20100107UWI to Staff 210, 214-218 etc.pdf

McDevitt & Miller LLP
Lawyers f:i ¡: C i: I f"cl '~.,_".~ r: " j i
[phone]
[phone] (Fax)
420 W. Bannock Street
P.O. Box 2564-83701
Boise, Idaho 83702
2010 JAN -7 PH i: i;£,s. F. McDevitt
Dean J. (Joe) Miler
Janua 7, 2010
Via Hand Delivery
Jean Jewell, Secreta
Idaho 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 Thd Response to
Commssion Staffs Tenth Production Request Nos. 210,214,215,216,217,218,221, and 222.
Kidly retu a fie stamped copy to me.
Very Truy Yours,
McDevitt & Mier 1L
~M&~
DJM/hh
End
OR\G\NAL
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]
i oe(fmcdevitt-miler.com
El
2mo JAN -1 PM \= 54
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
THIRD RESPONSE TO
COMMISSION STAFF'S TENTH
PRODUCTION REQUESTS
United Water Idaho Inc, ("United Water") by and through its undersigned attorneys,
hereby submits its Third Response to the Commission Staffs Tenth Production Request No's
210,214,215,216,217,218,221, and 222.
DATED this --day of Januar, 2010.
UNITED WATER IDAHO INC.
BY:Ùt Wt
Dean J. iler '\
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 THIR RESPONSE TO COMMISSION STAFF'S TENTH
PRODUCTION REQUESTS. 1
CERTIFICATE OF SERVICE i
I hereby certify that on the ~ay of January, 2010, 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
i i ewell (ipuc. 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(ihotmail.com
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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LiBY:
McDEVITT & MILLER LLP
UNITED WATER IDAHO INC'S THIR RESPONSE TO COMMISSION STAFF'S TENTH
PRODUCTION REQUESTS- 2
UNITED WATER IDAHO INC. 101
CASE UWI-W-09-01 a JAN -7 PH I:
TENTH PRODUCTION REQUEST OF TH COMMSSI~/eSWr. . 56
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Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 210:
Please reference the Excel fie provided in parial response to Stafs 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 Constrction for Developer Funded
Extensions from that originally fied and subsequently updated and fied by the Company on
December 11, 2009 when the Developer Funded Extensions increased by approximately
$56,000.
RESPONSE NO. 210:
An error was made in the original forecast, overstating the proforma amount for Contributions in
Aid of Construction (CIAC) for Developer Funded Extensions. The forecast was prepared in
July. The July 2009 capital forecast report indicated $974,600 in CIAC for developer fuded
extensions at May 31,2009. The report's forecast for year-end CIAC was $2,047,000, resulting
in a proforma period amount of $1,072,400 ($2,047,000 - $974,600). The overstatement amount
becomes the difference between the original Exhibit 4 forecast of $1,393,501 and $1,072,000, or
$321,501.
The actual proforma CIAC for developer fuded projects, as of December 29, 2009, is
$1,255,452. This indicates a modest increase over the appropriate Exhibit 4 projection of
$1,072,000. The actual amounts were determined from the December and May Capita
Expenditure Reports, which are available at the Company's office for review upon request.
UNITED WATER IDAHO INC.
CASE UWI - W -09-01 2010 JAN - 7 PH ,:
TENTH PRODUCTION REQUEST OF THE COMMISSION S~~ ';', ',....'.. S6
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Preparer/Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 214:
Please provide a detailed description of all Operating and Maintenance expenditues that were
deferred, delayed, reduced or otherwise managed to minimize costs as a cost reduction effort.
RESPONSE NO. 214:
Please refer to the Company's response to Production Request No. 215.
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REC r'iUNITED WATER IDAHO INC.. CASEUWI-W-09-01 ZOlØJAN -7 PH 1: 57
TENTH PRODUCTION REQUEST OF THE COMMISSIO%~¡r'+lfl' :
UTIIIT'-.." .'.._C.'...'.. ¡¡~ ieÓ cnl-.j.1AIQ(' ",.,-"''j,ji'i'~¡IV..Jivr\J
Preparer/SponsoringWitriess: Gregory P. Wyatt
REQUEST NO. 215:
Please explain actions taken by the Company to minimize the financial impact on customers in
the curent depressed. employment and economic climate; Please inClude copies of any and all
correspondence to employees, includingbut not limited .to email correspondence, letters, meeting
minutes, aid meeting handouts detailng cost cutting efforts planed or alrea4yihplace.
RESPONSE NO.. 215:
The.Compan.yroutinely manages its operating expenditures to minimize impact on customers
regardless of economic conditions. Costs are internally reviewed thoughout the budgeting and
monthly varance analysis processes to enSure that costs are required and justified.' Historical
examples of cost saving efforts initiated by the Company include its paricipation in Idaho
Pówer's Easy Upgrade program in which alllighting at the Company's two water treatment
plants and Victory road offces were changed out in 2007 saving approximately $14,000
anually in power. Another example is the Company's paricipation in the EnerNOC power
shaving prograni which lowers power costs by over $18,500 a year. Additionally, the Company
installed bulk salt storage tans at its two water treatment plants in ordeito beableto procure
salt for generatingsodiull¡,lypochloritefor disinfection ata signficantly lower cost per pound.
