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Home My WebLink About20091127UWI to Staff 120-122, 126-127, etc.pdfMcDevitt & Miller LLP Lawyers RECE. r:¡'i ?nM llQV 25 PM 2: 55fJJU:i ii Chas. F. McDevitt j p~an). (Joe) Miler :3 ~3t;~) 1"\ (208) 343-7500 (208) 336-6912 (Fax) 420 W. Bannock Street P.O. Box 2564-83701 Boise, Idaho 83702 November 25, 2009 Via Hand Delivery Jean Jewell, Secreta Idaho Public Utities Commssion 472 W. Washigton St. Boise, Idaho 83720 Re: Case No. UWI-W-09-01 General Rate Case Filng Dear Ms. Jewell: Enclosed for fig, please fid thee (3) copies of United Water Idaho's First Response to Commssion Staff's Fifth Production Request Nos. 120-122, 126, 127, 129-133, 135-137, 139, 142-144, and 146. Kidly retu a fie staped copy to me. Very Truy Yours, McDevitt & Mier U. ~ li Dean J. Mier DJM/hh End. Dean J. Miler (ISB No. 1968) McDEVITT & MILLER LLP 420 West Banock Street P.O. Box 2564-83701 Boise, Idaho 83702 Tel: 208-343-7500 Fax: 208-336-6912 joe(imcdevitt -miler .com ",""-C'" i"RJ=.,t i6ßq NOV 25 Pr' 2: 55 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. UWI-W-09-01 UNITED WATER IDAHO INC'S FIRST RESPONSE TO COMMISSION STAFF'S FIFTH PRODUCTION REQUESTS United Water Idaho Inc, ("United Water") by and through its undersigned attorneys, hereby submits its First Response to the Commission Staffs Fifth Production Request Nos. 120-122, 126, 127, 129-133, 135-137, 139, 142-144, and 146. DATED this 1.~ day of November, 2009. UNITED WATER IDAHO INC. BY:~~ Dean 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 FIRST RESPONSE TO COMMISSION STAFF'S FIFTH PRODUCTION REQUESTS- 1 CERTIFICATE OF SERVICE I hereby certify that on the ~y of November, 2009, I caused to be served, via the methodes) indicated below, true ana correct copies of the foregoing document, upon: Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, ID 83720-0074 j j ewell(ipuc. 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(ihotmail.com Hand Delivered U.S. Mail Fax Fed. Express Email (-- ~-- ~-- ~-- ~--~-- ~-- ~-- UNITED WATER IDAHO INC'S FIRST RESPONSE TO COMMISSION STAFF'S FIFTH PRODUCTION REQUESTS- 2 UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer: J arila Cary Sponsoring Witness: Charles E. Loy REQUEST NO. 120: Please provide a summary of test year revenues biled under Schedule No.5, Miscellaneous Fees and Charges for each ofthe following: 1. Return 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 Constrction Please provide your answer in a format similar to the following: Date Number of checks, charges, rentals, etc.Total Revenue June 2008 #$ May 2009 Totals #. # .$ $ RESPONSE NO. 120: The summar oftest year revenues billed under Schedule No.5, Miscellaneous Fees and Charges as requested above is attached and is also enclosed in the Excel file titled "Prod.Req #120 Misc Fees Charges.xlsx". K:\Rate Case 2009\Accounting\Req #120 Misc Fees Charges.xlsx UNITED WATER IDAHO Production Request #120 Rate Case Description Total # Total Revenue GIL Amount Jun-08 RETURN CHECK CHARGE 33 $660.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 49 $980.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)32 $960.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BillED TO ACCOUNT 77 $1,540.00 FIELD COLLECTION TRIP CHARGE 45 $675.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 11 $275.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 43 $12,629.95 Jun 08 Total 290 $17,719.95 Jul-08 RETURN CHECK CHARGE 23 $460.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 34 $680.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)21 $630.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 63 $1,260.00 FIELD COLLECTION TRIP CHARGE 42 $630.