20111021UWI to Staff 44,54,56,57,59,64-66,69,70.pdf

McDevitt & Miller LLP
Lawyers
RECEI D
[phone]
[phone] (Fax)
420 W. Bannock Street
P.O. Box 2564-83701 2011 OCT 21 PH 3: 09
Boise, Idaho 83702
UTI
Chas. F. McDevitt
Dean J. (Joe) Miler
October 21,2011
Via Hand Delivery
Jean Jewell Secreta
Idaho Public Utities Cotnssion
472 W. Washigton St.
. Boise, Idaho 83720
Re: Case No. UW-W-11-02
General Rate Case Filing
Dear Ms. Jewell:
Enclosed for fig, please fid thee (3) copies of United Water Idaho's Responses to the
Cotnssion Staffs Second Production Request No's 44, 54, 56, 57, 59, 64, 65, 66, 69, and 70.
Kidly retu a fie stamped copy to me.
Very Truy Yours,
McDevitt & Mier IL
~\U
Dean J. Mier
DJM/hh
Encl.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Greg Wyatt
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 El-Ada from those distributed by UWI directly to customers.
RESPONSE NO. 44:
El-Ada is the distribution center for kits for the UW Cares Program. Under the UW Cares
program, United Water Idaho has supplied indoor and outdoor kits to EI-Ada for distribution to
UW Cares program recipients. Since the program's inception, the Company has supplied El-Ada
(at their request) with 175 indoor kits and approximately 150 outdoor kits. The Company has
requested El-Ada to provide the breakdown of kits distributed to customers by year in order to
respond to this Production Request, but as yet they have not been able to provide the data. If the
breakdown by year is provided by El-Ada, the Company will submit that data.
The free outdoor water conservation kits distributed by United Water Idaho directly to customers
is considered a different program and tracked separately.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 54:
Please identify by category the amounts paid for all the capital investments related to the
installation of auxilar power at the CWTP raw water pumping facilty (Le. land acquisition,
installation of 800 kW diesel generator, etc.).
RESPONSE NO. 54:
The costs are detailed and sumarzed below:
C1OC302. AUXILIARY POWER FOR COLUMBIA
310200. RIVER PUMP STATION GENERATOR
TOTAL
$ 35,295.36
$ 636.65
$ 11.69
$ 104.55
$ 1,09.72
C09AOO5. MARION SMITH LAND PURCHASE
3032CX. LAND PURCHASE
3032CXA. LAND SURVEY
3032CXB. PROPERTY APPRAISAL
3032CXC. ENVIRONMENTAL ASSESSMENT
2CXD.
TAL
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 56:
Please state the total acreage of the purchased real estate property purchased from Mr. Marion
Smith.
RESPONSE NO. 56:
The Marion Smith propert purchase was a total of22.04 acres.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 57:
Please state the approximate acreage required in the installation of the auxilar electric
generating unit at the CWTP raw water pumping facility.
RESPONSE NO. 57:
The property required for the auxiliar electric generating unit was 22.04 acres and was only
available to purchase in its entirety from Marion Smith.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 59:
In page 7 of Rhead s 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.
RESPONSE NO. 59:
The following reasons support Witness Rhead's assertion 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. First, all four power feeds, two
serving the River Pump Station and two the Columbia Plant, originate from Idaho Power's
Amity power substation. A major event disrupting power available from this substation
(lightning, fire, mechanical failure, etc.), or a regional power outage, would put all electrical
power feeds to the Columbia facilties out of power. Second, these switches are unique,
expensive, and not employed on a regular basis by Idaho Power. Consequently, the power
company does not maintain an inventory of replacement units or pars for repair in the event
there was a failure (confirmed per a telephone conversation with Bruce Cleveland, Idaho Power
Company, 10/19/11).
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 64:
Rheads Exhibit 3, page I shows that the in-service date for Project No. CIIAOOI-Water Rights
is February 2011. Please provide a copy of all water rights acquisition related to this project.
RESPONSE NO. 64:
In response to this request is the enclosed PDF fie titled "#64 Boise Valley Irrgation
Agreement. pdf".
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 65:
In reference to Company's response to Staff Production Request No.7, United Water states that
re-drillng the Foxtail well (Project No. CIIA501) is necessar 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 Spurng Well (gpm) and the design capacity of the re-driled
Foxtail Well. If the design capacity of the Foxtail well is larger than the Spurng Well, will the
extra capacity be used to support future customers? Please explain.
RESPONSE NO. 65:
In response to your request is the information listed below:
Spurwing design capacity: 2,000 gpm
Foxtail design capacity: 1,000 gpm
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
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 ofthis cost (well development, pump and motor
installation, appurenances, etc.).
RESPONSE NO. 66:
In response to your request is the information listed below:
New Foxtail Pumphouse
Dril New Foxtail Well
$126,308
$227,449
$152,519
$5,649
$4,519
$13,557
Pump & Electrical Equipment
Treatment Equipment
Yard Piping
Telemetry Equipment
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
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 $167,910 under the Company's Capital
Expenditure Plan (CEP) as shown in Appendix E, page 5 of the UWSMP. Please explain why
the Company deviated from its original plan (Harison to Sunset) and instead constructed the Hil
Road main from Harrison to 36th Street (Project No. CIODI01).
RESPONSE NO. 69:
On page 6 of Appendix E of the UWSMP a new reservoir was listed, C 1 OEOO 1 - 36th StlWMSL
Storage, at an estimated cost of$I,780,000. This project was intended to achieve the same goal
as the new transmission main in Hil Road. We were unable to secure property at the correct
elevation for the reservoir. Our next alternative was to ru the 24-inch transmission main down
Hil Road from Harison Boulevard to 36th Street (Project No. C1ODIOl). This project also
resolved the low pressure issues along Hil Road from Harson to Sunset. See the enclosed PDF
fie titled "#69 Hil Rd. Preliminar Report.DEQ Approved.pdf'.
UNITED WATER IDAHO INC.
CASE UWI-W-II-02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 70:
Reference Rhead's Exhibit 8, page 1, concerning Replacement of Boulder Reservoir Project
(C II E50 1). 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.
RESPONSE NO. 70:
The reservoir inspection that revealed the need for and culminated in the decision to replace the
Boulder Reservoir was made on April 14,2009 and the final draft of the Master Plan was dated
March 26,2009, three weeks before this inspection.