20111109UWI to Staff 53,76,78.pdf

McDevitt & Miller LLP
Lawyers RECEIVED
[phone]
[phone] (Fax)
420 W. Bannock StroMi i NOV -8 PM ~: 2 l
P.o. Box 2564.8370i"
Boise, Idaho 83702
Wa Hand Delivery
Jean Jewel, Secreta
Idaho Public Utities Commssion
472 W. Washigton St.
Boise, Idao 83720
Re: Case No. UWI-W-11-02
General Rate Case Fil
Dear Ms. Jewell:
November 8, 2011
Chas. F. McDevitt
Dean J. (Joe) Miler
Enclosed for fig, please fid thee (3) copies of United Water Idaho's Responses to the
Commssion Staffs Second Production Request No. 53.
Also enclosed for fig, please fid thee (3) copies of United Water Idaho's Responses to the
Commssion Staffs Thd Production Request No's 76 and 78.
Kidly retu a fie staped copy to me.
DJM/hh
Encl.
Very,!ruy Yours,
McDevitt & Mier Ii
~~
Dea J. Miller (lSB No. I 968)
Chas. F. McDevitt (lSB No. 835)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: [phone]
Fax: [phone]
joecæcdevitt-miller.com
Qr-CE'" i: .1_o
ZOI I ~IOV -8 PM 4: 21
Attorneys for United Water Idaho, Inc
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF TH APPLICATION
OF UNITED WATER IDAHO INC. FOR
AUTHORIY TO INCREASE ITS RATES
AN CHAGES FOR WATER SERVICE IN
THE STATE OF IDAHO
Case No. UW..W-LL-02
UNITED WATER IDAHO INC'S
RESPONSE TO COMMSSION
STAFF'S SECOND PRODUCTION
REQUESTS
United Water Idaho Inc, ("United Water") by and though its undersigned attorneys,
hereby submits its Responses to the Commssion Stafs Second Production Request No. 53.
DATED ths ~day of November, 2011.
UNITED WATER IDAHO INC.
BY~\ll
. Dean J. Miler (ISB 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
CERTIFICATE OF SERVICE
I hereby certify that on the ~y of November, 2011, I caused to be served, via the
methodes) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secreta
Idaho Public Utilties Commssion
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
j jewell(ßuc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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Brad M. Purdy
Attorney at Law
2019 N. 17" St.
Boise, ID 83702
bmpurdy~otmail.com
Hand Delivered ..~
U.S. Mail ';
Fax ..~
Fed. Express ..~
Email ..~
BY:~~
McDEVITT & MILLER LLP
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S SECOND PRODUCTION
REQUESTS-2
,.
UNITED WATER IDAHO INC.
CASE UWI..W..LL..02
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Lynne Allaker, VP Customer Service
Sponsoring Witness: Greg Wyatt
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.
RESPONSE NO. 53:
Enclosed is an Excel fie titled "#53 UBS WINS and CC&B Functional Comparison.xlsx" which
includes the detailed functional comparson of the existing, and new cis systems. This
fuctional comparson was completed as par of the selection phase of the project. The
functional requirements were a combination of United Water's collated requirements as well as
the functional requirements gathered by our consultant at the time (5 Point Parners, formerly
TMG). Each requirement was rated as follows:
UW Rating of Requirement: 15 - Critical, 10 - Mandatory, 5 - Nice-to-Have, 0 - No Impact
Each CIS system was then assessed against each requirement and the total score calculated by
multiplying the rating score by the system assessment score. Although this comparison provides
significant detail, it captues the comparison of capabilties of the two systems in question as
required in this request.
During Staff s on-site visit of October 20, 2011 many of the comparisons requested above were
demonstrated live on the two systems. If Staff requires further demonstrations of the new CC&B
system, please advise.
Dea J. Miller (lSB No. 1968)
Chas. F. McDevitt (lSB No. 835)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: [phone]
Fax: [phone]
joecæcdevitt-miller.com
R..C E "/',. ",,. r . '1\ ¡"!,':: .- '- .~L ":'.' '.~ -,:""': .+-
ZOLI NOV -8 P~l 4: 21
Attorneys for United Water Idaho, Inc
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF TH APPLICATION
OF UNTED WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AN CHAGES FOR WATER SERVICE IN
THE STATE OF IDAHO
Case No. UW-W-LL-02
UNITED WATER IDAHO INC'S
RESPONSE TO COMMISSION
STAFF'S TmRD PRODUCTION
REQUESTS
United Water Idaho Inc, ("United Water") by and though its undersigned attorneys,
hereby submits its Responses to the Commission Stas Third Production Request No's 76 and
78.