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 15 $375.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 71 $20,144.92 Jul 08 Total 269 $24,179.92 Aug-08 RETURN CHECK CHARGE 33 $660.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 56 $1,120.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)30 $900.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 101 $2,020.00 FIELD COLLECTION TRIP CHARGE 72 $1,080.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 20 $500.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 51 $21,728.10 Aug 08 Total 363 $28,008.10 Sep-08 RETURN CHECK CHARGE 38 $760.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 34 $680.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)30 $900.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 80 $1,600.00 FIELD COLLECTION TRIP CHARGE 41 $615.00 SERVICE CONNECTION CHARGE. FOR OTHER THAN NORMAL BUSINESS HOURS 12 $300.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 70 $17,980.09 Sep 08 Total 305 $22,835.09 Oct-08 RETURN CHECK CHARGE 41 $820.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 54 $1,080.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)39 $1,170.00 Summary Page 1 K:\Rate Case 2oo9\Accounting\Req #120 Misc Fees Charges.xlsx UNITED WATER IDAHO Production Request #120 Rate Case Description Total # Total Revenue GIL Amount RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 101 $2,030.00 FIELD COLLECTION TRIP CHARGE 44 $660.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 15 $375.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 46 $19,674.58 Oet08 Total 340 $25,809.58 Nov-08 RETURN CHECK CHARGE 42 $840.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 30 $600.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)16 $480.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 88 $1,760.00 FIELD COLLECTION TRIP CHARGE 47 $705.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 5 $125.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 63 $12,114.66 Nov 08 Total 291 $16,624.66 Dec-08 RETURN CHECK CHARGE 34 $680.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 23 $460.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)9 $270.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 64 $1,305.00 FIELD COLLECTION TRIP CHARGE 26 $390.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 5 $125.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 31 $5,340.18 Dec 08 Total 192 $8,570.18 Jan-09 RETURN CHECK CHARGE 42 $840.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 23 $460.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)8 $240.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 33 $665.00 FIELD COLLECTION TRIP CHARGE 22 $330.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 2 $50.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 46 $6,181.18 Jan 09 Total 176 $8,766.18 Feb-09 RETURN CHECK CHARGE 37 $740.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 37 $740.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)17 $510.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 92 $1,840.00 FIELD COLLECTION TRIP CHARGE 58 $870.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 6 $150.00 Summary Page 2 K:\Rate Case 2009\Accounting\Req #120 Misc Fees Charges.xlsx UNITED WATER IDAHO Production Request #120 Rate Case Description Total # Total Revenue GIL Amount TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 22 $2,154.12 Feb 09 Total 269 $7,004.12 Mar-09 RETURN CHECK CHARGE 28 $560.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 27 $540.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)14 $420.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 68 $1,370.00 FIELD COLLECTION TRIP CHARGE 53 $795.