20150618Staff 1-22 to UWI.pdf

DONALD L. HOWELL, II
DAPHNE HUANG
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 3 34-03 12t334-0318
IDAHO BAR NOS ,336618370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attomeys for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
UNITED WATER IDAHO INC FOR
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR WATER SERVICE IN THE
STATE OF IDAHO.
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CASE NO. UWI-W-15-01
FIRST PRODUCTION
RE,QUEST OF THE
COMMISSION STAFF TO
UNITED WATER IDAHO INC.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Donald L. Howell and Daphne Huang, Deputy Attorneys General, request that United
Water provide the following documents and information as soon as possible, or no later than
THURSDAY, JULY 9,2015
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
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO JUNE 18,2015
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 a copy of or access to all internal and external audit
reports, work papers, etc. for the years 2011 to present.
REQUEST NO. 2: Please provide a schedule showing all plant additions completed
from Jan l,20ll through Dec. 30,2014 include the cost, retirement amounts associated with the
project, cost of removal, salvage, and Contributions In Aid of Construction (CIAC) associated
with that project, similar to Mr. Greaves' Exhibit No. 3. In addition please break out the CIAC
by additions.
REQUEST NO.3: Please break out the $3,644,000 in CIAC shown in Greaves' Exhibit
No. 2 by project ID.
REQUEST NO. 4: Please provide details of all goal targets and criteria requirements
comprising the Company's Short Term Incentive Plan as mentioned in Cary's Direct Testimony
on page 4, and show how much incentive bonus was applied to each criteria.
REQUEST NO. 5: Please provide details explaining the safety and compliance training
goals for the Company's Non-Exempt Incentive Program, as mentioned in Cary's Direct
Testimony on page 4, and show how much incentive bonus was applied to each criteria.
REQUEST NO. 6: Please provide the latest bargaining agreements for the bargaining
employees.
REQUEST NO. 7: Please explain and provide documentation showing why the pension
expense in the test year was about half the amount from the previous year.
REQUEST NO. 8: Please provide copies of the three most recent completed Forms
5500, including the attachments and schedules for all pension plans.
FIRST PRODUCTION REQUEST
TO LINITED WATER IDAHO 2 JLINE 1 8, 20 15
REQUEST NO. 9: Please provide a copy of the Tower Watson Report mentioned in
Cary's Testimony on page 6.
REQUEST NO. 10: Please provide a copy of or access to the latest contract for
dental, and group life insurance.
REQUEST NO. 1l: For all expenses allocated from the parent and affrliated companies,
please provide a schedule showing the total revenue, the allocated amount to each entity, the
allocation percentage, and methodology used to determine the allocation amount.
REQUEST NO. 12: Please provide a listing of services the Company provides to other
affiliates of the parent company, (i.e. United Water Missouri, etc.), with any cost amounts
allocated to those company units.
REQUEST NO. 13: Please provide the actual postage costs by year from the year
ending Dec 31,2011 through the year ending Dec 31,2014.
REQUEST NO. 14: Please provide the most recent insurance agreements for general
corporate insurance.
REQUEST NO. 15: Please provide invoices making up the $347,390 in test year
general corporate insurance expense.
REQUEST NO. 16: Please provide a break out of vehicle expenses by the same
categories used in Cary's Exhibit 10, Schedule 1, page l6,by year for the years ending Dec 31,
201I through2}l4.
REQUEST NO. 17: Please provide a schedule showing the actual expenses incurred in
litigating rate cases for the previous three rate cases and any unamortized balances remaining.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO JI.INE 18,2015
REQUEST NO. 18: Please provide a listing of all organizations the Company
participates in and the costs of participating in those organizations (e.g. NAWC, IACI, R&I
Alliance, etc.).
REQUEST NO. 19: Please provide a copy of the letter dated June 3,2014 from Idaho
State Tax Commission referencing the assessed value the Company. Please provide a copy of the
same information for 2015.
REQUEST NO. 20: Please provide a copy of the annual operator statement for the year
ending Dec 31,2014 filed with the Idaho State Tax Commission.
REQUEST NO. 21: Please provide line item journal entries making up the Contract
Professional amount of the annual report for the years ending Dec 31,2011,2012,2013, and
2014.
REQUEST NO. 22: Please provide invoices for purchased power expense for the
months of August, September, October, and November of 2014.
DATED at Boise,Idaho, this / #O^rof June 2015.
Technical Staff: Joe Terry Q-22)
i:umisc:prodreq/uwi I 5. I dhdjhrpsjbmechjbojtphtcmmac prod req I to UWI
FTRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 JLINE I8,2015
CERTIFICATE OF SER\TICE
I HEREBY CERTIFY THAT I HAVE THIS 18ft DAY OF JUNE 2015, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF' THE COMMISSTON
STAF'F TO UNITED WATER IDAHO INC, IN CASE NO. UWI-W-15-01, By
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DEAN J MILLER
MoDEVITT & MILLER LLP
42OW BANNOCK
BOISE ID 83702
E-MAIL: [e-mail]
KEVIN H DOHERTY
UNITED WATER MANAGEMENT
AND SERVICES CO
2OO OLD HOOK ROAD
HARRINGTON PARK NJ 07640
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE