20111021Staff to UWI 74-80.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
RECEIVED
20 It OCT 2 I PH I: 4 1
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
)
)
) THIRD 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 MONDAY,
NOVEMBER 14,2011.
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
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 OCTOBER 21,2011
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 IDAPA
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.
The following are in regards to Paul Herbert's testimony.
REQUEST NO. 74: Please provide all electronic fies, worksheets, tables and schedules
related to the development of Exhibit No.5, Schedules 1 through 5. Please provide in Excel
format with formulas intact.
REQUEST NO. 75: Please provide a copy of all the studies cited in Paul R. Herbert's
testimony page 11, lines 11 through 29. Please provide in electronic format (if possible).
REQUEST NO. 76: Regarding Exhibit No.5, Schedule 4, please provide the
methodology used to project the number of customers as of 2/28/20 12. Please provide in Excel
format with formulas intact.
REQUEST NO. 77: Regarding Exhibit No.5, Schedule 4, section Rl, please provide
justification for using Yí of growth (Column 4) in adjusting for customer growth.
REQUEST NO. 78: In reference to Mr. Wyatt's testimony regarding the installation of
a new $1.6 milion green sand fiter at the Hilton well facility for removing iron and manganese,
please respond to the following:
a. It is Staff s understanding that the Company was already using phosphate treatment to
improve water quality (iron and manganese) from Hilton well. Please explain why
the Company decided to change the process of treatment and invested $1.6 milion for
the new green sand fiter facilty.
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 OCTOBER 21,2011
b. Please provide the number of customer complaints in the area served by the Hilton
well for the last 5 years concerning iron and manganese.
c. Please provide data on the total anual cost savings for the elimination or reduction of
phosphates and other chemicals previously used for water treatment as a result of
installng the green sand filtration system.
d. Please provide water quality data (before and after the installation of green sand
filtration system) from the Hilton well, paricularly iron and manganese.
REQUEST NO. 79: In reference to Mr. Wyatt's testimony, page 17, lines 11 and 16.
Please provide a copy of your worksheet for calculating the $350.98 average anual cost for
residential customer and the proposed average bil of $420.89.
REQUEST NO. 80: In reference to Rhead's testimony (page 5) concerning joint
ownership and operation of the Columbia Raw Water Pumping facilty with Micron Technology
and J.R. Simplot Company, please provide the following:
a. Percent share of ownership (United Water, Micron Technology and lR. Simplot).
b. Percent share of the cost of operating the pumping facilty.
c. A copy of any agreement concerning the joint ownership or operation of the pumping
facility.
Dated at Boise, Idaho, this ,ll ~f- day of October 2011.
.£¿~
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Cathleen McHugh/74-77
Gerry Galinato/78-80
i:umisc:prodreqluwiwl I .2wscmgdg prod req3.doc
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 OCTOBER 21,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21st DAY OF OCTOBER 2011,
SERVED THE FOREGOING THIRD 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
HARRNGTON PARK, NJ 07640
E-MAIL: Kevin.doherty(iunitedwater.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(imcdevitt-miler.com
heather(imcdevitt-miler .com
BRAD M PURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(ihotmail.com
,b~~
SECRER
CERTIFICATE OF SERVICE