HomeMy WebLinkAbout20110915UWI to Staff 1,7,9,10-13,16-21,24.pdfMcDevitt & Miler LLP
Lawyers RECE o
(208) 343-7500
(208) 336-6912 (Fax)
420 West Bannock Street
P.O. Box 2564-83701
Boise, Idaho 83702
201 i SEP 15 PH 2: 51Chas. F. McDevitt
:Dean J. (Joe) Miler
!S.~3¡(J?\
September 15, 2011
Via Hand Deliveiy
Jean Jewell, Secretary
Idaho Public Utities Commssion
472 W. Washigton St.
Boise, Idaho 83720
Re: Case No. UWI-W-11-02
General Rate Case Filing
Dear Ms. Jewell:
Enclosed for fig, please fid thee (3) copies of United Water Idaho's Response to Commssion
Staffs First Production Requests No's 1, 7, 9, 10, 11, 12, 13, 16, 17, 18, 19,20,21 and 24.
Kidly retu a fie stamped copy to me.
Very Truy Yours,
McDevitt & Miler UP
~~
DJM/hh
End.
Dean J. Miler (ISB No.1968)
Chas. F. McDevitt (ISB No. 835)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: 208.343.7500
Fax: 208.336.6912
joe(ßmcdevitt -miller. com
Attorneys for United Water Idaho, Inc
-. "
RECE 0
2011 SEP 15 PH 3: 02
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHAGES FOR WATER SERVICE IN
THE STATE OF IDAHO
Case No. UWI-W-ll-02
UNITED WATER IDAHO INC'S
RESPONSE TO COMMISSION
STAFF'S FIRST PRODUCTION
REQUESTS
United Water Idaho Inc, ("United Water") by and through its undersigned attorneys,
hereby submits its Responses to the Commission Staffs First Production Request No's 1, 7, 9,
10, 11, 12, 13, 16, 17, 18, 19,20,21 and 24.
DATED this 15th day of September, 2011.
UNITED WATER IDAHO INC.
By:
eanJ. iller No. 1968)
McDevitt & Miler LLP
420 West Bannock
Boise, Idaho 83702
P: 208.343.7500
F: 208.336.6912
Attorney for United Water Idaho Inc.
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S FIRST PRODUCTION
REQUESTS-l
CERTIFICATE OF SERVICE
I hereby certify that on the 15th day of September, 2011, I caused to be served, via the
methodes) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, ID 83720-0074
j j ewellCiuc. state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
~............
Brad M. Purdy
Attorney at Law
2019 N. 17" St.
Boise, ID 83702
bmpurdy(ßhotmail.com
Hand Delivered ...
U.S. Mail ~
Fax ...
Fed. Express ...
Email ...
BY:~
McDEVITT & MILLER LLP
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S FIRST PRODUCTION
REQUESTS-2
RECEIVED
UNITED WATER IDAHO INC.
CASE UWI-W-ll-02 zon SEP 15 P~j 2: 59
FIRST PRODUCTION REQUEST OF THE COMMI~QN"Sr~rF
IT'f:S (~()l/~ /,lSS¡
Preparer/Sponsoring Witness: P. Herbert
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.
RESPONSE NO.1
See enclosed Excel spreadsheet file titled "#1 Exhibit5, Sch 6-9.xlsx".
UNITED WATER IDAHO INC.
CASE UWI-W-ll-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
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.
RESPONSE NO.7:
In response to your request see enclosed Excel fie titled "#7 Project Desc Justification.xlsx".
UNITED WATER IDAHO INC.
CASE UWI-W-ll-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO.9:
Ifnot 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 CllASOI in Exhibit 3, page 1. Is
this a water rights purchase or a water rights application? Please provide an explanation and
documentation.
RESPONSE NO.9
There is no water right expenditure included in Project No CIIAS01. It is for drillng a
replacement well at the Fox Tail well site.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 10:
Please reconcile the information indicating that the diesel generating unit was placed in service
in Februar 2011 (Rhead Di. page 6) and an in-service date of November 2011 (Rhead's Exhibit
3, page 1).
RESPONSE NO. 10
These two in-service dates, February 2011 and November 2011, relate to two separate projects.