The curent economic decline begai to inoresignficantlyevidence itself in the latterpar of
2008, after the 2009 operating budgeting and review cycle had already¡'een completed.. In early
2009, afer the extent of the economic decline was betterllderstood, the Companyre..evaluated
its 2009 budget to determine if certain costs could. be delayed or modified without compromising
regulatory requirements. or customer service~ The following list indicates amounts and areas
where costs were reduced in 2009 from the original budgeted amounts.
Amount
$4,300 Reduced Adopt-A-School summer intern program byi position
$10,400 Eliminated 1 Production Dept. summer temporary employee
$5,100 Delayed fillng 1 Utility Person vacancy
$32,900 Reduced attendance at various conferences, seminars and training
$8,500 Discontinued paper ads for job vacancies - used online services exclusively
$10,000 Deferred production of new summer conservation TV media ads
/
$25,700 Minimized use of outside legal services
$4,400 Reduced well maintenance chemical use
$56,600 R~duced use.ofvarious outside contractors
$16,600 Reduced use of various oiitsideprofessionai ~ervjces
$9,800 Reduced purchases of field operating and maintenance materials
$3ìOoo Reducèd use of outside equipment rental
$2,100 Reduced use of office supplies
$4,400 Reduced use ofoffîce equipment rental
$5,800 Reduced telephone usage
$17,300 Reduced use of IT related supplies and e)(penSe~i
$g2,ooO Reduced Property and general insurance
$306;700 Total
There were no wrtten corre~RQpdeice to employeesconceming cost reduction meastestaken in
response to the current depressed employtent and economic climate.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01 2010 JAN -7 PM I: 57
TENTH PRODUCTION REQUEST OF THE COMMISS~g~¡~l~~F .
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Preparer/Sponsoring Witness: Gregory P. Wyatt
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 401k expenses.
RESPONSE NO. 216:
United Water Idaho does not track vehicle expenses in a fashion that enables delineation by
personal use vs. business use of vehicles, so no schedule showing the dollar amount of all vehicle
expenses included in the rate case application that pertain to personal use of vehicles is available.
UNITED WATER IDAHO INC.
CASE UWI-W-09-01 ZOHJJAH-7 Prf ,.
TENTH PRODUCTION REQUEST OF THE COMMISSION1§;;M:F, .' 57
UT.'LI'r'...~n.... 1"''-.'...1 tiL. ,...:fi-r: r'(~'. '..'.. ~J '''.. Î .;"f ~~t I. S (\ I. (".' ...' . fl 'ti. \. t"J r,,.) t'+l'
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Preparer/Sponsoring Witness: Gregory P. Wyatt
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 pertaining to benefits such as
payroll taxes, and other benefits based on payroll such as pensions and 401k expenses.
RESPONSE NO. 217:
A schedule showing the total dollar amount of vehicle allowance expenses, by account number,
included in the rate case application is shown below. No costs pertaing to benefits such as
payroll taxes, and other benefits based on payroll such as pensions and 401k expenses are added
to the vehicle allowance expenses.
Control JE Line
Journal Account Account Amount Date Description JE Header Descr
PAY0284110 118 18420 $1,200.00 2008-06-15 Payroll and Benefits Payroll and Benefits
PAY0285997 118 18420 $800.00 2008-07-15 Payroll and Benefits Payroll and Benefits
PAY0287869 118 18420 $800.00 2008-08-15 Payroll and Benefits Payroll and Benefis
PAY0290077 118 18420 $400.00 2008-09-15 Payroll and Benefits Payroll and Benefits
PAY0292100 118 18420 $800.00 2008-10-15 Payroll and Benefits Payroll and Benefits
PAY0293695 118 18420 $1,200.00 2008-11-15 Payroll and Benefis Payroll and Benefits
PAY0295929 118 18420 $800.00 2008-12-15 Payroll and Benefits Payroll and Benefits
PAY0298895 118 18420 $800.00 2009-01-15 Payroll and Benefits Payroll and Benefits
PAY0301105 118 18420 $400.00 2009-02-15 Payroll and Benefits Payroll and Benefits
PAY0303368 118 18420 $800.00 2009-03-15 Payroll and Benefits Payroll and Benefits
PAY0305425 118 18420 $800.00 2009-04-15 Payroll and Benefits Payroll and Benefits
PAY0307430 118 18420 $800.00 2009-05-15 Payroll and Benefits Payroll and Benefits
Total Vehicle Allowance
$9,600.00 Payments
UNITED WATER IDAHO INC.
CASE UWI-W-09-01 20/0 JAN -7 PH .
TENT PRODUCTION REQUET OF TH COMlSSI~~I§;iJBLid . 57
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Preparer/Sponsoring Witness: Kevin Doherty
REQUEST NO. 218:
From Exhibit 10, Colum 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 ($2,947).
