20111109Staff to UWI 81-92.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
iun NOV -9 ~M \0: 04
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-11-02
)
)
) FOURTH 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, NOVEMBER 30, 2011.
This Production Request is continuing, and United Water is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will 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
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 NOVEMBER 9,2011
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 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.
The following questions refer to the direct testimony of Greg Wyatt.
REQUEST NO. 81: How much of an increase in customer charges (fixed charges)
would be necessar in order to alleviate upward rate pressure caused by declining use per
customer as discussed on page 6 of Greg Wyatt's testimony?
REQUEST NO. 82: On pages 8-12 of Greg Wyatt's direct testimony, he discusses the
Company's proposal for an anual rate adjustment. Please provide some estimates to
approximate the magnitude of anual rate changes that could occur under the proposed anual
rate adjustment (scope of rate variabilty as discussed on page 12, line 23 - page13, line 1).
REQUEST NO. 83: To what does UWI attribute the increase in O&M costs per
customer since 2007 as shown in the char on page 13? What caused the notable decreases in
O&M per customer in 2001, 2004 and 2006?
REQUEST NO. 84: How is the cost of the R&I Allance allocated between the five
international companies listed on page 20, lines 13-15 of Wyatt's direct testimony? How is
United Water Resources' share allocated among various UWR companies, including United
Water Idaho's anual share of$192,662?
REQUEST NO. 85: Please list the amounts of United Water Idaho's contributions to the
R&I Allance for each of the past six years.
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 NOVEMBER 9,2011
REQUEST NO. 86: For each of the past six years, please identify each R&I Allance
project in which UWI has been a direct paricipant. For each of those projects identified, please
list the cost of the project.
REQUEST NO. 87: What amounts ofR&I Allance funds are allocated to each of the
"themes" listed in Wyatt's testimony on page 22, lines 4-9?
REQUEST NO. 88: Please list the amounts ofR&I Allance fuds allocated to each of
the projects discussed on pages 22-23 of Wyatt's testimony.
REQUEST NO. 89: Explain how R&I Allance projects are selected for funding.
REQUEST NO. 90: Please clarify whether the $30,721 paid to the American Water
Works Association Water Research Foundation was paid by United Water Resources or United.
Water Idaho (page 23, line 22 of Wyatt's testimony).
REQUEST NO. 91: What benefits does UWI receive through its membership in the
A WWA Water Research Foundation? Please list any specific projects or research that has
directly benefitted UWI in the past.
REQUEST NO. 92: One of the recurng public comments expressed by customers in
this case is that UWI should "tighten its belt" in the current diffcult economy. Has UWI
adjusted its budgets for capital expenditures, deferred capital additions, deferred maintenance,
reduced contributions for research, reduced discretionar expenses, or implemented any other
similar measures not already addressed in Wyatt's testimony that directly address customers'
concerns? If so, please describe.
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 NOVEMBER 9, 2011
Dated at Boise, Idaho, this qti day of November 2011.
v:~
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Rick Sterling/81-92
i:umisc:prodreq/uwiwl 1 .2wsrps prod req4.doc
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 NOVEMBER 9, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF NOVEMBER 2011,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO UNITED WATER IDAHO INC., IN CASE NO.
UWI-W-11-02 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.doherty(Ðunitedwater.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(Ðmcdevitt-miler.com
heather(Ðmcdevitt -miler .com
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(Ðhotmail.com
J,~SECRETÁ --
CERTIFICATE OF SERVICE