20110826Staff to UWI 1-26.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
RECE\V
10\ \ ~UG 26 ll~ '3: 01
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 ELECTRIC SERVICE
IN IDAHO
)
) CASE NO. UWI-W-11-02
)
)
) FIRST 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 Stutzman, Deputy Attorney General, requests that United Water Idaho (Company;
United Water; UWI) provide the following documents and information on or before
FRIDAY, SEPTEMBER 16,2011.
This Production Request is 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
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 AUGUST 26,2011
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.1: Please provide all electronic fies, worksheets, tables, and schedules
related to the development of Exhibit No.5, Schedules 6 through 9. Please provide in Excel
format with formulas intact.
REQUEST NO.2: Please provide the number of customers each month from Januar
1986 to present for each customer class (residential bi-monthly, commercial bi-monthly, other
public authority bi-monthly, private fire lines bi-monthly). Please provide in Excel format with
all formulas intact.
REQUEST NO.3: Please provide the number of bils each month from January 1986 to
present for each customer class (residential bi-monthly, commercial bi-monthly, other public
authority bi-monthly, private fire lines bi-monthly). Please provide in Excel format with all
formulas intact.
REQUEST NO.4: Please provide average usage biled and total usage biled from
January 1986 onward for each customer class (residential bi-monthly, commercial bi-monthly,
other public authority bi-monthly, private fire lines bi-monthly). Please provide in Excel format
with all formulas intact.
The following production requests are in reference to Greg Wyatt's testimony:
REQUEST NO.5: Please provide a copy of United Water's most recent Water System
Master Plan. To the extent not discussed in the Master Plan, please provide copies of other
reports or plans that describe United Water's infrastructue improvement/replacement programs.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 AUGUST 26, 2011
REQUEST NO.6: In reference to managing your water system more efficiently, please
provide all available information on the lost and unaccounted-for-water in your system and how
you are managing the system to minimize these losses.
The following production requests are in reference to Scott Rhead's testimony:
REQUEST NO.7: Please provide brief project description, location and justification for
initiating, constructing and completing all capital projects listed in Exhibit 3, page 2-3.
REQUEST NO.8: Reference Exhibit 3, page 1-3. For those projects that are not yet
completed and put into service, please provide expected completion date, the final cost and
documentation of a contract for completion.
REQUEST NO.9: If not included as par of the response to Staff Production Request
No.7, please explain the purose of obtaining the water rights described as Project No CL lA501
in Exhibit 3, page 1. Is this a water rights purchase or a water rights application? Please provide
an explanation and documentation.
REQUEST NO. 10: Please reconcile the information indicating that the diesel
generating unit was placed in service in February 2011 (Rhead Di. page 6) and an in-service date
of November 201 1 (Rhead's Exhibit 3, page 1).
REQUEST NO. 11: Please provide financial analysis and workpapers to document the
Company's claim that the Alternate Distribution Service Agreement with Idaho Power Company
with an associated anual expense of$75,716 is now reduced to $21,160 by installing Auxilary
Power additions and the termination of the said agreement.
REQUEST NO. 12: Reference page 4, lines 20-21. The anual purchased water has
ranged from approximately $186,000 to $130,000 durng the period from 2004-2010. Please
provide the historical yearly water purchases for this period using similar format as shown in
Exhibit 4, page 1.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 AUGUST 26,2011
REQUEST NO. 13: Please provide an updated copy of all leases, purchase agreements
or other contracts for water as shown on Exhibit 4.
REQUEST NO. 14: Has United Water attempted to normalize its purchase water costs
due to varying raw surface water costs and availabilty from year to year? If yes, please explain
the process used. If not, why not?
REQUEST NO. 15: Reference Exhibit 4. Please clarify why three customers of United
Water are taking water from the Garden City Public Works and the Company is paying for it.
Does United Water have Interconnection Agreement with Garden City Public Works? Please
explain.