RESPONSE NO. 218:
Please refer to the enclosed Excel fie titled "#218 Attachment 53109 Income Stmt.xlsx"
showing the Company's 12 month Income Statement as of May 31,2009. The referenced
amounts come directly from the Income Statement.
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r:?r'CE"i1"C J .. ¡UNITED WATER IDAHO INC.
CASEUWI-W-09-01 201OJAN-7 PM 1=58
TENTH PRODUCTION REQUEST OF THE COMMI~~Çl~í~r~~F
UTILIT'r-" t" d ':_.d~, 'c'H:S ~..o.. ';,A;ilï'I'i;~C'iO". ".'.1~$n-_vVI"_ l'"t
Preparer/Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 221:
Please provide a schedule ofthe deferred power costs since the inception of the deferral account
as provided in Order No. 28505, Case No. UWI-W;.OO.Ol. 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.
RESPONSE NO~ 221:
The COmmissi?IlOrderautliorizingUnited Water Idaho to defer cerain power cost on its booksrelated to the fluctuation in Idaho Power's anual Power Cost Adjustment was Order No. 28800
issueâ inCaseNo,UWI~ W-Oh.02, The Order authorized a deferral account for incremental cost
related to recent. and future PCAreiate~ ,increases. in Idaho POW~l"s electrç power rates
beginninKin.MiiY1, 2001,.Additionally, the Commission found in thatOl'der that itwasreasonable to reserve judgnent on recovery of the amount deferred,aswel1 as the
appropriàtenes$ of any carng charge, until actual recovery was requested.
TheCompaný.proceeded to defer cost fromJune 2001 though the filingofÇase UW- W-04-04
in November, 2004. PursuanttOUrderNo.28800, UnitedJNaterIdaho sought recOvery of .$1,550,000 of deferred power costs in its direct case and,aarebuttal, reduced this amount to
$1,469,292 of deferred power costs, the Company's estiiate of deferred costs thugh June,
2005. In Order No. 29838, the COmmission found the amount cared on the Company's bòoksfrom May 1, 2001 to June 30, 2005 (estimated) to be appropriate for recovery, with a three year
amortization period, and a carng charge of 1 % to be included in the recovery of the costs. The
Company subsequcmtiy moved from account 18710 (Deferred Power Cost Pending) to account
18625 (Deferred Power Cost Approved) $1,470,386.26 in deferred power cost (the actual
deferral as of June, 2005) and $31,565 in interest cost at 1 %., or a total of$I,501,933.26. The
Company also wrote off $45,183.67 of over accrued interst costs from account 18710, as a
result ofthe Commission's Order allowing 1%. This essentially reset the 18710 account to zero.
On Februar 10, 2006, the Company filed Case UWI- W -06-02. Commission Order No. 30104
issued July 24, 2006 and recognizing the Stipulation Agreement reached in that case, provided
that the Company continue its current method to account for power cost as affected by Idaho
Power Company's anual rate adjustment (the Idaho Power PCA rate), that the Company may
amortize over thee years the approximate curent balance of $79,000 for purchased power
"
-/
expense, and that fuher deferral wil reflect the PCA rate as effective June 1, 2006. In August of
2006, the Company transferred $78,626.59 ($77,624.21 in deferred power and $1,002.38 in
accrued interest) from account 18710 (Deferred Power Pending) to account 18625, Deferred
Power Cost Approved. Again, this transfer essentially zeroed out the 18710 account.
Enclosed with this submission are files which provide the monthly and anual deferred power
amounts, along with the interest calculation, recorded on the Company's books for the years
2006 through 2009. Also enclosed is the December 2009 deferred power worksheet which
shows how the monthly deferral is derived. All the other monthly deferral worksheets are
available for inspection and review at the company's offices.
The enclosed files are titled:
"#221 IPUC PowerDef Summar 2006.xls"
"#221 IPUC Power DefSummar 2007.xls"
"#221 IPUC Power Def Sumar 2008.xls"
"#221 IPUC Power DefSumar 2009.xls'~
"#221 IPUC Power DefWorksheet.xls"
.
-."
RECE \/ Cl
UNITED WATER IDAHO INC.
CASEUWI-W-09-01 ZOIOJAN-7 PM 1:58
TENTH PRODUCTION REQUEST OF THE COMMSSI~~lì~r",
UTllITI.-r, 1'''' ,"'I f.¡,',,'". . . i...""'¡ i' l l ,!'- öl ~:i,-';I ! ..-' ."'' ,_'- "".IVfl1ln.L,li~
Preparer/Sponsoring Witness: Gregory P. Wyatt
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.
RESPONSE NO. 222:
Because "base rates" were last set in the 2006 rate proceeding (UWI-W-06-02) in accordance
with a Stipulated Settlement, the Company is not able to accurately determine what amount of
conservation expenses are currently included in base rates. For the test year in the curent case,
attached is a summary of the expenses charged to account 90410 related to the Company's
ongoing conservation expenses. In addition to these expenses, the Company incurs an anual
payroll expense of $39,027 (charged to account 92000) plus benefits for its Outreach and
Education Coordinator who's primary responsibility is the implementation of the Company's
conservation programs and efforts.
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