20091230UWI to Staff 205-209 etc.pdf

McDevitt & Miller LLP
Lawyers
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[phone]
[phone] (Fax)
420 W. Bannock Street
P.O. Box 2564-83701009 OEC 30 Pl1 2: 51
Boise, Idaho 83702
Chas. F. McDevitt
Dean J. (Joe) Miler
December 30, 2009
Via Hand Delivery
Jean Jewell, Secreta
Idao Public Utities Cotnssion
472 W. Washigton St.
Boise, Idaho 83720
Re: Case No. UWI-W-09-01
General Rate Case Fil
Dear Ms. Jewell:
Enclosed for fig, please fid thee (3) copies of United Water Idaho's First Response to
Cotnssion Staffs Tenth Production Request Nos. 205, 206, 207, 208, 209, 211, 213, 220, 223, 224,
226, 227, and 228.
Kidly retu a fie stamped copy to me.
Very Truy Yours,
McDevitt & Mier LL
DJM/hh
Encl.
~~Dean J. Mier
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]
joeCßmcdevitt -miller. com
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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 TENTH
PRODUCTION REQUESTS
United Water Idaho Inc, ("United Water") by and through its undersigned attorneys,
hereby submits its First Response to the Commission Staffs Tenth Production Request Nos. 205,
206,207,208,209,211,213,220,223,224,226,227, and 228.
DATED this~dayofDecember, 2009.
UNITED WATER IDAHO INC.
B~WL
DeaI 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 FIRT RESPONSE TO COMMISSION STAFF'S TENTH
PRODUCTION REQUESTS- 1
CERTIFICATE OF SERVICE
I hereby certify that on the ~ay of Decerber, 2009, I caused to be served, via the
methodes) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secretar
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, ID 83720-0074
j j ewel1mpuc. 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(fhotmaiL.com
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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BY:
McDEvm & MILLER LLP
UNITED WATER IDAHO INC'S FIRST RESPONSE TO COMMISSION STAFF'S TENTH
PRODUCTION REQUESTS- 2
UNITED WATER IDAHO INC.
CASE UWI- W -09-01
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 205:
In Response to Production Request No. 158, the Company says "EnerNOC reduced the number
of the Company's facilties 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 year 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.
RESPONSE NO. 205:
The EnerNOC agreement attached to Response No. 83 answers this Request. As stated in the
Agreement, EnerNOC may adjust the nominated capacity "to reflect actual performance,
changes in facility operations, Program rules, regulations, and/or other relevant inormation."
EnerNOC revised the nominated capacity based on their actual use experience durng the 2009
period. No new agreement was initiated.
UNTED WATER IDAHO INC.
CASE UWI- W -09-01
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 206:
Similar to "WP12,4,4 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 though December 2009.
RESPONSE NO. 206:
The customer count data requested is contained in the enclosed Excel file titled "#206 Customer
Count.xlsx"
UNITED WATER IDAHO INC.
CASE UWI- W -09-01
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 207:
To the extent not previously provided, please provide access to all books and records of the
Company and its related companies.
RESPONSE NO. 207:
Access to the Company's books and records and its related companies wil be provided upon
request. Depending on the request, the records may be located at the Company's Victory Road
office or may be located at its corporate office in New Jersey.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
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 inormation referenced in the
previous two production requests.
RESPONSE NO. 208:
Access to Company personnel wil be provided upon request with reasonable consideration given
to employee work schedule needs. Access to personnel not employed by the Company is not
directly within the Company's control. However, to the extent possible, the Company wil work
with Staf to assist in scheduling access with non-employee personnel as necessary.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kevin Doherty
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 files.
RESPONSE NO. 209:
The attached Excel file titled "Request 209 Attachment.xlsx" contains the information requested.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kevin Doherty
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 of 2, line 17. Please include within your
response the tax depreciation rates.
RESPONSE NO. 211:
The enclosed Excel file titled "Request 211 Attachment Tax Depreciation.xlsx" contains the
requested information.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kevin Doherty
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.
RESPONSE NO. 213:
The enclosed Excel fie titled "Request 213 Attachment Deferred AFUDC Equity Income.xlsx"
shows the projects and amounts that formed the basis for AFUDC Equity Work Paper. The
balances for the period December 2008 through May 2009 are shown on the schedule. The May
2008 through November 2008 balances are taken directly from the Company's Balance Sheet.
UNITED WATER IDAHO INC.