The following production requests are in reference to Paul Herbert's testimony:
REQUEST NO. 16: Please provide all electronic fies, worksheets, tables, and
schedules related to the development of Exhibit 5 (Schedules 1 -9), Revenue under Present and
Proposed Rates. Please provide in Excel format.
REQUEST NO. 17: Please provide spreadsheets, workpapers or other information
related to development of the Cost of Service Allocation Study (Exhibit 5, Schedules 1 -9).
Please provide in Excel format.
REQUEST NO. 18: Ifnot included in response to Staff Production Request No. 17,
please provide the meter equivalent ratios used in calculating the customer charge for the
proposed rates staring from 5/8-inch to 8-inch for residential and commercial, shown in Exhibit
5, Schedule 3. Similarly, please provide the meter-equivalent ratios used to calculate private fire
service customer charges for 3-inch to 12-inch lines.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 AUGUST 26,2011
REQUEST NO. 19: Reference Exhibit 6, Schedule A. Please explain what constitutes
"other revenues" and provide workpapers showing the basis for the adjustments from $161,306
(present rates) to $189,031 (proposed rates).
REQUEST NO. 20: Did United Water consider rate designs other than the one
proposed? If so, what other rate designs were considered? Why were they rejected?
REQUEST NO. 21: The Company's established summer biling period is between May
1 and September 30 (5 months), and the winter period is between October to April (7 months) as
shown in its curent taiff, Schedule 1, General Metered Service (Attachment 2, page 1 of
Application). Please explain why you used December through April biling to determine average
winter month consumption, since billngs in November and May would also include winter
consumption. Reference, Herbert Di, pages 4-5.
The following production requests are in reference to Jerry Healy's testimony:
REQUEST NO. 22: Please provide spreadsheets, workpapers and any other information
showing the derivation of the total annual power expenses as shown in Expense Adjustment No.
19, Exh. 1 1, Schedule 1, page 19. Please provide in electronic Excel format.
REQUEST NO. 23: Please provide spreadsheets, workpapers, and any other
information showing the derivation of the total annual chemical expenses as shown in
Adjustment No. 20, Exh. 11, Schedule 1, page 20). Please provide in electronic Excel format.
REQUEST NO. 24: Please provide a summary of all water quality tests that UWI is
required to perform. For each test, include the frequency and cost.
REQUEST NO. 25: In explaining how the proposed Anual Cost Adjustment (page 22
of Healy testimony) estimates the operating costs percentage, you used total proposed revenues
of $46,076,627 as the denominator (i.e. total operating costsltotal proposed revenues). In
calculating the proposed anual cost adjustment of customer's bil to compensate for over
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 5 AUGUST 26,2011
collecting, you divide the over-collected amount by the pro forma water revenue (no customer
service fees or other fees included in revenue considered), that is $165,310/$45,950,000 or
0.39%. Please explain why the pro forma water revenue ($45,950,000) was used instead of the
total proposed revenue ($46,076,627).
REQUEST NO. 26: Please explain the Company's proposal for timing the
implementation of the proposed cost adjustment mechanism between general case rate filings.
Dated at Boise, Idaho, this iray of August 2011.
~~
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Cathleen McHugh/I-4
Gerry Galinatol5-26
i:umisc:prodreq/uwiwl 1.2wscm prod reql.doc
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 6 AUGUST 26, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF AUGUST 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO UNITED WATER IDAHO INC., IN CASE NO.
UWI-W-II-02 BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
KEVIN H. DOHERTY
UNITED WATER MANAGEMENT AND
SERVICES COMPANY
200 OLD HOOK ROAD
HARRINGTON PARK, NJ 07640
E-MAIL: Kevin.dohertyiiunitedwater.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joeiimcdevitt-miler.com
heatheriimcdevitt -miller .com
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdyiihotmail.com
,b~
SECRETAR
CERTIFICATE OF SERVICE