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 10 $250.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 43 $5,482.82 Mar 09 Total 243 $9,417.82 Apr-09 RETURN CHECK CHARGE 25 $500.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 44 $880.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)20 $600.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 93 $1,890.00 FIELD COLLECTION TRIP CHARGE 56 $840.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 1 $25.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 15 $1,686.60 Apr 09 Total 254 $6,421.60 May-09 RETURN CHECK CHARGE 28 $560.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION 26 $520.00 RECONNECTION CHARGE FOR NONPAYMENT TERMINATION (AFTER HOURS)5 $150.00 RECONNECTION CHARGE/TRIP FEES/NEW SERV AFTER HOURS BILLED TO ACCOUNT 75 $1,390.00 FIELD COLLECTION TRIP CHARGE 29 $435.00 SERVICE CONNECTION CHARGE FOR OTHER THAN NORMAL BUSINESS HOURS 5 $125.00 TEMPORARY DISCONNECTION AT CUSTOMER REQUEST CHARGE 0 $ METER TEST AT CUSTOMER REQUEST CHARGE 0 $ METER RENTAL CHARGE FOR CONSTRUCTION 47 $8,956.70 May 09 Total 215 $12,136.70 $ 187,493.90 Summary Page 3 UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer: J armila Car Sponsoring Witness: Charles E. Loy 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 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 fies. RESPONSE NO. 121: The total revenues identified in Request No. 120 tie in exactly with the total of the "Miscellaneous Service" and "Rents from Water Property" revenues shown on lines 5 and 6 of Loy's Exhibit No. 12 Schedule 1. The $13,700 of "Rents from Water Property" is comprised of the $25.00 Meter Service Fee times the 548 Meter Rental Charges for Construction ($25 x 548 = $13,700) which are listed in the response to Production Request No. 120, and the revenue is included in the revenue for Meter Rental Charge for Construction in that Response. ~ UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer: J arila Cary Sponsoring Witness: Charles E. Loy 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 I? If so, please show or explain how bulk hydrant metered sales revenues have been included. RESPONSE NO. 122: A table showing bulk hydrant metered sales for the test year is attached and also enclosed as Excel file titled "Prod Req #122 Bulk Hydrant Meter Sales.xlsx". These charges are also detailed out as requested in response to Request No. 120. ~ ÌI United Water Idaho Production Request #122 Bulk Hydrant Meter Sales I Meter Rental Charge for Construction (also included in Request #120) # of Rentals 40200 Mise Revenue 40205 $25 Permit Fee TOTAL Jun-oS 43 $(11,554.95 $1,075.00 $12,629.95) Jul-OS 71 $(18,369.92 $1,775.00 $20,144.92) Aug-OS 51 $(20,453.10 $1,275.00 $21,728.10) Sep-oS 70 $16,230.09 $1,750.00 $17,980.09) Oct-oS 46 $18,524.58)$1,150.00 $(19,674.58) Nov-OS 63 $10,539.66)$1,575.00 $(12,114.66 Dec-oS 31 $4,565.18)$(775.00 $(5,340.18 Jan-09 46 $5,031.18 $(1,150.00 $(6,181.18 Feb-09 22 $1,604.12 $(550.00 $2,154.12 Mar-09 43 $4,407.82 $(1,075.00 $5,482.82 Apr-09 15 $1,311.60 $(375.00 $1,686.60 Mav-09 47 $7,781.70 $(1,175.00 $8,956.70 548.00 $(120,373.90'$(13,700.00)$(134,073.90) UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 126: Please provide one of each and every kit, device or other physical item provided to customers for water conservation purposes durng 2007,2008 and 2009. Please include within your response all items referenced in Greg Wyatt's testimony. RESPONSE NO. 126: The kit, device or other physical items that have been provided to customers for water conservation puroses during 2007,2008, and 2009 are listed below. They are available for inspection at the Company's offices during regular