20091221Staff 229-247 to UWI.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
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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
)
)
) ELEVENTH 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,
Weldon B. Stutzman, Deputy Attorney General, requests that United Water Idaho (Company;
United Water; UWI) provide the following documents and information on or before TUESDAY,
JANUARY 5, 2010. Year-end and December data may be updated no later than Friday,
January 8, 2010.
ELEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 DECEMBER 21,2009
This Production Request is to be considered as continuing, and United Water is requested
to provide, by way of supplementar 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 IDAP A
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. 229: In reference to Production Request No. 64 regarding corporate
governance, please identify the costs in the Company's response to Production Request No. 64
that are included in the general rate case expenses for recovery from customers. Please include
suffcient detail to allow identification of each specific cost on Production Request No. 64 for
which the Company requests recovery.
REQUEST NO. 230: Please identify all costs in the Company's case associated with its
new logo referenced in its 2009 biling insert. Please include with your response a detailed
listing oftransactions (whether direct or allocated costs) with account posted, amount posted,
date posted, vendor description, line description, and transaction number, and provide access to
or copies of the related accounting documents referenced in the previous production request.
REQUEST NO. 231: Please state the customer benefits the Company believes are
associated with the change in logo.
REQUEST NO. 232: Please provide the detailed supporting documentation for
chemical costs during the year and as updated in WP 11.1.10.1 and Adjustment 9 to Operating
Expenses (Exhibit No. 11, Schedule 1, page 9 of 22). Please include with your response the
ELEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 DECEMBER 21, 2009
price sheets (estimates, bids, invoices, and other relevant documentation) for all chemicals on
that workpaper.
REQUEST NO. 233: Please provide the final costs for painting the Crestlne Reservoir
if it differs from the $59,480.37 referenced in the Company's response to Production Request
No. 168. Please reconcile this amount with the $76,000 included in the case for Crestline tan
painting on Exhibit No. 13, Schedule 10, line 19.
REQUEST NO. 234: Please provide an accounting extract and access to the underlying
cost documentation for the Steelhead ta painting. Please include in the accounting extract the
vendor description, line description, amount paid, transaction number, date and account posted.
REQUEST NO. 235: Please provide an update on the status of the Steelhead tan
painting, and include a copy of all invoices received for this project. As of the Company's
response to Production Request No. 168 fied December 10,2009, no invoices had been received
associated with this project with a contracted completion date of December 31, 2009.
REQUEST NO. 236: Please provide an update on the status of the Hilcrest tan
painting. The Company's response to Production Request No. 168 fied December 10,2009,
stated that the project is anticipated to begin later in December 2009. Please provide
documentation evidencing the beginning and completion dates for this project, and include a
copy of all invoices received for this project.
REQUEST NO. 237: Please update Production Request No. 21 response with an
electronic copy in Microsoft Excel format (with formulas intact) of the most curent version of
the advance and refund spreadsheet maintained by the Company.
REQUEST NO. 238: In reference to Production Requests Nos. 118 and 119 regarding
rate case expenses, please provide the December 31, 2009, update to these responses when
ELEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 DECEMBER 21,2009
available, and include all related invoices since the Company's response to Production Requests
Nos. 118 and 119.
REQUEST NO. 239: In reference to the Company's response to Production Request
No. 119, please provide detailed supporting documentation regarding the Company's $50,000
estimate of M&S Company case management, including the estimated payroll hours and other
costs included within this estimate.
REQUEST NO. 240: In reference to the Company's response to Production Request
No. 119, please provide clarification of the GDS Associates letter agreements as both documents
are dated June 4,2009, seem to reference the same deliverables but contain differing dollar
amounts. Please include with your response the attached fee schedule referenced in the
agreement(s).
REQUEST NO. 241: In reference to the Company's response to Production Request
NO.1 19, please provide all supporting documentation regarding the Company's $15,000 estimate
of customer notice, cour reporting and miscellaneous costs.
REQUEST NO. 242: In reference to the Company's response to Production Request
No. 119, please explain and provide supporting documentation for the $26,384 included in the
rate case expense that is stated as the remaining unamortized balance of prior case UWI-W-06-
02 as of March 2010. Please include in your response the original amount and amortization
approved by the Commission, the underlying calculation of the $26,384 in executable format,
and the relationship of that to the $18,066 unamortized balance for the UWI-W-06-02 rate case
expense on line 12 of Exhibit No. 13, Schedule 10.
REQUEST NO. 243: In reference to the Company's response to Production Request
No. 149, please provide the CEA(s) and CWIP report for the System Enhancements Project
(C08J950). Please include with your response:
ELEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 DECEMBER 21,2009
a. a detailed description (both narrative and numeric) of how the original and amended
budget/CEA amounts were derived,
b. the purpose of the project,
c. a detailed description of why the project expenditure amount in Production Request
No. 149 exceeds the CEA amount by over $900,000, and
d. any fuer explanatory information necessar to describe the project(s) and their
costs.
REQUEST NO. 244: In reference to the Company's responses to Production Request
Nos. 75 and 149, please provide the CEA(s) for the GAC Filter at Swift 1 & 2 (C08B001).
Please include with your response:
a. a detailed description (both narative and numeric) of how the original and amended
budget/CEA amounts were derived,
b. the purose of the project,
c. a detailed description of why the project expenditure amount in Production Request
No. 75 exceeds the budget amount by approximately $500,000,
d. a detailed description and underlying spreadsheet of any expenditures that are an
allocation from Corporate or any other entity,
e. the difference between the budget amount and the CEA amount on Production
Request No. 149, and
f. any further explanatory information necessary to describe the project(s) and their
costs.
REQUEST NO. 245: In reference to the Company's responses to Production Request
Nos. 76 and 149, please provide the CEA(s) for the Braemere Booster upgrade (C07C504).
Please include with your response:
a. a detailed description (both narative and numeric) of how the original and amended
budget/CEA amounts' were derived,
b. the purose of the project,
ELEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 5 DECEMBER 21, 2009
c. a detailed description of why the project expenditure amount in Production Request
No. 76 exceeds the budget amount by approximately $400,000,
d. the difference between the budget amount and the CEA amount on Production
Request No. 149, and
e. any furher explanatory information necessar to describe the project(s) and their
costs.
REQUEST NO. 246: In Case No. UWI-W-06-02, Exhibit No.5 (Accumulated Deferred
Federal Income Taxes), line 4, the amount of$2,470,159 was identified as Account 253-87,
Deferred Advances and Contributions Gross Up related to the Tax Reform Act of 1986. In
Exhibit No. 13, Schedule 8 (Accumulated Deferred Income Taxes) ofthe.curent case there is no
such referenced amount. Please identify the status of that account/amount and explain how and
why the account/amount has changed.
REQUEST NO. 247: From Exhibit No. 13, Schedule 8, Per Books 05/31/2009, please
provide the documentation and workpapers for these amounts. Please include with your
response the account numbers and the dollar amounts for each line.
Dated at Boise, Idaho, this?l~day of December.
V,J~
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Patricia Hars/229-247
i:umisc:prodreqluwiw09. i wsksph prod req i i .doc
ELEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 6 DECEMBER 21,2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21sT DAY OF DECEMBER 2009,
SaRVED THE FOREGOING ELEVENTH 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
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmaiL.com
~b~SECRETARY -
CERTIFICATE OF SERVICE