DATED this ~day of November, 2011.
UNITED WATER IDAHO INC.
BY~\W
- ~ J. Miler (lŠB 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 THI PRODUCTION
REQUESTS- i
CERTIFICATE OF SERVICE
I hereby certify that on the ~y of November, 2011, I caused to be served, via the
methodes) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secreta
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
jjeweiicæpuc.state.id. us.
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Brad M. Purdy
Attorney at Law
2019 N. 17" St.
Boise, ID 83702
bmpurdy~otmail.com
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
xù
..~
..~
..~
..~~ù
..~ù
BY:_~v.
McDEVITT & MILLER LLP
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S TIDRD PRODUCTION
REQUESTS-2
UNITED WATER IDAHO INC.
CASE UWI..W..ll..02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jeremiah Healy
REQUEST NO. 76:
Regarding Exhibit No.5, Schedule 4, please provide the methodology used to project the number
of customers as of2/28/2012. Please provide in Excel format with formulas intact.
RESPONSE NO. 76
Please see the accompanying Excel fie titled "#76 Customer Projections.xlsx". This fie was
provided to Witness Herbert by the preparer. The file contains actual customer counts by class
through June 201 I. For the remainder of201 I and all of2012, customer counts are growth
projections used in the planing process.
~,.
1
UNITED WATER IDAHO INC.
CASE UWI..W..11..02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Greg Wyatt
REQUEST NO. 78:
In reference to Mr. Wyatt's testimony regarding the installation of a new $ 1.6 milion green sand
filter at the Hilton well facilty 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.
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 tota 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 fitration system.
d. Please provide water quality data (before and after the installation of green sand
fitration system) from the Hilton well, paricularly iron and manganese.
RESPONSE NO. 78
a.
Since 1993, the water at Hilton well has reported an average raw water manganese level of 0.18
mgI and an iron level of 0.03 mgI. For more than twenty year, The Company has applied
phosphate treatment to sequester the manganese at Hilton with marginal success. Phosphate
addition generally works well for treating iron, but is not as effective at sequestering manganese..
Due to the history of limited success using phosphate to sequester manganese, coupled with the
volume of complaints from customers in the area we decided the most effective long-term
solution was the installation of the green sand filtration system for the complete removal of the
iron and manganese.
In November 2010, following the new system installation, we sureyed customers in the Hilton
impact area who had previously called with discoloration problems. Of the seventy three (73)
sureys mailed, twenty five (25) customers responded. Following are the thee questions on the
surey and a sumary of the results.
.--
1. Prior to July 20 I 0, did you have problems with discolored water or staining at your
residence!business7
. Twenty four out of the twenty five respondents (96%) marked that they had
experienced discoloration problems prior to July 2010.
2. Has the quality of your water related to discoloration changed since July 20107
. Twenty one out of twenty five respondents (84%) marked their water quality has
changed since July.
3. Is your water quality now worse, the same, or better since July 20107
. Nineteen replied better (76%), four rated it as the same (16%), and two said it was
now worse (8%) due to a chlorine odor.
A space for additional comments was also provided on the surey and resulted in a wide varety
of results, mostly positive. Following are the positive comments received from customers:
. Than you!
. We have lived in the same home for 47 years. We have had a rust problem in the
water the entire 47 years. Since July 2010, the rust problem is gone.
. Than you - Than you! I have messed with brown water for 21 years. Now it is
great!
. Than you!!! We feel better about drinking/using the water now.
. Better water pressure. Thans!
. Good job. Than you!
. One of our homes had so much discoloration that we had to change water heaters.
The water is better now.
. My whole house water fiter was last changed in mid July. It lasted five months and
wasn't even as dirty as it usually gets in six weeks durng the sumer. Yea!
b.
Following is the number of discolored water (DW) complaints per year from the Hilton impact
area.
YEAR HILTONDW
COMPLAINTS
2006 83
2007 81
2008 110
2009 84
2010 74
c.
In 2010 the Company installed a greensand filtration system at the Hilton Well site which
eliminated use of phosphate at this facilty, and reduced chemical costs by $19,700 compared to
2009 use, which savings is already reflected in this present case.
d.
Hilton water quality results before vs. after installation of the green sand fitration system.
Raw Water (Before)Treated (After)
Fe Mn Fe Mn
.03 0.185 -eO.OL -e0.005