20091211UWI to Staff 160-167.pdf

McDevitt & Miller LLP
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[phone]
[phone] (Fax)
420 W. Bannock Street
P.O. Box 2564-83701
Boise, Idaho 83702
2009 DEC II PM 3: 0 IChas. F. McDevitt
¡(pean J. (Joe) Miler
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IDAHO
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December 11, 2009
1ïa Hand Delivery
Jean J ewell, 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 Staffs Seventh Production Request Nos. 160, 161, 162, 163, 164, 165, 166, and 167.
Kidly retu a fie staped copy to me.
Ver Truy Your,
cçwrDeaJ. Mier
DJM/hh
End
ORIGINAL
Dean J. Miler (ISB No. 1968)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
joe(imcdevitt-miler.com
eEI\'
2099 DEC 1 I PM 3: 02
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
UNTED WATER IDAHO INC'S
SECOND RESPONSE TO
COMMISSION STAFF'S
SEVENTH PRODUCTION
REQUESTS
United Water Idaho Inc, ("Unìted Water") by and through its undersigned attorneys,
hereby submits its Second Response to the Commission Staffs Seventh Production Request Nos.
160, 161, 162, 163, 164, 165, 166, and 167.. ~ ...
DATED this Kday of December, 2009.
UNITED WATER IDAHO INC.
BY.~UU~
D J. Miller
McDevitt & Miller LLP
420 West Banock
Boise, Idaho 83702
P: 208.343.7500
F: 208.336.6912
Attorney for United Water
UNITED WATER IDAHO INC'S SECOND RESPONSE TO COMMISSION STAFF'S SEVENTH
PRODUCTION REQUESTS. 1
CERTIFICATE OF SERVICE
I hereby certify that on theJJ day of December, 2009, I caused to be served, viafue
method(s) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secreta
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, ID 83720-0074
jjewell(ipuc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Brad M. P.urdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
bmpurdyßhotmail.com
"
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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UNITED WATER IDAHO INC'S SECOND RESPONSE TO COMMISSION STAFF'S SEVENTH
PRODUCTION REQUESTS. 2
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
SEVENTH. PRODUCTION REQUEST OF THE COMMSSION STAF
PreparerlSponsoring Witness: Scott Rhead
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 resPQnse the underlying supporting
documentation and calculations for all entres of actual and forecasted data. Please update this
response monthly up to and including December 31, 2009, actual and forecasted (if any) data.
RESPONSE. NO. 160:
Enclosed is an Excel fie titled "Prod Req#l60 SRExhibit 4 Update.xlsx" which reflects the
updates to Scott Rhead's Exhibit NO.4 with actual data though November 2009. The asset
management reports sumarizing the June though November 2009 actual data and the year-end
forecast, which provide the supporting inonnation for the Exhibit NO.4 update, are available for
Staff Auditor review at the Company offices durg nonnal business hours.
\.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 161:
Please update Scott Rhtads 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 serice
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 peceinber31, 20Q9, actual and forecasted (if any) data.
RESPONSE NO. 161:
Please see the Excel fie submitted in response to Request No. 160.
UNITED WATER IDAHO INC.
CASE UWI- W-09..0i
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsonng Witness: Scott Rheåd
REOUEST NO. 162:
Please provide the updated Exhibít No. 4 provided in response to the two previous requests in
Excel with formulas intact. Please update this response monthly up to and including 1)eeember
31,4009, actual and forecasted (if any) data.
RESPONSE NO. 162:
Please see the Excel fie submitted in response to Request No. 160.
¡,
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kevin Dohert
REQUEST NO. 163:
Please update the Exhbit No. 13, Schedule 4 Workpaper, pages 1-16 of 16 with actu data in
lieu of the forecasts/estimates for all months that actul data exists. Please provide the
underlying supporting documentation and calculations for all entres of actua data and forecasts.
Please update this response monthy up to and including December 31, 2009, actul and
forecasted (if any) data.
RESPONSE NO. 163:
Based on discussions between Commission Sta and United Water representatives, the Paries
have agreed that the updates requested by the above referenced Production Requests may be
provided afer the close of the calenda year December 31, 2009. United Water has agreed to
provide the requested updates not later than Januar 8, 2010.
UNTED WATER IDAHO INC.
CASE UWI-W-09-01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsorig Witness: Kevin Doherty
REQUEST NO. 164:
Please provide the updated workpapers provided in response to the previous request in Excel
with formulas intact.
RESPONSE NO. 164:
Based on discussions between Commission Sta and United Water representatives, the Paries
have agreed that the updtes requested by the above referenced Production Requests may be
provided afer the close of the calendar year December 31, 2009. United Water has agreed to
provide the requested updates not later than Janua 8, 2010.
UNTED WATER IDAHO INC.
CASE UWI-W-09-01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kevin Doherty
REQUEST NO. 165:
Please update the Exhbit No. 13, Schedule 10 Workpaper, page 1 of 1 with actu data in lieu of
the estimates for all month that actu data exists. Please provide the underlying supporting
documentation and calculations for all entres of actual data and forecasts. Please update this
response monthy up to and including December 31,2009, actu and forecasted (if any) data.
RESPONSE NO. 165:
Based on discussions between Commssion Sta and United Water representatives, the Paries
have agreed that the updates requested by the above referenced Production Requests may be
provided afer the close of the calendar year December 31,2009. United Water has agreed to
provide the requested updates not later than Janua 8, 2010.
UNTED WATER IDAHO INC.
CASE UW-W-09-0i
SEVENTH PRODUCTION REQUEST OF TH COMMISSION STAFF
Preparer/Sponsorig Witness: Kevin Doherty
REQUEST NO. 166:
Please provide the updated workpaper provided in response to the previous request in Excel with
formulas intact.
RESPONSE NO. 166:
Based on discussions between Commission Sta and United Water representatives, the Pares
have agreed that the updates requested by the above referenced Production Requests may be
provided afer the close of the calendar year December 31, 2009. United Water has agreed to
provide the requested updates not later than Janua 8, 2010.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsorig Witness: Kevin Doherty
REQUEST NO. 167:
Please provide Exhbit No. 13, Schedule 12 Workpapers, pages 1-2 of2 in Excel with formulas
intact.
RESPONSE NO. 167:
Based on discussions between Commssion Sta and United Water representatives, the Paries
have agreed that the updates requested by the above referenced Production Requests may be
provided afer the close of the calenda year December 31, 2009. United Water has agreed to
provide the requested updates not later than Januar 8, 2010.