The diesel generating units placed in service in February 2011 were installed at the Columbia
iWater Treatment Plant (CWTP) and the CWTP Raw Water Pump Station (CLOC302). The
diesel generating unit projected to be placed in service in November 2011 is for the Spuring
Well (CIIC301).
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 11:
Please provide financial analysis and work papers 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 installng Auxiliar Power additions and the
termination of the said agreement.
RESPONSE NO. 11
Please see the two enclosed files. The Excel fie titled "# 11 Doc. of Power Expense
Reduction.xlsx" ilustrates the derivation of the $54,556 anual savings by comparng pre and
post auxilary power capacity and facilty charges for both the Columbia Water Treatment Plant
and the Boise River Raw Water Pump Station. The total historic anual charges for the capacity
charge and the facilities charge for both facilties is $75,715.88. The attched PDF fie titled
"#11 Termination of Back up Power.pdf' contains the Idaho Power bils with service dates of
Januar 27,2011 and December 31,2010 for the Columbia Water Treatment Plant and the Boise
River Pump Station, respectively, and document the amounts on the Excel fie. On the PDF file,
there are also copies of current Idaho Power bils for these two facilities for the period June 30,
2011 to July 31, 2011. The bils for both facilities under rate schedule 46 indicate that the current
prorated bil is the "Closing bil for this service". Because Idaho Power did not physically
disconnect the power at the River Pump Station until September 6, 2011 and at the Columbia
Water Treatment Plant until September 12,2011, the respective facilty charge bilings have not
yet been received. However, we anticipate that the lower facilty charges wil star to show on the
September 30,2011 read date bils and be fully reflected on the October 31,2011 read date bils.
The PDF file also includes correspondence between Idaho Power and United Water Idaho
noticing the termination of the Uniform Alternate Distribution Service Agreement.
UNITED WATER IDAHO INC.
CASE UWI-W-I1-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 12:
Reference page 4, lines 20-21. The anual purchased water has ranged from approximately
$186,000 to $130,000 during 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.
RESPONSE NO. 12
In response to this request see the attached Anual Purchased Water schedule for the period
2004-2010.
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UNITED WATER IDAHO INC.
CASE UWI-W-I1-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 13:
Please provide an updated copy of all leases, purchase agreements or other contracts for water as
shown on Exhibit 4.
RESPONSE NO. 13
The following attached PDF files are responsive to this request.
#13 Basin 63 Agreement.pdf
#13 BCCC Agreement.pdf
#13 BCCC Shares.pdf
#13 BOR Lucky Peak Agreement.pdf
#13 BOR Lucky Peak O&M.pdf
#13 BOR Anderson.pdf
#13 BVDC Agreement.pdf
#13 BVDC Shares.pdf
#13 Farers Co-op Agreement.pdf
#13 Garden City Agreement.pdf
# 13 Thuran Mil Agreement
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: P. Herbert
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.
RESPONSE NO. 16
See enclosed Excel fie tited "#16 Attachment.xlsx" for data related to Exhibit 5, Schedules 1-5.
For Exhibit 5, Schedules 6-9, see response to Request NO.1.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: P. Herbert
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.
RESPONSE NO. 17
See enclosed Excel Spreadsheet fie titled "# 17 Attachment.xlsx" for Exhibit 6, (Cost of Service
Study) Schedules A through G.
UNITED WATER IDAHO INC.
CASE UWI-W-I1-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
PreparerlSponsoring Witness: P. Herbert
REQUEST NO. 18:
If not 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.
RESPONSE NO. 18
See the attachment to the Response No. 17, worksheet titled "Cust Cost Meter Size" which
calculates the customer costs for residential, commercial and municipal customers by meter size.
The customer costs were based on meter and service equivalents using actual costs. The
proposed customer charges, colum 11, were based on the sum of meters and services, biling
and collecting, and public fire service costs. In order to have a gradual increase to the bi-
monthly customer charge and to move toward cost of service, the proposed customer charges
were within a range of 60% to 89% of the customer costs by meter size, with no customer charge
increasing more than 76% over present customer charges.
