20091113Staff 120-146 to UWI.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
nE""..í'\ _Lt:
2009 NOV I 3 PM 2: 02
KRSTINE 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
)
)
) FIFTH 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,
Kristine A. Sasser, Deputy Attorney General, requests that United Water Idaho (Company;
United Water; UWI) provide the following documents and information on or before
FRIDAY, DECEMBER 4, 2009.
FIFTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 NOVEMBER 13,2009
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 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. 120: Please provide a sumar of test year revenues biled under
Schedule No.5, Miscellaneous Fees and Charges for each of the following:
1. Retur Check Charge
2. Reconnection Charge for Nonpayment Terminations
3. Field Collection Trip Charge
4. Service Connection Charge for Other Than Normal Business Hours
5. Temporary Disconnection at Customer Request Charge
6. Meter Test at Customer Request Charge
7. Meter Rental Charge for Construction
Please provide your answer in a format similar to the following:
Date
June 2008
Number of checks, charges, rentals, etc.
#
Total Revenue
$
May 2009
Totals
ti
#
i
$
REQUEST NO. 121: Please reconcile the total revenues identified in Request No. 120
above with the "Miscellaneous Service" and "Rents from Water Property" revenues shown on
FIFTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 NOVEMBER 13,2009
lines 5 and 6 of Loy's Exhibit No. 12 Schedule 1. If the totals are different, please explain why
and provide the corresponding executable electronic files.
REQUEST NO. 122: Please provide a table showing bulk hydrant metered sales for the
test year. Please use a format similar to that shown above in Request No. 120. Are the bulk
hydrant metered sales shown in the table included in the total revenues shown on Loy's Exhibit
No. 12, Schedule 1? If so, please show or explain how bulk hydrant metered sales revenues have
been included.
REQUEST NO. 123: Referring to Rhead's Exhibit No.5, Purchased Water Expenses,
please identify those purchases wherein the quantity and/or cost have been estimated for the
2010 season and those for which the purchase has already been made or for which a contract has
already been signed. For those purchases that have yet to be executed, please provide an
estimate of when those purchases wil be made. For those purchases that have been estimated,
please discuss the basis for the estimated cost and quantity.
REQUEST NO. 124: Data provided in response to Staff Request No. 27 seems to
indicate a gradually decreasing total volume of purchased water from 2005 through 2009 and a
corresponding decrease in total purchased water costs. Please explain this downward trend. In
addition, please explain why UWI is requesting a pro forma purchased water expense that seems
counter to this trend.
REQUEST NO. 125: Please explain how UWI determines each year how much water to
rent from the Basin 63 Rental Pool and how much to lease from the State Water Ban.
Approximately when does UWI make this decision?
REQUEST NO. 126: Please provide one of each and every kit, device or other physical
item provided to customers for water conservation puroses durng 2007, 2008 and 2009. Please
include within your response all items referenced in Greg Wyatt's testimony.
FIFTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 NOVEMBER 13, 2009
REQUEST NO. 127: Please describe in detail any planned brochures, kits, devices or
other physical items currently planned for but not yet distributed to customers. Please include
within your response the timing of distribution(s), draft brochures, kits, devices or other physical
items underway, the status of the items, and the expected result from said distributions.
REQUEST NO. 128: Please provide all documentation pertaining to the Avimor
Special Facilities Agreement (SF A) including but not limited to:
a. An extract from the accounting system showing all transactions related to this SF A,
b. A copy of the original accounting transaction(s) recording the asset(s),
contribution(s), advance(s), and other accounts,
c. Copies of other accounting transactions and the relevant supporting documentation
upon request by on-site Staff,
d. A copy of all documentation demonstrating that transmission and distribution
facilities necessar to serve the new development were contributed by the developer
without refund,
e. A detailed description of the status of the development (including but not limited to
its phase, how many customers have connected, and how many refuds have
processed),
f. All relevant documentation supporting the statements included in response to item e.,
g. A detailed description of the water conservation measures currently in place for the
project either by UWI or the developer or any other pary,
h. All relevant documentation supporting the statements included in response to item g.,
and
1. Any and all documentation demonstrating that the Avimor project was recorded and
continues to be processed as intended by the Commission in Case No. UWI-W-07-1.
REQUEST NO. 129: When explaining why the Budget Bil plan for residential
customers is in the public's interest, the Company says it "believes that there is significant
customer demand for such an option." Explain why the Company believes this to be true, and
how, when determining the program cost, it estimated that 10% of its residential customers wil
enroll. Please provide the corresponding analysis in electronic executable format.
REQUEST NO. 130: In testimony Company witness Wyatt included a graph on page
19 showing accounts receivables over 90 days for the years 2006,2007,2008 and 2009. Please
provide a monthly history of accounts receivables for the years 2006, 2007, 2008 and 2009 to
date in electronic executable format.
FIFTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 NOVEMBER 13,2009
REQUEST NO. 131: In testimony Company witness Wyatt included a graph on page
19 showing annual net bad debt expense for the years 2006, 2007, 2008 and an estimate for
2009. Please provide a detailed explanation of why the Company estimates that there will be an
increase in 2009 of 27%. Please provide a monthly history of bad debt expense for the same
time frame in electronic executable format.
REQUEST NO. 132: Please provide the average seasonal variabilty of non-delinquent
customers and those delinquent over 90 days for the years 2006, 2007, 2008 and 2009 to date.
Please provide the corresponding analysis in electronic executable format.
REQUEST NO. 133: Please provide research the Company has completed to determine
that "residential customers understand and react to the price signal inherent in the seasonal rate
design" and that the "Budget Bil plan would not significantly dampen such a signaL." (Company
witness Wyatt, page 17) Please explain how the Company has isolated the rate design impact
from other demand-influencing factors. Please provide the corresponding analysis in electronic
executable format.
REQUEST NO. 134: Please assess and quantify the impact of United Water's water
conservation program on system peak hourly, system peak daily, and system annual consumption
for the years 2006, 2007, 2008 and 2009.
REQUEST NO. 135: Please provide the number of water conservation kits distributed
by UWI in the "United Water Shares" program for 2006,2007,2008 and 2009 to date. Please
separate and identify the number of kits distributed through El-Ada from those distributed by
UWI directly to customers.
REQUEST NO. 136: Please provide an update on the "United Water Shares" program,
including fuding to date by Company, customer contributions, total dollar amount awarded to
customers, total number of customers assisted, and total amount provided to CAP AI for
FIFTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 5 NOVEMBER 13, 2009
administration. Please provide the corresponding analysis in electronic executable format on a
monthly basis for the years 2006 - 2009 to date.
REQUEST NO. 137: Please identify expenditures for each program by month and year
for the years 2006 - 2009 for each of the four conservation programs authorized in Commission
Order No. 29871.
REQUEST NO. 138: Please identify the estimated water savings achieved in each year
for the years 2006-2009, by program, for each of the four conservation programs authorized in
Commission Order No. 29871.
REQUEST NO. 139: In his testimony, Company witness Wyatt indicated the Company
offered a coupon for trigger shut-off valve and hose timer kits in its 2007 conversation guide.
Does the Company stil make such an offer and if so how is it caried out?
REQUEST NO. 140: In his testimony, Company witness Wyatt mentioned that a total
of2,066 of the trigger shut-off valve and hose timer kits had been distributed. How many of
these devices have actually been installed?
REQUEST NO. 141: Has the Company completed studies to differentiate water
consumption declines associated with changes in usage habits vs. those savings attributable to
water saving devices? If yes, please explain how and provide the corresponding analysis in
electronic executable format. If not, explain why not.
REQUEST NO. 142: In response to Production Request 44, the Company states that it
is piloting an outbound callng system from Televox. Please explain further how the system
tracks completion of calls. How does it differentiate among calls where the customer answers,
an answering machine or voice mail records a message, or when there is no answer?
FIFTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 6 NOVEMBER 13, 2009
REQUEST NO. 143: Does the Company routinely physically disconnect service after a
customer requests closure of an account or disconnection of service? If so, what are the average
and maximum intervals between receipt of the customer's requests and actual disconnection of
service? Please provide this information for 2006, 2007, 2008 and 2009 to date.
REQUEST NO. 144: If a meter is left on between occupants, is a reading always taken
again when a new tenant moves in? If not, please explain how the Company determines whether
to read the meter. Does the ending meter reading date given on bils for the deparing customer
correspond to the actual date the meter was read? If not, please explain.
REQUEST NO. 145: In his testimony, Mr. Wyatt indicated the Company has two pilot
projects for automated metering systems. Please provide further information on these projects,
including original date of inception, ongoing results or determinations, comparisons with other
available systems, and cost benefit analysis, etc.
REQUEST NO. 146: Does United Water handle customer calls for other entities? If so,
what are those entities? Are the United Water complaint and inquiry calls tracked separately? If
so, please quantify calls by United Water complaints and inquiries and All Other entity calls.
Dated at Boise, Idaho, this J~ day of November.
ff~t;H' a. ~Q!\Kri ine A. Sasser
Deputy Attorney General
Technical Staff: Matt Elam/120-125
Patricia Hars/126-128
Chris Hecht/129-146
i:umisc:prodreqluwiw09. i wsksmephcwh prod req 5.doc
FIFTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 7 NOVEMBER 13,2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF NOVEMBER 2009,
SERVED THE FOREGOING FIFTH 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
HARRNGTON 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
BRAD M. PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(ihotmail.com
~~rÁ
SECRETA
CERTIFICATE OF SERVICE