organization chart showing Suez at the top and
all subsidiaries and affiliates. Please provide a chart and identify the percentage ownership of
each separately for 2007,2008 and 2009 to date. Please include within your response the
company Home Service which sends United Water mailings regarding customer premise water
and wastewater lines.
REQUEST NO. 86: Please provide a detailed narative description of all companies and
business unts identified in the previous char(s). Include with your response the
mission/purose of each company and business unit.
REQUEST NO. 87: Please provide a detailed description of any changes planed or
contemplated to the organizational strcture shown in the most recent organization chart
provided. Please include within your response the reason for the change, for example, if the
reason is to obtain greater efficiency please identify how the change will accomplish that and in
what specific area.
REQUEST NO. 88: Please provide a list of all financial transactions between each
affiiate and UWI for 2007, 2008 and 2009 to date sumarzed by year and affiiate. Staff is
aware that these transactions should be captured in the financial statements ofUWI. Please
provide in Excel pivot table format an extract from UWI's financial records separate for each
year. The table should include the category (AP Vouchers for example), line description,
affiliate number, grand total at the right for each line description and grand total for each affliate
number at the bottom.
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 NOVEMBER 6, 2009
REQUEST NO. 89: Please provide income statements and balance sheets for each
affliate for the year ending December 31, 2008, or the equivalent extracts for each affliate from
the general ledger system.
REQUEST NO. 90: Please provide a spreadsheet in Excel format with formulas
activated detailing United Waterworks Dividend/Capital Contrbutions (il Cash settlement) in
2008. Please see the following file from the 2006 general rate case for suggested format:
k:\2006 Rate Case\TJH Offcial Responses\Audit Req #2 Resp 16 to 63\(# 23 il cash
settlement.xls) Sheet 1.
REQUEST NO. 91: Please provide a separate schedule for each affiliate showing the
total number of customers, employees and revenues for 2007, 2008 and 2009 to date.
REQUEST NO. 92: Please provide the total number along with the title and duties of
each employee transferred to or from affiliates and UWI for 2007,2008 and 2009 to date, if any.
REQUEST NO. 93: Please provide a list ofthe inter-company loans/loan guarantees to
the utility from affliates and loans/loan guarantees from the utility to affliates for 2007, 2008
and 2009 to date, if any. Please provide descriptions and documentation related to these
including the terms and conditions for these loans/guarantees including interest rate and basis for
interest rate.
REQUEST NO. 94: Please provide a copy of all contracts, leases, or other arrangements
between UWI and any affiliate in operation during 2007, 2008 and 2009 to date.
REQUEST NO. 95: Please provide the details of all affliate receivables and payables
for 2007, 2008 and 2009 to date. Please include within your response the dollar amounts,
explanations of how receivable/payable was generated and calculation of the receivable/payable
amount. If this information has already been provided, please provide a complete reference.
FOURTH PRODUCTION REQUEST
TO UNTED WATER IDAHO 4 NOVEMBER 6, 2009
REQUEST NO. 96: Please provide a list of all asset transfers (tangible and intangible)
between the affliates and UWI from 2007,2008 and 2009 to date. Please include within your
response the pricing basis and related documentation for all transfers, purchases, and sales.
REQUEST NO. 97: Please provide a list of all customer information transferred
between affliates and UWI from 2007, 2008 and 2009 to date. Please include within your
response the pricing basis and related documentation for all transfers, purchases, and sales.
REQUEST NO. 98: Please provide a detailed description of all activities between any
company and/or business unit identified in the organization chart(s) provided and United Water
Idaho's customer base whether as a whole or in par.
REQUEST NO. 99: Please provide a detailed description of all activities by the
Company to protect its customers' information including addresses and ban account (or other)
payment information.
REQUEST NO. 100: Please provide a detailed description of the circumstances under
which the Company would provide customer information in any form to other companies.
Please include within your response the pricing parameters associated with each scenario.
REQUEST NO.1 01: Please provide a detailed description of all such circumstances
under which any customer information was provided to another company beginning with Home
Service to date. Please include within your response the name of the company, its relationship to
UWI, the type of customer information provided, the date such information was provided (if the
information is provided or updated anually, please include that within your response), the price
charged for such data, if any, and the method used to calculate the price charged (if there is no
charge, please so state and indicate in detail the underlying reason).
REQUEST NO. 102: Please identify how Suez, Home Service and United Water clearly
and expressly communicate in each and every mailing to United Water Idaho customers that the
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 5 NOVEMBER 6, 2009
service being offered and company providing it is not the customer's regulated utility. Please
include in your response an example of each mailing from Home Service to any United Water
Idaho customer and circle the statements clearly and explicitly communicating that information.
REQUEST NO. 103: Please describe in detail how United Water Idaho customers were
identified to receive mailings from Home Service. Please include within your response whether
a customer had to expressly opt in or opt out of mailings from related companies, an example of
each of the mailings including those options and the dates when United Water Idaho customers
were identified for Home Service mailings.
REQUEST NO. 104: Please provide the following information with Utility Business
Services, Inc. (UBS):
a. A detailed description of the arrangements.
b. The cost included within the general rate case.
c. How does that cost compare to other billing arangements including a
demonstration of its cost effectiveness for UWI compared to other possible
(including local) arangements.