business hours. Indoor/outdoor water conservation kits were made available durng 2007,2008, and 2009 Trigger shut offvalves were made available during 2007,2008, and 2009 Hose timers were made available during 2007, 2008, and 2009 Rain sensors (shut-off device) were made available during 2008, and 2009 Low flow spray nozzles for commercial kitchens were made available beginning in 2009 UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 127: Please describe in detail any planned brochures, kits, devices or other physical items curently planed for but not yet distrbuted 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 distrbutions. RESPONSE NO. 127: In answering this Request, United Water Idaho assumes the Request is with regard to conservation. For 2010, the Company plans to make available to customers the same kits and devices as described in its response to Request No. 126, as these devices are par ofthe Company's Commission approved Conservation Plan. Conservation kits and devices are available to customers upon request year round. The Company plans to make conservation information materials available to customers in 2010, such as the Anual conservation Guide, and bil insert. These 2010 information pieces are not yet designed. The 2010 information pieces would be targeted for distrbution to customers using similar methods as in the past durng the late spring and early summer of2010. The Company also intends to enhance its messaging and coupons for conservation devices via its website in 2010, but exact plans have not yet been developed. UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 129: When explaining why the Budget Bill 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 will enroll. Please provide the corresponding analysis in electronic executable format. RESPONSE NO. 129: United Water Idaho believes there is significant customer demand for a Budget Bill plan because ofthe fact that the single largest type of customer request the Company receives into its customer service call center is customers requesting payment arrangements. Customers who establish payment arrangements with the Company are essentially being placed on a type of Budget Bil plan, and thus we perceive this as a significant customer requested option. The Company estimated that 10% of its residential customers would enroll in a Budget bill plan if it were made available based on the frequency of customer requests for payment arrangements. There is no electronic executable analysis deriving the 10% estimate. ~..'I UNITED WATER IDAHO INC. CASE UW-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt 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. RESPONSE NO. 130: The monthly history of accounts receivables for the years 2006, 2007, 2008 and 2009 to date is attached and also enclosed as an Excel fie titled "Prod Req #130 Response.xlsx". .,.. 00 \D ,.,.00 O'..00 \D 00 l/,.m m 00 \D 0 ..0 00 0 00 ..\D\D l/\D m ..N 0 \D O'..\D 00 ~I O'-00-.D Ñ V)rr N-00-al ..-m-oo00O'00 N ,...O'..00 ..O'........V)m ..N ....0V)V)V)V)V)V)V)Ñ N-N-V)V)V) 00 0 l/..0 0 l/0 l/O'0 ,.O'\D 00 N \D 00 ..N N 00 \D NNl/..m 00 N \D 00 00 ,.l/.. ~I iñ \D-00-iñ ..-l/-0-00 rr N-al l/-l/N O'N 00 00 00 \D 00 l/\D ......V)....V)N N ..O'00 qV) V)V)V)V)V)V)N-N-mV)V) V) 00 O',.0 O'O'O'00 ,.00 \D 00 O'00 ,.00l/N N l/00 0 O'00 00 m N O'\D \D l/..N 0 N N 0 ,.,.00 m ,.0 \D O',.O'\D gi rr ..-Ò\D-..-..-00 ..-00-N-O'-,.-0-iñ ,.-o-N N 00 l/\D ..m O'00 m ..00 ..,.m O'....V) V)......V)N N N ..0 "'0 ..V)V)V) V)V)V)V)V)V)00-m 00-00-V)V) V)V) O'0 ..0 l/00 0 00 00 00 ..00 00 ..O'00000m,...O'\D 00 0 m O'..,.N N m0\D \D_00 ..-00 \D_\D N ..N ..0 00 O'00 ~..-,.