20111005Staff to UWI 27-73.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
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lUll OCT -5 ~.M 10: 35
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-LL-02
)
)
) SECOND PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO UNITED WATER IDAHO
) INC.
)
The Staff of the Idaho Public Utilties 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
WEDNESDAY, OCTOBER 26, 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 wil 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
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 OCTOBER 5, 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 hearng 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. 27: Please identify the number of disconnections for non-payment on a
monthly basis for calendar years 2009, 2010 and 2011 to date, by customer class (residential or
commercial). For residential accounts identified as having been disconnected for non-payment,
please provide the number of accounts that received UW Cares benefits prior to disconnection.
REQUEST NO. 28: For those accounts that received benefits from UW Cares and were
later disconnected for non-payment, please provide the monthly and anual total dollar amount
owed at the time of disconnection.
REQUEST NO. 29: For each of the past three calendar years (2008-2010), please
provide by rate schedule: (a) the monthly and annual total dollars written off (gross), and (b) the
monthly and annual total dollars written off due to customer banptcy.
REQUEST NO. 30: For those accounts identified in your response to the previous
question that received payment assistance through UW Cares, please provide: (a) the monthly
and anual total dollars written off (gross), and (b) the monthly and anual total dollars written
off due to customer banruptcy.
REQUEST NO. 31: Please provide an update on the United Water Cares program,
including fuding to date by Company, customer contributions, total dollar amount awarded to
customers, total number of customers assisted, and total amount provided to CAP AI for
administration. Please provide further explanation of the UW Cares program details including
any changes to the program since initiated and when the change was initiated. Please provide the
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 OCTOBER 5, 2011
corresponding analysis in electronic executable format on a monthly basis for calendar years
2009,2010 and 2011 to date.
REQUEST NO. 32: Please describe how incoming calls from customers to the
Company are handled. Include in that explanation answers to the following questions: (a) Are
all calls handled by a centralized customer service call center, or are some types of calls (e.g.,
service outage or new construction) directed to a separate call center or deparment? (b) If some
types of calls are directed outside the customer service call center, are those calls separately
measured or tracked? (c) If some types of calls are handled through an interactive voice
response (IVR) system without the callng party speaking to a customer service representative,
are those calls separately measured or tracked?
REQUEST NO. 33: Please describe all types of calls the Company's IVR system can
handle and identify the implementation date for each type of call handled by the IVR system.
Please provide a call routing and choice selection char or drawing for the system.
REQUEST NO. 34: Please provide the Company's performance objectives for handling
incoming calls; include objectives for both IVR and customer service representative (CSR)
handled calls. What steps does the Company take if it fails to meet its performance objectives?
REQUEST NO. 35: Please provide the service level for the customer service call center
by month for calendar years 2009, 2010 and 2011 to date. "Service level" is the percentage of
calls answered within a certain number of seconds, e.g., 80% of calls answered within 20
seconds. Please differentiate between IVR and CSR calls.
REQUEST NO. 36: Please provide the number of incoming calls handled by the
customer service call center by month for calendar years 2009,2010 and 2011 to date. Please
differentiate between IVR and CSR calls.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 OCTOBER 5, 2011
REQUEST NO. 37: Please provide the number of busy signals reached by parties
callng the customer service center by month for calendar years 2009, 2010 and 2011 to date.
Please differentiate between IVR and CSR calls.
REQUEST NO. 38: Please describe how the Company handles e-mail inquiries,
complaints, payment arangements, service orders, and other routine customer transactions.
Please provide the average response time for e-mail transactions by month for calendar years
2009,2010 and 2011 to date. "Average response time" is the average number of hours from
receipt of an e-mail by the Company to sending a substative response; auto-response
acknowledgements do not count as a substantive response.
REQUEST NO. 39: Does United Water handle customer calls for other entities? If so,
what are those entities? Are the United Water complaint and inquiry calls tracked separately? If
so, please quantify calls by United Water complaints and inquiries and All Other entity calls.