REQUEST NO. 105: Please identify the timeline ofthe current contractual relationship
with UBS - when the contract was negotiated, the costs for other arangements at the time, and
any evaluation/preparation for contract adjustments given the past and curent economic
environment.
REQUEST NO.1 06: Please identify any changes, if any are contemplated, with the
Company's relationship with UBS.
REQUEST NO. 107: Please identify whether there have been any changes to the
Management and Services (M&S) agreement on file with the Idaho Public Utilities Commission
since the last general rate case (2006). Ifthe agreement is no longer in effect, please so state and
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 6 NOVEMBER 6, 2009
include within your response any agreements/arangements either in lieu of or in addition to the
M&S agreement.
REQUEST NO.1 08: Please provide a detailed description of any and all activities
between any company and/or business unt identified in the organization chart(s) and United
Water Idaho that are not identified specifically and explicitly within the M&S agreement on fie
with the Idaho Public Utilities Commission.
REQUEST NO. 109: Please provide a copy (or access to the presentations in Boise) of
all presentations made describing the relationship, activities, benefits and detriments of the M&S
Company and any other company to the United Water subsidiares durng 2007, 2008 and 2009
to date. Please include within your response any M&S Value Added Assessments.
REQUEST NO. 110: Please provide a copy (or access to the reports in Boise) of any
studies performed (internally or externally) that demonstrate the benefit of the M&S Company to
the United Water subsidiares. If none have been performed since 1997, please so state in your
response and provide access to the following reports - A Comprehensive Management Audit of
United Water New Jersey dated Januar 3, 1997, A Stratified Management and Operations Audit
of United Water Pennsylvania dated March 20, 1996, and Final Report of the General
Waterworks Corporation (Pennsylvana Operations) Comprehensive Management and
Operations Study, dated June 1988.
REQUEST NO. 111: Please describe the process by which the M&S Company charges
employee time to the various subsidiares. Please include within your response at a minimum the
process by which the M&S Company's Engineering Deparent determines how to charge
employee time to the varous UWI capital projects and whether that time is directly charged to
large projects, charged to projects in an overhead rate, some combination of the two, or in
another maner.
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 7 NOVEMBER 6, 2009
REQUEST NO. 112: To the extent not provided in response to the previous requests,
please provide a detailed list of all non-regulated activities UWI is engaged in that are not under
an affiiate structure.
REQUEST NO. 113: To the extent not provided in response to previous requests, please
identify any costs shared with other companes and the maner in which these costs are
calculated for 2007, 2008 and 2009 to date.
REQUEST NO. 114: To the extent not provided in response to previous requests, please
describe the financial reporting strctue of the United Water companies for 2007,2008 and
2009 to date. Please include within your response any changes planned or contemplated to that
structure.
REQUEST NO. 115: Please provide a list of affiliate companies and/or operations that
have been discontinued since 2007, if any, and how the costs associated with those discontinued
operations were handled. For example, were employees absorbed into the utility and if so, how
many employees, what was the associated dollar amount, when did it occur, and what is the
ongoing impact to the Company as a whole.
REQUEST NO. 116: Please reference WP 11. 1.12.1 Non Biling Postage.
a. Please provide an example of each notice sent via auto sort, Draper & Associates
(CCRs), and Non UBS Courer Service.
b. Please explain the reason for the varability (when it is extreme) in costs from
month to month.
REQUEST NO. 117: Please provide in an Excel file an extract from the Company's
general ledger system that lists all transactions posted to the Power Expense account number
50610 by month for the $1,510,530 "test year per books" amount listed on line 10 of Exhibit No.
11, Schedule 1, page 8 of22. Please include in the Excel fie, at a minimum, the category,
document number, line description, payee, amount paid/credited, and date posted for each
FOURTH PRODUCTION REQUEST
TO UNTED WATER IDAHO 8 NOVEMBER 6, 2009
transaction. Please create a pivot table from that detail that sumarzes the activity by month.
Staff is in receipt of the Company's monthly trial balances and will compare the monthly trial
balance totals with those contained in the Excel file prepared in response to this request.
REQUEST NO. 118: Please provide a schedule of rate case expenses incurred to date
for general rate Case No. UWI-W-09-1. Please include within your response an Excel file
containing an extract from the Company's accounting system that lists each transaction, the
document number, the account posted, the amount posted, the date posted, the line description.
Please update this response on a monthly basis.
REQUEST NO. 119: Please provide a copy of all invoices, contracts, agreements, and
the basis of estimates underlying rate case preliminary budget estimates included in Company
WP 11.1.20.1-Rate Case Costs. Please update this response on a monthly basis.
rl-
Dated at Boise, Idaho, this (p- day of November.
~ikl. a. ~tll
Krs . ne A. Sasser
Deputy Attorney General
Technical Staff: Matt Elam80-84
Patricia Hars/85-119
i:umisc:prodreq/uwiw09.1 wsks prod req 4.doc
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 9 NOVEMBER 6, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF NOVEMBER 2009,
SERVED THE FOREGOING FOURTH 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
HARRGTON 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
BRAD M. PURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmail.com
--FSECRETARY
CERTIFICATE OF SERVICE