-N al l/00-N 00 .D N-iñ 00 l/-O'-iñ 00-0 0 \D 00 00 \D \D 00 00 ,.N O'00 ,.m l/....V) V)V) V) V) V)......V)00 00_\D \DV)V)V) V)V)00-00 00-00-V) V)V)V) l/..O',.,.0 m l/N ..N N \D N \D 00000ml/l/\D ,.\D m ,...N \D l/,.00 '"""0 ..00 m 00_l/,.00 O'O'N 0 ,. ~.D ,.O'..-0-..-00-0 \D-00-m-..-,.-,.-\D-\D-00 00 00 00 l/00 \D 00 m N ..00 m ..m NV) V) V) V)V) V) V) V)......V)00 N_\D O'V)V)V)m-00 00-m-V) V)V)V) l/0 ,.00 ..0 \D \D \D 0 m 0 00 0 l/m000mO'O'..0 ..O'O'00 ..,.O'\D 00000'"m.m '"O'_....\D ..l/..,.l/\D ~I 00-O'-l/0 rr ,.00 .D 00 .D 00-.D 00-,.-00-l/-O'00 l/l/m m N N N N 00 ,.0 \D l/NV) V) V) V)V) V) V) V)....V) V)N 00 ..0V)V)rr N-00-rrV)V)V)V)..m ..\D l/..l/m \D 00 \D O'\D ..m 000O'N ,...00 0 00 l/,.N ..m 00 N 0N\D O'00 0 m ,.-O'N 0 \D 00 N 00 00 N ~I .,..-..-..O'-00-\D ..-m-\D-00-m-N-00-N-O'-O'00 l/00 m m N m m ..,.,.0 ..N ,.V) V)V)V)V)V)V) V)....V)V)00 l/q NV) V)N-N-m N-V)V)V) V) 00 0 00 00 l/l/m 0 O'l/..00 0 ..m 0000NNO'00 00 0 m \D 0 m N O'0 l/O'00 N m.O'....q ,.0 00 m.,.O',...00 ~iñ o-m m-,.-..-N 00 rr ..-l/N-00-00-..-\D-o O'l/l/N m m N m N 00 00 l/l/N N..V) V) V)V) V) V) V)....V) V)l/~\D mV)V)V)..-....-..-V)V) V)V)0 ..\D 00 0 00 m ..0 l/O'O'\D ,.O'O',.O'l/m 0 00 O'0 ,.,.00 m O'00 0 ,.,.l/\D_o O'_\D ,.0 \D N 00 0 O'\D \D 0 ~..0-O',.-0 ..-m-N-N-N-rr al 0-\D-00 00-..0 l/l/00 m m m l/m O'00 ..l/O'm....V) V)V) V) V) V).... V)V)00 l/\D mV) V)V)V)..-..-..-..-V)V)V)V) l/N m \D 00 ,.0 l/O'O'm ..O'O'm 000\D \D ..l/00 ..00 m 00 ,.0 ,.l/00 ..l/00 m ..m m.,.""O'00 0 m N l/O'\D ~I m-oo-N-al ,.-,.o-N 0-l/-m-..-00-00-Ò \D-m N 00 \D N N N m \D l/0 0 m ..\D \D....V) V)V) V) V) V)........m.l/m ..V)V)V)V)V) V)....-..-..-V) V)V)V) 0 N \D l/l/l/00 m l/,.00 00 00 0 N \DmO',.m O'm 0 ,.N N 00 0 ,.m \D l/0 \D ..m N m ..00 m 0 N N 0 \D N 00 ~I 0-00-00-00-m-0-al N-m-iñ m-,.-.D 00 00-l/-0 ..N 0 00 \D 00 m 00 ,.,.m N 0 0 mNN....V) V)V)V)N N ....\D O'00 \DenV) V)V) V)V)V)V)V)..-..-..-..-00 V)V)V)V)N..00 00 00 O',.m ..l/....l/00 \D ..m 00u00\D 0 ,.l/,.00 ,.0 00 00 l/..l/O'N0..00 m N ..O'\D_o m 00 O'm 0 o_N \D i ~I ,.-N-,.-00 iñ 0-00 00-N-m-iñ .D 00-N Ò ..ID m 00 l/m \D ,.00 \D 0 ..0 0 00 ..,.\D0NN....V) V) V) V)m m N N ~,.-\D_\D0V)V)V)V)V) V) V) V)........-N V) V) V) V)~0..0 .!!m ~en co ,.ID en co ,.ID en co ..ID en co ..ID'"0 =I CI 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0:i 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0.c ..N N N N N N N N N N N N N N N NIIllII~CI ::::'ai..rr I CI CI u l l ..0:CIII0: ::c ll0;..0:"0 u C c:CI :::: ¡¡.."0 0ï:e u ..u t!:;0.c: 1 UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 131: In testimony Company witness Wyatt included a graph on page 19 showing anual 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 wil be an increase in 2009 of27%. Please provide a monthly history of bad debt expense for the same time frame in electronic executable format. RESPONSE NO. 131: A monthly history of bad debt expense for the years 2006,2007,2008 and 2009 to date is attached and also enclosed as an Excel fie titled "Prod Req #131 Response.xlsx". The file also shows how the $154,000 estimated wrte-off for 2009 was determined. United Water Idaho does not understand where the 27% increase stated above comes from, however, 2009 actual write- offs through October (less reserve adjustment and large account wrte-offs) stand at $142,560 as shown in the bad debt history. The twelve months to date wrte-offs (Nov 2008 - Oct 2009) less reserve adjustments and large acct write-offs, total $159,835, which shows that the 2009 estimate of$154,000 is actually too low. .. Un i t e d W a t e r I d a h o Pr o d u c t i o n R e q u e s t # 1 3 1 67 0 . B a d D e b t E x p e n s e To t a l Ja n Fe b Ma r Ai .M Ju n Ju l Ay ~ Oc t No v De c Ye a r 20 0 6 N e t W r i t e - o f f s $1 2 , 7 2 9 . 5 3 $2 5 , 2 5 0 . 0 5 $1 1 , 4 3 1 . 