20150625Staff 23-66 to UWI.pdf

DONALD L. HOWELL, II :
DAPHNE HUANG
DEpUTyATToRNEyS GENERAL "r "JI.l l,- f.:i I: IE
IDAHO PUBLIC UTILITIES COMMISSION -]
PO BOX 93720 , ; : -l,, , ,. ,. , .
BOISE, IDAHO 83720-0074
(208) 3 34-03 121334-03 t8
IDAHO BAR NOS .336618370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
UNITED WATER IDAHO INC FOR ) CASE NO. UWr-W-15-01
AUTHORITY TO INCREASE ITS RATES AND )
CHARGES FOR WATER SERVICE IN THE ) SECOND PRODUCTION
STATE OF IDAHO.) REQUEST OF THE) coMMrssroN STAFF To
) UNITED WATER IDAHO INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Donald L. Howell and Daphne Huang, Deputy Attomeys General, request that United
Water provide the following documents and information as soon as possible, or no later than
THURSDAY, JULY 16,2015
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.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO JUNE 25,20T5
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. 23: Please provide the monthly billing data, monthly Palmer-Z data,
and work papers used by Mr. Herbert in his analyses. If available, please provide this data for
the period from 2000 through 2014.
REQUEST NO. 24: Please provide work papers and data supporting Mr. Herbert's base
and trend line calculations for residential and commercial customers. Please include information
supporting the decision to exclude drought index from his commercial trend line model. Please
include information showing how adjusted R-Squared values were obtained.
REQUEST NO.25: In his analysis of residential data, Mr. Herbert uses a three-step
process, in which he separates baseline from irrigation usage, determines a trend equation for
each, and then recombines these into a single equation.
a. Please explain the rationale for using this method versus using a simple trend analysis
on unseparated data.
b. Was multiple regression considered as an analysis method?
c. Please provide work papers and data for this analysis.
REQUEST NO. 26: In his testimony, Mr. Herbert states that he analyzed residential
water usage using data for the period 2005 through2}l4, and commercial water usage using data
for the period 2002through20lI. Later, in Exhibit 5, Schedules 5 and 7, he presents residential
data for the period 2000 through2}l4, and commercial data for the period 2001 through2014.
Please explain why each time period was selected.
REQUEST NO. 27: In his testimony, Mr. Herbert indicates that he analyzedresidential
water usage for the 10 year period from 2005 through 2014. Later, he states that he used
monthly data from the last 7 years to ascertain baseline usage. Why were only 7 years used to
ascertain baseline usage?
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO JUNE 25,2075
REQUEST NO.28: In his analysis of residential data, Mr. Herbert uses billed
consumption for the 5 months from December through April to determine baseline usage. Please
provide work papers showing how this baseline was calculated. Given UWI's 2 month billing
cycle, how was data adjusted for this period?
REQUEST NO. 29: Please provide a detailed explanation for the adjustment described
on lines l6 through 23 of page 1 1 of Mr. Herbert's testimony, and illustrated on Schedule 8 of
Exhibit 5. On page 11, Mr. Herbert explains that this is related to a change in the number of
customers.
a. Please explain why the customer count changed.
b. Given that the analyses were performed on average per-customer consumption, please
explain why a change in customer count necessitated this adjustment.
c. Please provide a thorough explanation for shifting the trend line upwards.
d. Please provide rationale, work papers, and data supporting this adjustment.
REQUEST NO. 30: Some of the data presented in UWI's 2011 rate case differ from
those presented in the current rate case. In particular, there are differences in the commercial
billed consumption values tabulated on page I of Schedule 7, and substantial differences in
Palmer Z indices tabulated on page 1 of Schedule 5. Herbert alludes to some of these differences
on page 16 line 17 of his testimony. Please fully explain the differences, and provide data and
work papers supporting any adjustments that may have been made.
REQUEST NO.31: Please provide work papers and data supporting the calculation of
adjustment R2 (projected increases in average numbers of customers through November 30,
20 l s).
REQUEST NO. 32: Mr. Greaves states that annual purchased water costs have ranged
from approximately $208,000 to $128,000 during the period from 201| - 2014. Please provide
details, such as those provided for Ms. Cary's Adjustment No. 9, for purchased water expenses
during the years 20ll -2014.
SECOND PRODUCTION REQUEST
TO TINITED WATER IDAHO JUNE 25,2015
REQUEST NO.33: Please provide work papers and data supporting adjustment R4
(Customer Leak Adj ustments).