REQUEST NO. 40: Regarding the Company's Televox outbound callng system, please
explain how the system tracks completion of calls. How does it differentiate among calls where
the customer answers, an answering machine or voice mail records a message, or when there is
no answer?
REQUEST NO. 41: Regarding the Company's Televox outbound callng system, please
explain how the calls, once completed, are uploaded in the customer's account and utilzed in the
collection process. Does the Company make more than one attempt to call the customer if there
is no answer, or the phone was busy? Does the system have the capability of handling multiple
phone numbers for a single account? How does the Company handle an account if the phone is
out of order or the number is invalid in the attempt to contact the customer prior to
disconnection?
REQUEST NO. 42: Please provide a detailed accounting oftest year revenues biled
under Schedule No.5, Miscellaneous Fees and Charges for each of the following:
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 OCTOBER 5, 2011
1. Retur Check Charge
2. Reconnection Charge for Nonpayment Terminations
3. Field Collection Trip Charge
4. Service Connection Charge for Other than Normal Business Hours
5. Temporar Disconnection at Customer Request Charge
6. Meter Test at Customer Request Charge
7. Meter Rental Charge for Construction
Please provide your answer in a format similar to the following:
Date Fee or amount charged Number of checks, charges, rentals, etc. Total Revenue
REQUEST NO. 43: Please provide a sample copy of any brochure or other printed
material regarding the Company's Water Conservation program. How and when is this material
provided to customers?
REQUEST NO. 44: Please provide the number of water conservation kits distributed by
UWI in the United Water Cares program for calendar years 2009, 2010 and 2011 to date., Please
separate and identify the number of kits distributed through EI-Ada from those distributed by
UWI directly to customers.
REQUEST NO. 45: Please describe in detail any planed brochures, kits, devices or
other physical items curently planed for but not yet distributed to customers. Please include
within your response the timing of distribution(s), draft brochures, kits, devices or other physical
items underway, the status of the items, and the expected result from said distributions.
REQUEST NO. 46: Regarding the conservation guide produced by the Company and
distributed as a supplement to the Idaho Statesman and at events throughout the year, please
provide a breakdown of costs to produce, print and distribute the guide for calendar years 2009,
2010 and 2011 to date.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 5 OCTOBER 5,2011
REQUEST NO. 47: Regarding pilot projects fuded through or on behalf of the R & I
Allance and occurring within UWI's service territory, please provide updates and/or final reports
on any projects that have been completed since January 2009. Also please provide information
on any new or additional projects stared since January 2009, including original date of
inception, ongoing results or determinations, comparisons with other available systems, and cost
benefit analysis, etc.
REQUEST NO. 48: Please explain how the new cis system wil integrate with other
systems curently utilzed by UWI, including PeopleSoft, the current IVR system, Televox
system, and the current SCADA system. Address the impact on service capability and any
associated costs to integrate.
REQUEST NO. 49: Please explain how the new cis system will affect UWI's business
relationship with each of the companies listed on page 12 of Company witness Healy's
testimony, in terms of contractual arrangements and financial expenditures. Identify those
companies that UWI wil no longer be using and any financial penalties associated with
discontinuing that business relationship.
REQUEST NO. 50: Please provide a copy of the following documents referenced in
Company witness Hawthorne's testimony: IT Master Plan; UW self-assessment of the legacy
UBS WINS II system; and TMG's analysis of the cis alternatives available.
REQUEST NO. 51: Please provide the date by which UWI expects the new cis system
to be fully operationaL. Wil the new cis system be integrated with other systems at that time?
Please explain.
REQUEST NO. 52: Please explain how the determination was made for the amount to
be charged to UWI for the new cis system and who made the determination. Please also explain
how UWI's portion of future costs for maintenance or upgrades wil be determined.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 6 OCTOBER 5, 2011
REQUEST NO. 53: Please provide a detailed comparison of the existing, and new cis
system capabilties, with respect to biling accuracy, one stop shopping, call center service level,
scheduling appointments, handling customer complaints, monitoring workflow, customer
communications, and biling services.