7 2 $5 , 1 1 9 . 6 8 $4 , 2 1 0 . 3 8 $7 , 3 9 0 . 1 1 ($ 6 , 1 2 7 . 0 1 ) $1 1 , 3 4 5 . 2 9 ($ 3 6 8 . 5 7 ) $1 0 , 7 7 6 . 7 7 ($ 6 3 3 . 0 7 ) $5 7 0 . 7 9 $8 1 , 6 9 5 . 6 7 20 0 7 N e t W r i t e - o f f s $2 3 , 8 5 3 . 9 6 $2 1 , 1 5 8 . 4 1 $1 8 , 0 3 7 . 9 8 $8 , 8 1 3 . 7 9 $6 , 2 5 7 . 4 9 $2 0 , 9 3 2 . 9 7 $6 , 3 2 2 . 2 8 $5 , 4 9 4 . 3 1 $5 , 7 5 9 . 5 8 $5 , 4 8 3 . 6 4 $3 , 8 3 2 . 2 9 $9 , 1 7 4 . 5 2 $1 3 5 , 1 2 1 . 2 2 Re s e r v e A d j u s t m e n t s $1 8 , 8 0 0 . 0 0 ($ 2 , 3 0 0 . 0 0 ) $1 6 , 5 0 0 . 0 0 Tr u e W r i t e - o f f s $2 3 , 8 5 3 . 9 6 $2 1 , 1 5 8 . 4 1 $1 8 , 0 3 7 . 9 8 $8 , 8 1 3 . 7 9 $6 , 2 5 7 . 4 9 $2 , 1 3 2 . 9 7 $6 , 3 2 2 . 2 8 $5 , 4 9 4 . 3 1 $5 , 7 5 9 . 5 8 $5 , 4 8 3 . 6 4 $6 , 1 3 2 . 2 9 $9 , 1 7 4 . 5 2 $1 1 8 , 6 2 1 . 2 2 20 0 8 N e t W r i t e - o f f s $1 9 , 5 2 4 . 2 2 $2 1 , 7 2 2 . 2 1 $1 8 , 3 3 5 . 7 4 $1 3 , 0 5 4 . 6 6 $4 , 4 2 4 . 0 3 $2 9 2 . 9 6 $6 2 4 . 7 1 $4 , 3 6 7 . 3 7 $2 , 5 0 1 . 3 6 $7 , 5 6 3 . 3 6 $9 , 7 1 1 . 9 7 ($ 5 , 2 0 0 . 1 1 ) $9 6 , 9 2 2 . 4 8 Re s e r v e A d j u s t m e n t s ($ 9 , 0 0 0 . 0 0 ) ($ 6 , 8 0 0 . 0 0 ) ( $ 1 5 , 8 0 0 . 0 0 ) Tr u e W r i t e - o f f s $1 9 , 5 2 4 . 2 2 $2 1 , 7 2 2 . 2 1 $1 8 , 3 3 5 . 7 4 $1 3 , 0 5 4 . 6 6 $4 , 4 2 4 . 0 3 $9 , 2 9 2 . 9 6 $6 2 4 . 7 1 $4 , 3 6 7 . 3 7 $2 , 5 0 1 . 3 6 $7 , 5 6 3 . 3 6 $9 , 7 1 1 . 9 7 $1 , 5 9 9 . 8 9 $1 1 2 , 7 2 2 . 4 8 20 0 9 N e t W r i t e - o f f s $2 6 , 2 6 7 . 9 1 $1 6 , 5 4 3 . 9 7 $4 2 , 7 2 3 . 9 2 $1 3 , 2 7 0 . 9 9 $1 8 , 9 1 8 . 3 9 $1 9 , 0 8 3 . 2 9 $7 , 7 8 7 . 4 5 $1 2 , 1 5 2 . 5 4 $6 , 6 7 5 . 2 1 $9 , 2 9 3 . 2 1 $1 7 2 , 7 1 6 . 8 8 Re s e r v e A d j u s t m e n t s ($ 1 0 0 . 0 0 ) ($ 1 0 0 . 0 0 ) Tr u e W r i t e - o f f s $2 6 , 2 6 7 . 9 1 $1 6 , 5 4 3 . 9 7 $4 2 , 7 2 3 . 9 2 $1 3 , 2 7 0 . 9 9 $1 8 , 9 1 8 . 3 9 $1 9 , 1 8 3 . 2 9 $7 , 7 8 7 . 4 5 $1 2 , 1 5 2 . 5 4 $6 , 6 7 5 . 2 1 $9 , 2 9 3 . 2 1 $1 7 2 , 8 1 6 . 8 8 La r g e a c c t b a n k r u p t c y ' s $2 2 , 9 4 8 . 0 0 $6 , 2 4 0 . 0 0 $1 , 0 6 9 . 0 0 $3 0 , 2 5 7 . 0 0 Ne t W r i t e - o f f s U s e d $2 6 , 2 6 7 . 9 1 $1 6 , 5 4 3 . 9 7 $1 9 , 7 7 5 . 9 2 $7 , 0 3 0 . 9 9 $1 7 , 8 4 9 . 3 9 $1 9 , 1 8 3 . 2 9 $7 , 7 8 7 . 4 5 $1 2 , 1 5 2 . 5 4 $6 , 6 7 5 . 2 1 $9 , 2 9 3 . 2 1 $1 4 2 , 5 5 9 . 8 8 No t e s : Ne t W r i t e - o f f s = g r o s s w r i t e - o f f s m i n u s c o l l e c t i o n s To e s t i m a t e 2 0 1 0 w r i t e - o f f s : - t o o k t h e l a s t 1 2 m o n t h s w r i t e - o f f s ( J u n e 2 0 0 8 - J u l y 2 0 0 9 ) $1 7 0 , 4 4 0 - s u b t r a c t l a r g e a c c t . b a n k r u p t c y ' s w r i t t e n o f f ($ 3 0 , 2 5 7 ) - A d d b a c k 1 / 2 o f t h e l a r g e a c c t b a n k r u p t c y ' s $1 5 , 1 2 9 20 1 0 E s t i m a t e d W r i t e - o f f s $1 5 5 , 3 1 2 ( u s e d $ 1 5 4 , 0 0 0 ) UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 132: Please provide the average seasonal variability 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. RESPONSE NO. 132: United Water Idaho has no data or calculations readily available nor does it routinely make any calculations that could be used to answer this Request. UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt 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. RESPONSE NO. 133: United Water Idaho has not performed any research that is responsive to this Request. UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 135: Please provide the number of water conservation kits distributed byUWI in the "United Water Shares" program for 2006, 2007, 2008 and 2009 to date. Please separate and identify the number of kits distrbuted through EI-Ada from those distributed by UWI directly to customers. RESPONSE