20110921UWI to Staff 2,3,4.pdf

McDevitt & Miller LLP
Lawyers RECEIVED
[phone]
[phone] (Fax)
420 West Bannock Streeioii SEP 21 PH l¡: 16 .P.O. Box 2564-83701 Chas. F. McDevittBoise, Idaho 83702 Dean J. (Joe) Miler
September 21, 2011
Via Hand Delivery
Jean Jewell, Secretary
Idaho Public Utities Commssion
472 W. Washigton St.
Boise, Idaho 83720
Re: Case No. UWI-W-11-02
General Rate Case Fili
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 2, 3 and 4.
Kidly retu a fie staped copy to me.
Very Truy Yours,
&~~
Dean J. Mier
DJM/hh
Encl.
OR\G\NAL
RECEIVED
Dean J. Miler (lSB No. 1968)
Chas. F. McDevitt (ISB No. 835)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: [phone]
Fax: [phone]
joeCfmcdevitt-miler .com
ZOIl SEP 2' PH 4: J 6
Attorneys for United Water Idaho, Inc
BEFORE TH IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF TH APPLICATION
OF UNTED WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHAGES FOR WATER SERVICE IN
THE STATE OF IDAHO
Case No. UW-W-ll-02
UNITED WATER IDAHO INC'S
RESPONSE TO COMMISSION
STAFF'S FIRST PRODUCTION
REQUESTS
United Water Idaho Inc, ("United Water") by and though its undersigned attorneys,
hereby submits its Responses to the Commission Staffs First Production Request No's 2, 3, and
4.
DATED ths~day of September, 2011.
UNITED WATER IDAHO INC.
By~4è \ll
. --. J. Miler (lSB No. 19(8)
McDevitt & Miler LLP
420 West Banock
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 FIST PRODUCTION
REQUESTS-l
CERTIFICATE OF SERVICE
1 herby cefy tht on the .t \'ïy of Sepbe, 201 1, I cans to be sered vi. the
method(s) indicated below, tre an correct copies of the foregoing document, upon:
Jean Jewell, Secreta
Idaho Public Utilties Commssion
472 West Washigton Street
P.O. Box 83720
Boise,ID 83720-0074
j jewellCfpuc.state.id. us
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U.S. Mail
Fax
Fed. Express
Email
Brad M. Purdy
Attorney at Law
2019 N. 17" St.
Boise, ID 83702
bmpurdyCfhotmail.com
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Fax
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Email
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BY:~e:~
Me EVITT & MILLER LLP
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S FIRST PRODUCTION
REQUESTS-2
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Sponsoring Witness: Jeremiah Healy
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.
RESPONSE NO.2
United Water Idaho views First Production Request Nos. 2, 3 & 4 as requesting information that
is inter-related, therefore the response to all three requests is consolidated in this response to
Request NO.2. The Company also interprets Request NO.2 and Request NO.3 as asking for the
same data. The Company interprets, for the purposes of this response, the number of bils
rendered to be equal to the number of customers biled in any month. For these reasons, the
responses to Production Requests Nos. 2 & 3 are the same. The enclosed Excel file titled "#2
Customers and Usage Jan 1986 to Present.xlsx" contains the data requested.
With regard to total consumption by month by class, the Company has historically used customer
information system monthly biling reports.
With regard to usage per customer, the Company has generally divided actual or adjusted actual
total monthly consumption for each customer class by the bi-monthly customer count by class to
derive the average usage. This information is well documented for the periods 1986 though
1998 and March 2005 through the present. For the period Januay 2000 through Februar 2005,
the Company had total usage, but the monthly customers biled count was not readily available.
Therefore, the Company relied on and used a historical ratio of the relative size of each class of
customers in each monthly biling cycle (historical data) and derived the number of customers
biled in order to calculate usage per customer for the years 2000 through February 2005. This
data could be validated on an anual basis because total consumption was known, and the
calculation is documented.
For the period January through December 1999, the Company has data that indicates monthly
usage per customer by class, however, this usage per customer is not verifiable with actual
support documents. Therefore, it was decided that monthly usage per customer for this period
would not be supplied. However, we have supplied anual usage per customer.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jeremiah Healy
REQUEST NO.3:
Please provide the number of bils each month from Janua 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.
RESPONSE NO.3
Please see the response to Request NO.2.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jeremiah Healy
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-
monthy, private fire lines bi-monthly). Please provide in Excel format with all formulas intact.
RESPONSE NO.4
Please see the response to Request No.2.