20141016Staff 1-15 to UWI.pdf

KARL KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6864
Street Address for Express Mail:
472 W , WASHINGTON
BOISE, IDAHO 83702.5918
Attorneys for the Commission Staff
IN THE MATTER OF UNITED WATER IDAHO
INC.'S AND BRIAN SUBDIVISION WATER
USERS ASSOCIATION'S APPLICATION TO
ALLOW UNITED WATER TO TAKE OVER
BRIAN WATER'S DOMESTIC WATER
SYSTEM.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. trWI-W-14-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
UNITED WATER IDAHO INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl Klein, Deputy Attorney General, requests that United Water Idaho Inc. (United Water)
provide the following documents and information as soon as possible, but no later than
THURSDAY, OCTOBER 30, 2014.t
This Production Request is to be considered as 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
' Staffis requesting an expedited response.
attorney at [phone].
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO
If responding by this date will be problematic, please call Staff s
ocToBER 16,2014
the person preparing the documents. Please identifu the name, job title, location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide copies of United Water's water treatment
alternatives, calculations, and analysis for the Brian Subdivision Water Users Association
(.'BSWUA") with the formulas, macros, and links activated, including copies of all files linked.
REQUEST NO.2: Please explain why connecting and transferring BSWUA's water
systems to United Water:
(a) Specifically benefits United Water's customers; and
(b) Is for the public convenience and necessity.
REQUEST NO. 3: Please provide a map showing the service area for State of Idaho
Certificate of Public Convenience and Necessity (i.e., CPCN No. 143) as that service area would
be amended if the Application is approved.
REQUEST NO. 4: Please provide an explanation, supporting diagrams, estimated fiscal
values, and calculations that demonstrate the anticipated benefits from the proposed looped
system configuration that extends United Water's system to Brian Subdivision and ultimately to
the other water service areas that United Water serves to the west of Brian Subdivision.
REQUEST NO. 5: Please provide the following:
(a) an explanation of how United Water estimated the proposed capital investments,
construction, and operation costs (i.e., actual bids submitted in response to a proposal
request);
(b) an Excel-file copy of the actual values and calculations supporting both the
Application's cost estimates and the cost estimates for the analyzed alternatives in an
Excel file with the formulas activated; and
(c) the proposed construction method and payment methods,
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO ocroBER 16,2014
REQUEST NO.6: Please provide the basis for the construction cost estimates,
including labor rates and unit prices for materials.
REQUEST NO. 7: Please provide a copy of United Water's most recent Water System
Master Plan, if the Master Plan has been updated since 2009. To the extent not discussed in the
Master Plan, please provide copies of other reports or plans that describe United Water's
infrastructure improvement/replacement pro grams.
REQUEST NO. 8: Please provide the backup documentation for the Capital Structure
and Component Cost as stated in Exhibit Nos. 3 and 4 from Mr. Wyatt's direct testimony.
REQUEST NO.9: Please explain:
(a) O&C in Exhibit No. 2; and
(b) Why O&C is calculated in Mr. Wyatt's direct testimony at l0o/o on Exhibit No. 2,
pages 2,3 and 4, and calculated at 15o/o on Exhibit No. 2, page 5.
REQUEST NO. 10: Please define what is included in projects' overhead rate and
provide the rationale for why that rate is 12.51%. Please provide a schedule documenting the
125t%.
REQUEST NO. 11: Please provide the construction schedule with budgeted expenses at
each step.
REQUEST NO. 12: Section 3 of the Agreement for Connection and Transfer of Water
Systems ("Agreement") provides that certain costs will be recovered from existing customers of
the BSWUA. See Exhibit C, page 4. Does the reference to "existing customers" mean all
BSWUA customers of record as of the closing date of the transfer of the Tangible and Intangible
Property as specified in Section l0 of the Agreement? See Exhibit C, page 8. If not, please
explain how o'existing customers" will be identified.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO ocToBER t6,2014
REQUEST NO. 13: If a former BSWUA customer discontinues service (closes an
account) with United Water after United Water assumes system ownership and a new applicant
signs up for service (opens an account) with United Water at that location, will the new customer
be responsible for paying the appropriate bi-monthly surcharge from the date of sign-up
forward? Or does the obligation to pay the surcharge remain with the prior customer? Please
explain.
REQUEST NO. 14: Does United Water intend to pro-rate the surcharge on bills that
cover less than a full billing period due to opening or closing an account? Please explain.
REQUEST NO. 15: There are homes and lots in the Brian Subdivision that currently are
not receiving service from BSWUA. If a party asks United Water to connect service after United
Water assumes system ownership, will United Water require the customer to pay the appropriate
bi-monthly surcharge from the date the customer is connected to the system and is receiving
water? May the newly-connected customer opt to pay a one-time fee based on net present value
in lieu of paying the monthly surcharge? Please explain.
DATED at Boise,Idaho, this lu+! day of October2014.
y)l4/l--
Karl Klein
Deputy Attorney General
Technical Staff: Johanna Bell/l-7
Joseph Terry/8-l I
Chris Hecht/I2-15
i:umisc:prodreq/uwil4.lkkjbjtch prod req I to UWI
FIRST PRODUCTION REQUEST
TO LINITED WATER IDAHO 4 ocroBER 16,20t4
CERTIFICATE OF SERVICE
I HEREBy CERTIFy rHAT I HAvE THIS l6rH DAy oF ocroBER 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO UNITED WATER IDAHO INC., IN CASE NO.
UWI.W-14.0I, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
GREGORY P WYATT
UNITED WATER IDAHO INC
PO BOX 190420
BOISE TD 837T9-0420
EMAIL: [e-mail]
RICHARD JUENGLING
PRESIDENT
BRIAN SUB WATER USERS
5855 E WOOD PLACE
BOISE ID 83716
EMAIL: [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK
BOISE ID 83702
EMAIL: [e-mail]
CERTIFICATE OF SERVICE