NO. 135: United Water Idaho's low-income help program is named "UW Cares", and the Company assumes that it is the UW Cares program that this Production Request is concerned with. The numbers of water conservation kits distributed via the UW Cares program for 2006, 2007, 2008 and 2009 to date are as follows: 2006 - 63 kits 2007 - 25 kits 2008 - 35 kits 2009 to date - 40 kits All kits are provided by United Water Idaho to EL-ADA Community Action Parnership for distribution by EL-ADA to customers who receive assistance under the UW Cares program. These kits are not distributed by the Company directly to customers. ~ UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer: J arila Cary Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 136: Please provide an update on the "United Water Shares" program, including funding 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 administration. Please provide the corresponding analysis in electronic executable format on a monthly basis for the years 2006 - 2009 to date. RESPONSE NO. 136: United Water Idaho's low-income help program is named "UW Cares",. and the Company assumes that it is the UW Cares program that this Production Request is concerned with. An Excel file titled "Prod Req #136 UW Cares.xlsx" is enclosed that is responsive to this Request. A printout of the fie is also attached. , UNITED WATER IDAHO UWCARES Production Request #136 Funding to date by Customer $ awarded to # of Customers Payment to CAPAI - Company Contributions Customers Assisted Admin Fee January-06 $522.15 $360.00 $522.15 13 February-06 $324.33 $$324.33 13 March-06 $691.86 $50.00 $691.86 10 April-06 $421.00 $20.00 $421.00 4 May-06 $190.63 $$190.63 0 June-06 $147.90 $$147.90 4 $408.35 July-06 $417.10 $$417.10 7 August-06 $100.00 $20.00 $100.00 6 September-06 $516.89 $$516.89 11 October-06 $525.29 $$525.29 12 November-06 $798.62 $380.00 $798.62 13 December-06 $1,061.61 $302.00 $1,061.61 22 January-07 $1,007.18 $104.00 $1,007.18 22 February-07 $562.39 $375.00 $562.39 10 March-07 $444.88 $$444.88 9 April-07 $150.00 $20.00 $150.00 1 May-07 $193.72 $$193.72 3 June-07 $50.00 $$50.00 1 July-07 $90.32 $110.00 $90.32 5 August-07 $395.50 $342.16 $395.50 8 $141.23 September-07 $544.90 $65.00 $544.90 13 $423.95 October-07 $1,150.00 $$1,150.00 33 November-07 $1,532.64 $5.00 $1,532.64 23 December-07 $1,365.56 $37.00 $1,365.56 25 January-OS $1,285.67 $$1,285.67 26 February-OS $906.17 $$906.17 24 March-OS $1,195.32 $$1,195.32 16 April-OS $297.17 $$393.91 10 May-OS $393.91 $$297.17 8 June-OS $177.82 $$535.11 9 $442.18 July-OS $737.14 $220.39 $177.82 4 August-OS $515.11 $195.00 $737.14 14 september-OS $1,816.82 $102.00 $886.71 27 October-OS $886.71 $(13.00)$1,816.82 47 November-OS $2,368.73 $$2,368.73 51 $401.83 December-oS $3,034.62 $25.00 $3,034.62 0 January-09 $1,381.64 $$1,381.64 53 February-09 $2,061.96 $$2,061.96 27 March-09 $966.65 $$966.65 22 April-09 $1,315.01 $$1,315.01 19 May-09 $504.60 $$504.60 18 $415.29 June-09 $556.10 $$556.10 9 July-09 $506.06 $$506.06 24 August-09 $1,795.55 $$1,795.55 35 September-09 $1,291.71 $155.00 $1,291.71 32 October-09 $(1,669.27) $335.00 $1,540.28 64 Totals $35,549.67 $3,209.55 $3S,759.22 807 $2,232.S3 Note: Customer contributions were netted against Company expense in October 2009 UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 137: Please identify expenditures for each program by month and year for the years 2006 - 2009 for each ofthe four conservation programs authorized in Commission Order No. 29871. RESPONSE NO. 137: United Water Idaho does not understand the reference to Order No. 29871, which was the Final Order on Reconsideration in United Water's 2004 general rate case. That Order authorized