20091230UWI to Staff 230-231, etc.pdf

McDevitt & Miller LLP
Lawyers
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[phone]
[phone] (Fax)
420 W. Bannock Street
P.O. Box 2564.83701 2ß09 DEC 30 PM 3: 00 Chas. F. McDevitt
Boise, Idaho 83702 Dean J. (Joe) Miler
December 30, 2009
Via Hand Delivery
Jean Jewell Secreta
Idao Public Utities Commssion
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
Commssion Staffs Eleventh Production Request Nos. 230, 231, 233, 234, and 237.
Kidly retu a fie staped copy to me.
Very Truy Yours,
McDevitt & Mier lL
~ULDean J. Mier
DJM/hh
End.
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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(lmcdevitt -miler. com
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2009 OEC 30 PM 3: 00
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
ELEVENTH PRODUCTION
REQUESTS
United Water Idaho Inc, ("United Water") by and though its undersigned attorneys,
hereby submits its First Response to the Commission Staffs Eleventh Production Request Nos.
230,231,233,234, and 237.
DATED ths -Šday of December, 2009.
UNITED WATER IDAHO INC.B~Dead ~
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 FIRST RESPONSE TO COMMISSION STAFF'S ELEVENTH
PRODUCTION REQUESTS- 1
CERTIFICATE OF SERVICE
I hereby certify that on the ~ay of December, 2009, I caused to be sered, via the
method(s) 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 ewell(lpuc. 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(lhotmail.com
Hand Delivered
.U.S. Mail
Fax
Fed. Express
Email
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BY:
McDEvirr & MILLER LLP
UNITED WATER IDAHO INC'S FIRT RESPONSE TO COMMISSION STAFF'S ELEVENTH
PRODUCTION REQUESTS- 2
UNITED WATER IDAHO INC.
CASE UWI- W -09-01
ELEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
PreparerlSponsoring Witness: Gregory P. Wyatt
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 of transactions (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.
RESPONSE NO. 230:
All costs associated with the roll-out and implementation of the Company's new logo were paid
by Suez Environnement. No costs for the new logo were incured by or allocated to United
Water Idaho.
UNTED WATER IDAHO INC.
CASE UWI- W -09-01
ELEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
PreparerlSponsoring Witness: Gregory P. Wyatt
REQUEST NQ. 231:
Please state the customer benefits the Company believes are associated with the change in logo.
RESPONSE NQ. 231:
None of the logo change costs were incured by or allocated to United Water Idaho.
UNITED WATER IDAHO INC.
CASE UWI- W -09-01
ELEVENm PRODUCTION REQUEST OF TH COMMISSION STAFF
PreparerlSponsoring Witness: Gregory P. Wyatt
REQUEST NO. 233:
Please provide the final costs for painting the Crestline 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.
RESPONSE NO. 233:
The initial $76,000 projected cost to paint the Crestline Reservoir used in the case fiing was
from an estimate provided by Preferred Tan & Tower, Inc. When the project was actually bid
to various contractors, it was awarded to J&L Co. Norteast Inc. who was able to perform the
tan painting for a lower cost. To date, the Company does not yet have the contractor's final
invoice for the work, but the final cost is stil anticipated to be the $59,480.37 as indicated in the
response to Request #168.
UNITED WATER IDAHO INC.
CASE UWI- W -09-01
ELEVENm PRODUCTION REQUEST OF TH COMMISSION STAFF
PreparerlSponsoring Witness: Gregory P. Wyatt
REQUEST NO. 234:
Please provide an accounting extract and access to the underlying cost documentation for the
Steelhead tan painting. Please include in the accounting extract the vendor description, line
description, amount paid, transaction number, date and account posted.
RESPONSE NO. 234:
As the Steelhead project is just now getting underway, the Company has not yet received any
invoices from the contractor and thus no accounting extract is yet available.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01
ELEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 237:
Please update Production Request No. 21 response with an electronic copy in Microsoft Excel
format (with formulas intact) of the most current version of the advance and refund spreadsheet
maintained by the Company.
RESPONSE NO. 237:
Enclosed is an Excel fie titled "#237 25200 UWID Advance Refud List.xlsx" which is
responsive to this request.