Proposed Private fire service proposed customer charges were increased 30% across-the-board
so that existing equivalent ratios curently used by the Company were maintained, as follows:
Present ProposedPrivate fire Meter Rates Meter Equivalent Rates
3" and Smaller $31.68 1.00 $41.18
4".48.02 1.52 62.42
6"1 i 9.26 3.76 155.04
8"195.96 6.19 254.74
10"305.60 9.65 397.28
12"457.74 14.45 595.06
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
PreparerlSponsoring Witness: P. Herbert
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).
RESPONSE NO. 19
Other Revenues includes the following:
Test Year Pro Forma Pro Forma
Account Present Rates Present rates Proposed rates
Misc. Service Charges $56,961 $56,961 $56,961
Construction and Hydrant Rev.96,244 97,788 123,970
Hydrant Rental fee 8,100 8,100 8,100
Total $161,305 $162,849 $189,031
Exhibit 6, Schedule A, colum 4, Other Revenues should have reflected Pro Forma Other
Revenues under Present rates of$162,849 rather than Test Year Other Revenues of$161,306.
See attached Excel spreadsheet fie titled "#19 Attachment.xlsx" for the basis for the adjustment
to Construction and Hydrant revenue from $97,788 to $123,970, which results in the increase to
Other Revenues from $162,849 to $189,031.
UNITED WATER IDAHO INC.
CASE UWI-W-l1-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
PreparerlSponsoring Witness: P. Herbert
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?
RESPONSE NO. 20
United Water Idaho did not consider alternate rate structures other than the one proposed.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
PreparerlSponsoring Witness: P. Herbert
REQUEST NO. 21:
The Company's established summer billng 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
tariff, 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.
RESPONSE NO. 21
The objective in selecting which billng periods to use to estimate average winter or "indoor"
consumption is to isolate the "indoor," non-irrgation usage. The objective is not to include all
consumption biled at the winter rate. Because of the timing of the issuance of the bils, the bils
dated in November and May (most especially for November) include some consumption biled
under the sumer schedule and, more importantly, include usage for irrigation. As noted in Mr.
Herbert's direct testimony pp. 4-5, the biled consumption amounts in the selected months were
lower than the other months and the year-to-year varation was lower, both characteristics
suggesting that those months' bils did not have a substantial irrgation component.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Camille Cegnar, UWID Water Quality Specialist
Sponsoring Witness: Jeremiah J. Healy
REQUEST NO. 24:
Please provide a sumary of all water quality tests that UWI is required to
perform. For each test, include the frequency and cost.
RESPONSE NO. 24
The Idaho Deparment of Environmental Quality (IDEQ) public drinking water
system monitoring schedule report for United Water Idaho, covering the period
Januar 1,2011 though December 31,2013, is listed in the enclosed PDF file
titled "#24 IDEQ Sampling Schedule.pdf'. This schedule indicates distribution
system tests required for the Company's ground water wells and water treatment
plant facilities. For example, the 16th Street well facility, included on the first page
of the report, is required to have one test for Arsenic & Sodium, and one test for
VOCs, performed once in the thee year testing window. This same facilty is
required to test for Nitrates anually. Different water quality test have different
frequency requirements, some test are required anually, some are required once
every three years, some test are required once in a six year cycle. Also, the US
Environmental Protection Agency or IDEQ can introduce new rules, change the
frequency of a paricular test due to the vulnerability of a source, or, if any source
reports a detection on a regulated contaminant, the test cycle for that source
immediately changes from aI, 3 or 6 year cycle to quarerly annual monitoring.
United Water Idaho currently utilzes Analytical Laboratories, Inc, in Boise, as its
testing vendor. Analytical Labs provides United Water Idaho a discounted price for
many of their water quality test. As of September 14, 2011, these prices are as
follows:
~
r'
1. Inorganics (lOCs)
2. Volatile Organics (VOCs)
3. Synthetic Organics (SOCs)
4. Nitrate
5. Arsenic
6. Arsenic/Sodium
7. Iron/anganese
8. Cyanide
9. Lead/Copper
10.Uranium
11. Gross Alpha
12.Radium 226
13.Radium 228
14.Total Coliform
15.Disinfection By Products
16.Toxic Organic Chemicals (TOCs)
$ 425.70
$ 171.00
$1,170.00
$16.20
$18.90
$30.60
$23.40
$33.00
$28.00
$31.50
$63.00
$81.00
$117.00
$10.75
$225.00
$45.00