20111028UWI to Staff 73-75,77,79,80.pdf

McDevitt & Miller LLP
Lawyers
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[phone]
[phone] (Fax)
420 W. Bannock Street T "'0 pM 2' 56
P.O. Box 2564-83ôQJ OC ¿ Q ''i. .
Boise, Idaho 83702
Chas. F. McDevitt
Dean J. (Joe) Miler
October 28, 2011
Via Hand Delivery
Jean Jewell Secreta
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 Responses to the
Commssion Staffs Second Production Request No. 73.
Also enclosed for fig, please fid thee (3) copies of United Water Idaho's Responses to the
Commssion Staffs Four Production Request No's 74, 75, 77, 79, and 80.
Kidly retu a fie stamped copy to me.
Very Truy Yours,
McDevitt & Miet IL
DJM/hh
Encl.
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Dean J. Miller (lSB No.1 968)
Chas. F. McDevitt (ISB No. 835)
McDEVITT & MILER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: [phone]
Fax: [phone]
joet$mcdevitt-miller.com
201 I OCT 28 PM 2: 57
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Attorneysfor United Water Idaho, Inc
BEFORE TH IDAHO PUBLIC UTILITIES COMMSSION
IN TH MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AN CHAGES FOR WATER SERVICE IN
TH STATE OF IDAHO
Case No. UW-W-LL-Ø2
UNITED WATER IDAHO INC'S
RESPONSE TO COMMISSION
STAFF'S SECOND PRODUCTION
REQUESTS
United Water Idaho Inc, ("United Water") by and through its undersigned attorneys,
hereby submits its Responses to the Commission Stafs Second Production Request No. 73.
DATED ths -=day of October, 2011.
UNITED WATER IDAHO INC.
BY~~
. eo i. Mier (lSB No. 1968)
McDevitt & Miler LLP
420 West Banock
Boise, Idaho 83702
P: 208.343.7500
F: 208.336.6912
Attorney for United Water Idaho Inc.
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S SECOND PRODUCTION
REQUESTS- i
CERTIFCATE OF SERVICE
I hereby certify that on the rJ~y of October, 2011, I caused to be served, via the
methodes) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secretar
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, ID 83720-0074
j jewell§puc.state.id.us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Brad M. Purdy
Attorney at Law
2019N. 17" St.
Boise, ID 83702
bmpurdy($hotmail.com
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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McDEVITT & MILLER LLP
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S SECOND PRODUCTION
REQUESTS-2
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UNITED WATER IDAHO INC
CASE UWI-W-ll-02 ZOll OCT 28 PH 2: 57
SECOND PRODUCTION REQUEST OF THE COMMISSI9NSTAFF
LJ T' .~. L, l l~ i E S (; CJ ¡:'/'J 1\/ilf3 ;:~; i () -j'.'t!
Preparer / Sponsoring Witness: Jeremiah Healy
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.
RESPONSE NO. 73:
United Water reads about half its customers monthy, with the reading period about
60 days long. The meter books read in the months of Januar, March, May, July,
September and November are known as the "odd" cycle. The meter books read in
the intervening even months are known as the "even cycle". For the period in
question, on a monthly basis, the billng system provided total billed usage of
either the odd or even cycle. However, the billing system did not identify the
number of customers in the cycle responsible for generating the total biled usage.
The biling system only reported the total customer count, including both cycles. It
was not efficient to manually determine each month how many customers were in
each cycle, so the Company utilzed a ratio of total customers. 48.55% of total
customers were assigned to the odd cycle and 51.45% to the even cycle. My best
recollection is that this ratio was developed by performing a time consuming
analysis of each meter book over a period immediately preceding the biling
system change. The exact methodology/files utilzed to determine the ratio no
longer exists.
The enclosed Excel file titled "73 Usage Per Customer.elsx" indicates the
application of the ratio.
Dean J. Miller (lSB No.1 968)
Chas. F. McDevitt (ISB No. 835)
McDEVITT & MILER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: [phone]
Fax: [phone]
joe(ß,mcdevitt-miller.com
Attorneys for United Water Idaho, Inc
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2m 1 OCT 28 PH 2: 58
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHAGES FOR WATER SERVICE IN
TH STATE OF IDAHO
Case No. UW-W-LL-02
UNITED WATER IDAHO INC'S
RESPONSE TO COMMSSION
STAFF'S FOURTH PRODUCTION
REQUESTS
United Water Idaho Inc, ("United Water") by and though its undersigned attorneys,
hereby submits its Responses to the Commission Staffs Fourh Production Request No's 74, 75,
77, 79 and 80.
DATED this -Zit day of October, 2011.
UNITED WATER IDAHO INC.