Installation of auxilary power at the Columbia raw water pumping facilty (No. 54-60)
REQUEST NO. 54: Please identify by category the amounts paid for all the capital
investments related to the installation of auxilary power at the CWTP raw water pumping
facility (Le. land acquisition, installation of 800 kW diesel generator, etc.).
REQUEST NO. 55: Please explain United Water's rationale in installng an 800-kW
auxilar diesel electric power generation unit at the CWTP raw water pumping facility which is
considerably lower in capacity compared to the recently terminated Alternate Distribution
Agreement (Schedule 46) with Idaho Power that has 1040 k W reserve capacity. In light of the
peak summer power demand in July 2011 at the raw water pumping plant shows 966 kW
(Response to Production Request No. 22, Excel spreadsheet), is the auxilary generation
adequate to meet the potential requirement?
REQUEST NO. 56: Please state the total acreage of the purchased real estate property
purchased from Mr. Marion Smith.
REQUEST NO. 57: Please state the approximate acreage required in the installation of
the auxiliary electric generating unit at the CWTP raw water pumping facilty.
REQUEST NO. 58: Please provide any economic analysis comparing the cost of
owning and operating the newly installed auxilary diesel power unit at the CWTP raw water
pumping station versus the cost of relying on backup electrical service under Idaho Power's
Schedule 46, Alternate Distribution Service.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 7 OCTOBER 5, 2011
REQUEST NO. 59: In page 7 of Rheads testimony, the Company asserts that having
direct control of standby power and associated pumping capacity is much more reliable than
relying on transmission circuits and automatic transfer switches from Idaho Power. Please
provide any additional explanation supporting this claim.
REQUEST NO. 60: For each of the past four years, please state the number oftimes the
Company utilzed the Idaho Power's Alternate Distribution System and the duration for each
occurrence.
REQUEST NO. 61: In the Company's response to Staff Production Request No. 10,
United Water indicated that Project No. C1OC302 includes a diesel generating unit installed at
the Columbia Water Treatment Plant and placed in service in Februar 2011. Please respond to
the following:
a. State the size of the auxilar diesel generating unit.
b. Provide a breakdown by category showing amounts paid for all the capital
investments related to the installation of the auxilary diesel generating unit at the
CWTP (Le. additional land acquisition if any; installation of diesel generator; etc.).
c. Please provide any economic analysis comparing the cost of owning and operating
the newly installed auxilary diesel power unit at the CWTP versus the cost of relying
on backup electrical service under Idaho Power's Schedule 46, Alternate Distribution
Service.
REQUEST NO. 62: Regarding Company witness Healy's Exhibit NO.1 1, Schedule 1,
page 19 (Adjustment to Purchased Power Expense), please provide workpapers and any
associated spreadsheets showing how the ($36,941) - Benefit of Enernoc Demand Response
Program was estimated.
REQUEST NO. 63: Regarding Company witness Car's testimony, page 7 and Exhibit
NO.1 1, Schedule 1, page 15, please provide the following:
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 8 OCTOBER 5, 2011
a. A copy of the most recent annual United Water Report on PCA Balancing Account.
Please attach any worksheets supporting the report.
b. Worksheets supporting the projected deferred PCA balance of$337,483 as of
February 29,2012 approved in Case UWI-W-09-01 as cited in lines 15-16.
c. Worksheets supporting the 2011 deferred pending power expense of$201,845
balance as of February 29,2012 accumulated since March 2010.
Plant Additions and Retirements (No. 64-70)
REQUEST NO. 64: Rheads Exhibit 3, page 1 shows that the in-service date for Project
No. CL 1AOOI-Water Rights is February 201 1. Please provide a copy of all water rights
acquisition related to this project.
