20091125Staff 157-168 to UWI.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 1 8
BARNO. 3283
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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
)
)
) SEVENTH 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
WEDNESDAY, DECEMBER 16,2009.
SEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 NOVEMBER 25, 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 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 hearing if need be. Reference IDAPA
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. 157: Please explain how the United Water Idaho facilties shown in the
EnerNOC-Idaho Power Demand Response Program Sales and Services Agreement were selected
for the program.
REQUEST NO. 158: How many other United Water Idaho facilties might be eligible
for the EnerNOC-Idaho Power Demand Response Program? Please include an explanation of
why these facilties were not enrolled in the program, the number of eligible facilties expected to
be enrolled over the next three years, and the estimated monthly capacity nomination of each
eligible facility.
REQUEST NO. 159: In response to Production Request No. 83, the Company
ilustrates how the benefit of the EnerNOC Demand Response Program was estimated to
determine the Total Pro Forma Purchased Power Expense. Why were the "Energy Payments"
shown in section 3, par d of the agreement or the "True-Up Payment" shown in section 3, par e
of the agreement not included as a benefit of the program?
REQUEST NO. 160: Please update Scott Rhead's Exhibit NO.4 with actual cost data in
lieu of the forecasts for all months that actual data exists. Please include within your response
SEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 NOVEMBER 25, 2009
the underlying supporting documentation and calculations for all entries of actual and forecasted
data. Please update this response monthly up to and including December 31, 2009, actual and
forecasted (if any) data.
REQUEST NO. 161: Please update Scott Rhead's Exhibit NO.4 with the actual plant in
service date of all projects listed. If plant listed has not been placed in service, please provide the
current planed service date. Please include within your response the underlying supporting
documentation for the original and revised plant in service dates. Please update this response
monthly up to and including December 31, 2009, actual and forecasted (if any) data.
REQUEST NO. 162: Please provide the updated Exhibit NO.4 provided in response to
the two previous requests in Excel with formulas intact. Please update this response monthly up
to and including December 31,2009, actual and forecasted (if any) data.
REQUEST NO. 163: Please update the Exhibit No. 13, Schedule 4 Workpaper, pages
1 - 1 6 of l6 with actual data in lieu of the forecasts/estimates for all months that actual data exists.
Please provide the underlying supporting documentation and calculations for all entries of actual
data and forecasts. Please update this response monthly up to and including December 31,2009,
actual and forecasted (if any) data.
REQUEST NO. 164: Please provide the updated workpapers provided in response to
the previous request in Excel with formulas intact.
REQUEST NO. 165: Please update the Exhibit No. 13, Schedule 10 Workpaper, page 1
of 1 with actual data in lieu of the estimates for all months that actual data exists. Please provide
the underlying supporting documentation and calculations for all entries of actual data and
forecasts. Please update this response monthly up to and including December 31, 2009, actual
and forecasted (if any) data.
SEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 NOVEMBER 25, 2009
REQUEST NO. 166: Please provide the updated workpaper provided in response to the
previous request in Excel with formulas intact.
REQUEST NO. 167: Please provide Exhibit No. 13, Schedule 12 Workpapers, pages
1-2 of2 in Excel with formulas intact.
REQUEST NO. 168: Please provide all documentation supporting the need for the tan
painting costs proposed for recovery from customers within the case for the Ustick Reservoir,
Steelhead Reservoir, Crestline Reservoir, and Hilcrest Reservoir. Please include within your
response all estimates and actual costs associated with each project and the need for these
proposed activities to occur within the test year, fall 2009 and early 2010 as identified in WP
11.1.14.1- Tan Painting. Include within your response the date these activities were performed
and/or the most current date planed for these activities.
-1CSø
Dated at Boise, Idaho, this;. day of November.
~~a.~'?Kr A. Sasser ~
Deputy Attorney General
Technical Staff: Matt Elam157-159
Patricia Hars/160-168
i:umisc:prodreq/uwiw09.1 wsks prod req 7.doc
SEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 NOVEMBER 25,2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF NOVEMBER 2009,
SERVED THE FOREGOING SEVENTH 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(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
Jo~SECRETARY ,
CERTIFICATE OF SERVICE