preparation of a new conservation plan, but did not approve any specific programs. The expenditures for each program by month and year for the years 2007 - 2009 for each ofthe four conservation programs authorized in Commission Order No. 30305 are listed below. No expenditures were incurred in 2006 for the four conservation programs authorized by Commission Order No. 30305 because the Order wasn't issued until April of2007. Xeriscape Commercial Kitchen Low Hose Timer/Rain Sensor Demonstration Flow Trigger Shut-off Shut-off Garden Spray Nozzle 2007 Jul $9,380.60 Dec $14,905.30 2008 Jun $2,546.00 Oct $10,547.00 2009 Jul $10,644.70 $16,027.20 Aug $1,852.79 $10,500.00 $5,830.00 Sep $178.68 UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt 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 cared out? RESPONSE NO. 139: The coupon for the trigger shut-off valve and hose timer kits was again offered in the 2008 and 2009 Conservation Guides. A coupon for the rain sensor shut-off device was also offered in the 2008 and 2009 Guides. Additionally, customers have been able to, and can stil access the coupons by visiting the Company's offices, and via download from the Company's web site. UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 142: In response to Production Request 44, the Company states that it is piloting an outbound calling 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? RESPONSE NO. 142: The Televox software tracks the call completion and provides a daily report to the Company. The call results are also uploaded into the biling system as a call track note on the customers' "accounts. The report tells us: A person answered and pressed the key to transfer to the Western Union payment option. A person answered and hung up before the entire message played. A person answered and pressed the key indicating they were not the pary we were callng. A person answered and listened to the entire message. A person answered and asked for the message to be repeated. Message delivered to an answering machine. Called - no answer. Invalid phone number Out of order Phone busy UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt 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 ofthe customer's requests and actual disconnection of service? Please provide this information for 2006, 2007, 2008 and 2009 to date. RESPONSE NO. 143: The Company takes a closing meter reading and physically turns the meter valve offwhen a customer requests the account closed. The Company completes the service order on the day the customer requests it. UNITED WATER IDAHO INC. CASE UWI- W -09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 144: If a meter is left on between occupants, is a reading always taken again when a new tenant moves in? Ifnot, 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? Ifnot, please explain. RESPONSE NO. 144: When a customer calls to have the water service taken out of their name, a reading is taken and the water meter is turned off unless it is obvious there is another person moving into the property. In that case, the meter is left on for their convenience and a notice left for them to contact the offce. If the meter is left on in that scenaro, when the new tenant calls to open an account, the Company would star their service with the meter reading taken to close the previous account. The ending meter reading date on the final bil for the deparing customer is the actual date the meter was read and service was stopped. UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Gregory P. Wyatt 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. RESPONSE NO. 146: United Water Idaho does not handle customer calls for any other entities.