REQUEST NO. 65: In reference to Company's response to Staff Production Request
No.7, United Water states that re-drllng the Foxtail well (Project No. CL 1A501) is necessary to
meet domestic and fire protection demands in the event the Spurwng Well is out of service.
Please provide data on the present design capacity of the Spurwing Well (gpm) and the design
capacity of the re-driled Foxtail Well. If the design capacity of the Foxtail well is larger than
the Spurwng Well, wil the extra capacity be used to support future customers? Please explain.
REQUEST NO. 66: As shown in Rheads Exhibit No.3, the cost for re-
driling/developing the Foxtail well is $530,001. Please provide a breakdown of this cost (well
development, pump and motor installation, appurtenances, etc.).
REQUEST NO. 67: In reference to Company's response to Staff Production Request
No.7 concerning the VFD Filtering Project No. Cll C004 (Exhibit No.4), please provide a list
of all Company projects that need to have VFD filters installed, showing those already
completed and cost for each installation, and how many more projects need to be completed.
Please indicate in this list which VFD filtering systems were included in the total cost of
$107,200 as shown Rheads Exhibit 3 (Project No. CIIC004).
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 9 OCTOBER 5, 2011
REQUEST NO. 68: Regarding the Company's Response to Production Request NO.7
(Exhibit 4) and Rheads Exhibit NO.3 about Project No. C1ODI0l, Hil Road 24-inch Main
Phase II, please answer the following:
a. Explain the specific hydraulic capacity and service pressure improvements expected
as a result of this project, and
b. Was the hydraulic capacity improvement (i.e. increased pipeline capacity) also
intended to include provision for serving future customers in the West Main Service
Level of United Water? Please explain.
REQUEST NO. 69: In response to Production Request No.5, the Company provided
Staff an electronic copy of United Water System Master Plan 2009-2015 (UWSMP). Section
7 -7 of the UWSMP recommends that new main be installed along Hil Road between Harison
and Sunset and provides an estimated cost of $167,910 under the Company's Capital
Expenditue Plan (CEP) as shown in Appendix E, page 5 of the UWSMP. Please explain why
the Company deviated from its original plan (Harison to Sunset) and instead constructed the Hil
Road main from Harrison to 36th Street (Project No. C1ODI0l).
REQUEST NO. 70: Reference Rheads Exhibit 8, page 1, concerning Replacement of
Boulder Reservoir Project (CIIE501). Please explain why the Company built a new reservoir to
replace the Boulder Reservoir and such project was never included in the recommended projects
as listed in the Company's CEP.
REQUEST NO. 71: In reference to the Company's response to Staff Production
Request No. 22, please provide an explanation or documentation for the amount shown for diesel
fuel and natural gas of $ 1 5,555 as shown in line 12, Exhibit No.4, Schedule 1, Adjustment for
Purchased Power Expense. The cell formula indicates 13,693.46 + 1795.36 + 66.3.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 10 OCTOBER 5,2011
REQUEST NO. 72: Please provide spreadsheets, workpapers, or other information
showing the derivation of the total adjustment to varable expenses due to volume normalization
as shown in Adjustment No. 29, Exhibit 11, Schedule 1, page 29). Please provide in electronic
Excel format.
REQUEST NO. 73: Please provide the methodology for deriving the number of
customers biled from January 2000 through January 2005 per your response to Production
Request #2. Please provide this in Excel format with all formulas activated.
Dated at Boise, Idaho, thisr day of October 2011.
tC=-~Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Chris Hecht/27-53
Gerry Galinato/54-72
Cathleen McHugh/73
i:umisc:prodreqluwiwl 1.2wscwhgdgch prod req2.doc
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO 11 OCTOBER 5, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF OCTOBER 2011,
SERVED THE FOREGOING SECOND 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.dohertytmunitedwater.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joeCimcdevitt-miler.com
heathertmmcdevitt-miler .com
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdyCihotmail.com
Jo~SECRETAR-
CERTIFICATE OF SERVICE