BYÙÅWh
Dean J. Miler (lSB No. 1968)
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 FOURTH PRODUCTION
REQUESTS- i
CERTIFICATE OF SERVICE
I hereby certify that on the ~y of October, 2011, I caused to be served, via the
methodes) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secreta
Idaho Public Utilities Commssion
472 West Washigton Street
P.O. Box 83720
Boise, ID 83720-0074
jjewell§puc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Brad M. Purdy
Attorney at Law
2019N. 17" St.
Boise, ID 83702
bmpurdy($hotmail.com
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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C EVITT & MILLER LLP
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S FOURTH PRODUCTION
REQUESTS-2
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UNITEDWATERIDAHO~Nf ., ~" .
CASE UWI-W-ll-02 Jll, UC i 2ö Pr1 2.58
THIRD PRODUCTION REQUEST OF THE COMMI~~~QNdSIAFF
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Preparer: P. Herbert
Sponsoring Witness: P. Herbert
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.
RESPONSE NO. 74
See response to Production Request No. 16.
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UNITED WATER IDAHO ~çorT 2R Pt'1 2: 58
CASE UWI-W-II-02 TJì, v ~
THIRD PRODUCTION REQUEST OF THE £Rm~~~~~~J~FF
Preparer: P. Herbert
Sponsoring Witness: P. Herbert
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).
RESPONSE NO. 75
Supporting data can be found in the research paper North American Water Usage Trends Since
1992, which was prepared by the Center for Infrastrctue Research at the University of
Louisvile and was jointly sponsored by the Water Research Foundation and the U.S.
Environmental Protection Agency. The paper is enclosed as a PDF file titled "#75 Water Usage
Trends.pdf'.
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UNITED WATER IDAHO INC.
CASE UWI-W-L1-02 i311 OCT 28 P~l 2= 58
THIRD PRODUCTION REQUEST OF THE COMl\lSi~lQ:~rSJ',AFF
tJ;r~L:i-~rl 'rES' C:CJrt;:j f~i, ¡:;:3~:ú¡();\\l
Preparer: P. Herbert
Sponsoring Witness: P. Herbert
REQUEST NO. 77:
Regarding Exhibit No.5, Schedule 4, section Rl, please provide justification for using ~ of
growth (Colum 4) in adjusting for customer growt.
RESPONSE NO. 77
The growth represented by adjustment Rl is growt during the test year from 4/30/2010 to
4/30/2011. Such growth would have occurred throughout this 12 month period. Therefore, we
can assume that some of the growth would already be reflected in the biling determinants in
Schedule 3, which reflects actual bils during the test year. On average, we assumed that half of
the growth was not reflected in Schedule 3 and needs to be added in adjustment Rl.
F~ECE!VFn
UNITED WATER IDAHO INC.
CASE UWI-W-l1-02 23l! OCT 28 Pt'î 2: 58
THIRD PRODUCTION REQUEST OF THE COMMISS.lQ~:STAFF~ !,...) !l ¡ i;'i.,l ¡ ';_,/ ;'___' c.," c'."
L ¡ 'r ¡ E: ,SC; t) h:-l ¡\r; i :~~~) J ()
Preparer/Sponsoring Witness: Greg Wyatt
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.
RESPONSE NO. 79
The averages in question were provided to me by Witness Herbert and are shown on the enclosed
PDF file titled "#79 Avg Anual Bil Rev.pdf'. The total present and proposed residential
averages are the result of adding the metered and unetered revenue amounts together in each
case (from Herbert's Exhibit No.5, Schedule 1) to derive total residential revenue as shown in
the enclosed fie, and then dividing the totals by the pro-forma number of residential customers
(74,492) to obtain the resulting averages of$350.98 and $420.89.
UNITED WATER IDAHO INC.
CASE UWI-W-L1-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Scott Rhead
REQUEST NO. 80
In reference to Rhead's testimony (page 5) concernng 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 J.R. 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
facilty.
RESPONSE NO. 80
a. The facilties that are jointly owned are referred to in the Surnse Valley Pump System
Ownership Agreement and Surnse Valley System Operation & Maintenance Agreements as
Facilty A.
The following facilties are jointly owned:
a. Pump Station Site - - earhwork and gravel
b. Pump Station Building - - wet well ladders, traveling screen, electrcal outlets,
security and fire alar sensors, electrcal conduit and junction boxes appurenant to those
electrcal facilties which are jointly owned, light switches, controls and sensors
appurenant to the space heaters and ventilation equipment, switchgear and motor control
equipment appurenant to the traveling screen and ventilation equipment.
The ownership percentages for Facilties A are as follows:
URited Water Idaho 50%
Micron 19.23%
Surrise Valley 5.19%
Simplot 25.58%
b. The percent share of the cost of operating the pumping facilty are the same as the Ownership
percentages as defined in Facilty A.
c. In response to this request see the enclosed files listed below:
#80 Surrise Valley Pump System Operation & Maintenance Agreement.pdf
#80 Surnse Valley Pump System Ownership Agreement.pdf