20091203Staff 169-183 to UWI.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
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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
)
)
) EIGHTH 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
THURSDAY, DECEMBER 24,2009.
EIGHTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 DECEMBER 3, 2009
This Production Request is to be considered as continuing, and United Water is requested
to provide, by way of supplementa 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 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. 169: Please calculate the change to the Company's fied revenue
requirement that occurs as a result of the updates to actuals for Plant in Service requested in
Production Request Nos. 160 to 166. Please identify and include within your response all
amounts that would change as a result of updating Plant in Service forecasts to actuals. If an
amount such as taxes (deferrals or expenses) does not change, please provide a detailed
explanation as to why the amount would not change as a result of updating Plant in Service
forecasts to actuals.
REQUEST NO. 170: Please provide all workpapers and underlying documentation
supporting the Company's response to the preceding request.
REQUEST NO. 171: Please provide the fies in Excel format with formulas intact for
all items in response to the preceding two requests.
REQUEST NO. 172: Please prepare Adjustment 1 (Exhibit 11, Schedule 1, Adjustment
1: Adjustment to Payroll Chargeable to Operations and Maintenance) based on pay rates and
employee counts as of December 31, 2009. Include the pro forma workpapers 11.1.1, 11.1.2,
EIGHTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 DECEMBER 3, 2009
11.1.3. If there are any other adjustments affected by this adjustment, please include those
affected adjustments and workpapers with this response.
REQUEST NO. 173: Please provide the United Water Idaho specific parameters for the
Short Term Incentive Plan (STIP). Please separate out the objectives into financial and personal
objectives. Please provide any and all criteria upon which the incentive and bonus plans are
based. Please break out each objective or criteria by its percentage weight.
REQUEST NO. 174: Please provide the United Water Idaho specific parameters for the
Bargaining Unit Incentive Plan. Please separate out the objectives into financial and personal
objectives. Please provide any and all criteria upon which the incentive and bonus plans are
based. Please break out each objective or criteria by its percentage weight.
REQUEST NO. 175: Please provide the United Water Idaho specific parameters for the
Non-Exempt Bonus Plan. Please separate out the objectives into financial and personal
objectives. Please provide any and all criteria upon which the incentive and bonus plans are
based. Please break out each objective or criteria by its percentage weight.
REQUEST NO. 176: When are each of the bonus or incentive plans paid? Please break
down the response by each plan type.
REQUEST NO. 177: What is the time period that each incentive or bonus plan covers?
Please break down the response by each plan tye.
REQUEST NO. 178: What is the amount of bonus or incentive plan that is included in
the test year (June 1, 2008 through May 31, 2009)? Please break down the response by each plan
type.
EIGHTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 DECEMBER 3, 2009
REQUEST NO. 179: What is the amount of bonus or incentive plan that is included in
the Pro Forma Adjustment 1 outside of the test year? Please break down the response by each
plan type.
REQUEST NO. 180: Please provide details on futue milestones and goals for
individual conservation programs; include both supply side programs and customer demand side
programs.
REQUEST NO. 181: In a preliminar review the spreadsheet provided in response to
Production Request No. 136 regarding the United Water Shares program indicates that some
customers may have been provided more than the $50.00 maximum. Please provide complete
financial detail on the United Water Shares program on a monthly basis for the years 2006-
2009 to date in an electronically executable format with formulas intact. Please provide fuher
explanation of the program details including: how customer contributions were distributed
among recipients, maximum amount of benefits, any changes to the program since initiated and
when the change was initiated.
REQUEST NO. 182: Please provide a sample copy of a bil for those legacy customers
for which the Company stil collects the Leakguard fee. Provide additional detail regarding the
number of customers being biled for Leakguard, how those transactions and the monies
collected are handled, and how the Company processes the accounts.
REQUEST NO. 183: Please provide the total number of conservation kits distributed in
2006 through United Water Shares and EI-Ada.
EIGHTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 DECEMBER 3, 2009
/Î RADated at Boise, Idaho, this ~- day of December.
iit;~ a £"AYiKri ne A. Sasser
Deputy Attorney General
Technical Staff: Patricia Hars/169-171
Kathy Stockton/172-179
Chris Hecht/180-183
i:umisc:prodreqluwiw09. Iwsks prod req 8.doc
EIGHTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 5 DECEMBER 3,2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF DECEMBER 2009,
SERVED THE FOREGOING EIGHTH 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
HARRINGTON 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
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmail.com
Jaø/b-
SECRET Y
CERTIFICATE OF SERVICE