CASE UWI- W -09-01
TENTH PRODUCTION REQUEST OF THE COMMSSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 220:
What is the per customer cost for biling 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.
RESPONSE NO. 220:
Biling and collection costs for all customers (new and existing) are budgeted for on an aggregate
basis by category of expense such as UBS biling, postage, Mellon Ban, etc. Certain costs, such
as those related to delinquent account activity, only apply to a portion of customers. Similarly,
some customers choose e-biling and electronic bil payment which result in a different biling
and collection cost.
As submitted in this case in Loy's work paper WP1 1. 1.10.1 - TY UBS Biling, the incremental
additional biling and collections cost per customer, solely for biling and collections activities
for Budget Biling, is $1.41 per bil or $8.46 per customer ($1.41 x 6). The account numbers
which contain the cost categories considered in this calculation are account numbers 50400,
50410, and 90450. The Company does not segregate these types of costs for new customers
separate from existing customers on its books and records.
This cost per customer does not include any cost for items like meter reading, customer service
staff, office supplies or utilities, and the like, as they do not necessarily increase incrementally
with the addition of each new customer.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 223:
The Company's response to Production Request No. 142 offers an explanation of the Televox
outbound calling system. When does the system place the calls? Is the timing of calls controlled
or automatic?
RESPONSE NO. 223:
The Televox outbound calling system was a pilot project. Durg the pilot, the Company tested
making calls during the afternoon and also tested making calls durg the evening. The
afternoon calls were made from 12:00 -1:00 PM and the evening calls were made from 7:00-
8:00 PM. The selection for the timing of the calls is controlled by the system operator. Once the
call timing is set up and the call fie is uploaded, the system wil place the calls automatically at
the scheduled time.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
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.
RESPONSE NO. 224:
United Water Idaho receives no revenue from United Water Leakguard or from Home Service
for its efforts related to the legacy Leakguard customers. There is no incremental increase in
cost to generate a Leakguard bil over a standard water bilL. Historically, United Water Idaho has
charged United Water Leakguard a monthly fee designed to cover administrative costs for offce
and miscellaneous expenses associated with handling the transactions related to the legacy
Leakguard customers. Currently that charge is $480 per month, or $5,760 per year.
Additionally, certain individuals charge labor to United Water Leakguard for performing the
monthly tasks related to processing collections, handling non-pay notifications, terminating
Leakguard service for non-payment of the Leakguard fee, and other miscellaneous work
associated with Leakguard. The enclosed Excel file titled "#224 Leakguard Cost Trans.xlsx"
contains two worksheets identifying the labor transferred and administration costs transferred
from United Water Idaho to Leakguard for the years 2007 - 2009.
United Water Idaho does not handle incoming calls on behalf of Home Service. In the event an
individual calls United Water Idaho with a question about Leakguard service, our customer
service representatives advise the individual to contact Home Service via their 1-800 phone
number.
UNTED WATER IDAHO INC.
CASE UWI- W -09-01
TENTH PRODUCTION REQUEST OF TH COMMISSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 226:
Please describe the relationship between United Water Suez and Home Service USA. Is Home
Service USA a subsidiary or affiliate of United Water Suez?
RESPONSE NO. 226:
There is no business entity named United Water Suez. As explained in response to Requests
No. 85 and 101, Home Service is neither a subsidiar nor an affilate of the Company. United
Water has an affinity agreement in place with Home Service. A copy of that agreement is
provided in response to Request No. 225.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
TENTH PRODUCTION REQUEST OF TH COMMISSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
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 inormation in an electronically executable format.
RESPONSE NO. 227:
Contributions by the Company to the UW Cares program have already been provided in response
to Request No. 136. In addition to those costs, United Water Idaho has anually placed a bil
insert advertisements in customer's bils to promote the program. The costs for the bil inserts
were $3,580 in August 2007, $3,675 in July 2008, and $3,705 in September 2009. Additionally,
a UW Cares aricle appeared in the 2009 Anual Conservation Guide (page 6) at no additional
cost, and the Company regularly rus a UW Cares bil message on its bils, which is also at no
additional cost. The UW Cares program was initiated in 2004 so no "set up" costs were incured
during 2007 - 2009.
There is no business entitxnamed United Water Suez.
UNITED WATER IDAHO INC.
CASE UWI- W -09-01
TENTH PRODUCTION REQUEST OF THE COMMSSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
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.
RESPONSE NO. 228:
The data that is responsive to this Request has already been provided in response to Request No.
136. There is no business entity named United Water Suez.