20091218Staff 205-288 to UWI.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
RFCi= r:~"-- --
20U9 DEC l 8 PM 3: l 9
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
)
)
) TENTH PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) UNITED WATER IDAHO INC.
)
The Staff of the Idaho Public Utilities 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, JANUARY 8, 2010.
TENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 DECEMBER 18, 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 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. 205: In Response to Production Request No. 158, the Company says
"EnerNOC reduced the number of the Company's facilities enrolled in the Demand Response
Program and that they revised the Company's enrolled monthly capacity nomination downward to
1,548 kW for 2009 and the remaining years of the Program." Please explain why EnerNOC has
reduced the monthly capacity nomination and describe how they are able to do this within the
parameters of the original agreement. If a new agreement was initiated, please provide a copy with
an explanation of the changes.
REQUEST NO. 206: Similar to "WPI2.4.4 Cust Counts", please provide executable
electronic copies of the customer count by month and class (i. e. - residential, commercial, public
authority, and misc.) for the period October 2009 through December 2009.
REQUEST NO. 207: To the extent not previously provided, please provide access to all
books and records of the Company and its related companies.
REQUEST NO. 208: To the extent not previously provided, please provide access to all
personnel (whether employed by the Company or not) necessary to explain and/or support the
information referenced in the previous two production requests.
TENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 DECEMBER 18, 2009
REQUEST NO. 209: Please calculate the revenue requirement increase associated with the
rate base increase since the last general rate case referenced in Greg Wyatt's testimony and its
associated expenses. Please include within your response the electronic spreadsheet in Excel with
formulas activated that are the basis of the Company's response and any related documents and/or
fies.
REQUEST NO. 210: Please reference the Excel fie provided in parial response to Staffs
Production Request No. 160. Please identify, describe in detail and provide the detailed supporting
documentation explaining the $281,000 decrease in Contributions in Aid of Construction for
Developer Funded Extensions from that originally filed and subsequently updated and filed by the
Company on December 11, 2009 when the Developer Funded Extensions increased by
approximately $56,000.
REQUEST NO. 211: Please provide the electronic spreadsheets in Excel format that are
the basis of the Pro Forma Tax Depreciation on Exhibit No. 11, Schedule 4, page 1 of2, line 17.
Please include within your response the tax depreciation rates.
REQUEST NO. 212: Please provide an updated debt schedule, Doherty Exhibit No.7,
page 2 of 2, Composite Cost Rate of Debt through December 31, 2009. Please include within your
response the electronic spreadsheets with formulas intact that are the basis of the response and any
other related documents and/or fies.
REQUEST NO. 213: In response to Staff Production Request No.1, the Company has
provided the electronic spreadsheet that calculates the Deferred AFUDC Equity Income on Doherty
Exhibit No. 13, Schedule 10, line 21. Please provide the documentation, accounting or other data
extracts that were the basis of the amounts included on that electronic spreadsheet tab entitled
AFUDC Equity WP.
TENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 DECEMBER 18, 2009
REQUEST NO. 214: Please provide a detailed description of all Operating and
Maintenance expenditures that were deferred, delayed, reduced or otherwise managed to minimize
costs as a cost reduction effort.
REQUEST NO. 215: Please explain actions taken by the Company to minimize the
financial impact on customers in the current depressed employment and economic climate. Please
include copies of any and all correspondence to employees, including but not limited to email
correspondence, letters, meeting minutes, and meeting handouts detailing cost cutting efforts
planned or already in place.
REQUEST NO. 216: Please provide a schedule showing the dollar amount of all vehicle
expenses included in the rate case application that pertain to personal use of vehicles. Please break
down the schedule by account number, and identify all costs that are added onto the actual
transportation costs pertaining to benefits such as payroll taxes, and other benefits based on payroll
such as pensions and 401 k expenses.
REQUEST NO. 217: Please provide a schedule showing the total dollar amount of vehicle
allowance expenses included in the rate case application. Please break down the schedule by
account number, and identify all costs that are added onto the actual transportation costs pertining
to benefits such as payroll taxes, and other benefits based on payroll such as pensions and 401k
expenses.
REQUEST NO. 218: From Exhibit 10, Column 2, Per Books 05/31/2009, please provide
the documentation and workpapers for these amounts. Include the account numbers and the dollar
amounts for Operating Revenues ($36,905,290), Ad Valorem ($1,370,595), State Income Taxes
($2,289,830), and Federal Income Taxes ($2,947).
REQUEST NO. 219: Please provide a schedule showing the direct benefit to Idaho
customers ofUWI's allocation of costs for the R&I Allance. Include a description of the benefit to
Idaho customers including the cost savings realized. Identify which expenses, by account number,
TENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 DECEMBER 18,2009
have been reduced, or what additional revenues, by account number, have been received to offset
customer costs as a result of the R&I Allance participation.
REQUEST NO. 220: What is the per customer cost for billng and collections? For
example, for each new customer, identify the biling and collection costs expected to be increased
(by X dollars per customer). Include the account numbers for all the biling and collection accounts
that pertain to a new customer.
REQUEST NO. 221: Please provide a schedule of the deferred power costs since the
inception of the deferral account as provided in Order No. 28505, Case No. UWI-W-OO-01. Provide
the schedule by month, and separately identify the monthly interest payments and underlying
calculations. Please provide the schedule through November 2009 and update it with December
2009 information as soon as the information becomes available.
REQUEST NO. 222: What amount of conservation expenses are currently included in base
rates? For the test year, please identify the amounts, by month, and the accounts to which the
conservation expenses are booked.
REQUEST NO. 223: The Company's response to Production Request No. 142 offers an
explanation of the Televox outbound callng system. When does the system place the calls? Is the
timing of calls controlled or automatic?
REQUEST NO. 224: Please provide further detail of all costs and revenues associated with
United Water Idaho's biling of Leakguard legacy customers, including costs and revenues for the
collection and transfer of fuds and handling of incoming calls by United Water Idaho's customer
service center on behalf of Home Service. Please provide the information on a monthly basis for
the years 2007-2009 to date in an electronically executable format.
REQUEST NO. 225: Please provide copies of the agreements between United Water Suez,
Home Service and United Water Idaho, concerning the possession and use of United Water Idaho's
TENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 5 DECEMBER 18, 2009
customer mailing list by United Water Suez and Home Service. Please provide detailed explanation
of any revenue (including commissions) or costs for United Water Idaho associated with providing
its customer mailng list to United Water Suez and Home Service. Please provide the information
on a monthly basis for the years 2007-2009 to date in an electronically executable format.
REQUEST NO. 226: Please describe the relationship between United Water Suez and
Home Service USA. Is Home Service USA a subsidiar or affiiate of United Water Suez?
REQUEST NO. 227: Regarding the United Water Cares program, please provide detail of
all costs incured by United Water Suez and United Water Idaho separately by month for 2007-
2009 to date including but not limited to program set up costs, program promotion costs, biling
inserts, and ongoing costs. Please provide the information in an electronically executable format.
REQUEST NO. 228: Regarding the United Water Cares program, please provide detail of
all donations made or in kind services provided by United Water Idaho and United Water Suez
separately by month for 2007-2009 to date in an electronically executable format.
Oíll
Dated at Boise, Idaho, this J a -day of December.
~£.,d.~KriS. Sasser --
Deputy Attorney General
Technical Staff: Matt Elam205-206
Patricia Hars/207-213
Kathy Stockton/214- 222
Chris Hecht/223-228
i:umisc:prodreqluwiw09. i wsksme prod req i O.doc
TENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 6 DECEMBER 18, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF DECEMBER 2009,
SERVED THE FOREGOING TENTH 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(funitedwater.com
BRAD M. PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmaiLcom
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(fmcdevitt-miler.com
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SECRETARY
CERTIFICATE OF SERVICE