REQUEST NO. 34: Please explain the reasons for the Company's proposed Rule 44
changes.
REQUEST NO.35: What are UWI's policies regarding disconnection and reconnection
of residential fire service customers? What policies, in particular, pertain to disconnection of
residential fire service customers for non-payment of either their residential or fire service water
bills?
REQUEST NO.36: According to the National Fire Protection Association, "NFPA l3D
is a residential sprinkler design standard focused on one- and two-family dwellings and
manufactured homes. The intent is to provide an affordable sprinkler system in homes while
maintaining a high level of life safety."
a. Would the Company's proposed Rule 44 change apply to multiple use customers who
wish to install an NFPA 13D compliant system? If so, how would the Company's
proposed Rule 44 changes affect residential customers' ability to take full advantage of
the cost savings afforded under NFPA l3D?
b. For customers wishing to install sprinkler systems conforming to NFPA 13D, what
would be the incremental costs associated with the Company's proposed rule changes?
REQUEST NO. 37: How many residential fire service customers does the Company
currently have? How many new residential customers applied for fire service in2012,2073,
2014, and 2015 to present?
REQUEST NO.38: Please describe the impact that the Broadway River Crossing will
have on the Company's transmission and distribution lines. When will work on the Company's
transmission and distribution lines be complete? What will be the Company's share of the costs
associated with this project?
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO JUNE 25,2015
REQUEST NO. 39: Please provide a detailed electronic copy of the Company's
Pressure ZoneMap.
REQUEST NO. 40: Please explain whether the Company's Asset Management Plan
and/or Capital Investment Plan(s) are developed according to each individual pressure zone and
explain how frequently the plans are updated. Please provide the current individual pressure
zone plans if these are available.
REQUEST NO. 41: Please provide a copy of the Coordination Agreement for new
service between the Company and the City of Meridian. Please provide all other new service
coordination agreements currently in place between the Company and other adjacent entities.
REQUEST NO. 42: Please provide the proportion of ground water and surface water
supplied to customers during 2012,2013, and2014. Please provide these proportions for the (1)
non-summer (i.e., end of October through April); and (2) summer periods.
REQUEST NO. 43: Please provide the pro-forma (i.e., as described by the Company)
plant additions and retirements on a monthly basis (See Application, Greaves DI Exhibit 3).
REQUEST NO. 44: Please describe how the quantity of water treated might impact the
type of water quality treatment selected by the Company.
REQUEST NO.45: Please explain whether the Company is re-examining the treatment
methods due to new or emerging water quality requirements or concerns.
REQUEST NO.46: Please provide a copy of the pertinent section of the Uniform
Plumbing Code cited in Thompson's DI on page 4. (i.e., Section 1320.5)
REQUEST NO. 47: Please provide copies of correspondence between UWI and IDEQ,
EPA, other State DEQ, etc. concerning the proposed changes to Rules 14,15, and 16 as
referenced in Thompson's DI on page 5.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO JLINE 25,2015
REQUEST NO. 48: Please provide copies of the following: (1) Cross Connection
Control Specialist(s)' current Idaho Drinking Water Distribution Operator Class II license: (2)
the Idaho Bureau of Occupational Licenses (IBOL) Backflow Assembly Tester certification; and
(3) the Idaho Backflow Tester exam.
REQUEST NO. 49: Please provide a summary of new service inspections showing
when turn-on orders are received for new or previously inactive service connections, including
cross-connection assembly, backflow assembly, and initial testing inspections. Also provide the
number of times the Company has turned off new water services and/or issued notifications to
the Plumbing Inspector to stop issuance of occupancy permits for the years2013 and 2014. As
part of your response, please provide an example of this type of correspondence.
REQUEST NO. 50: Please provide a summary of the Company's existing Connections
Service Inspections Program including:
a. Service area prioritizatron strategy and rationale;
b. Number of staff assigned;
c. When the program was first initiated, when significant process or requirement changes
were made to the program and a summary of what those changes were.
REQUEST NO. 51: Please provide a detailed description of the current inspection
process including: annual and long-term work planning, pressure zone or specific neighborhood
selection and prioritization, field activities, field inspection forms, customer correspondence
prior to field work, customer correspondence following field work, and the results of the
inspections program for 2013, 2014, and the first half of 2015.
REQUEST NO. 52: Please provide the results of the inspections program according to:
(l) pressure zone or neighborhood; (2) number of facilities inspected; (3) number of prohibited
cross-connection devices found; (4) number of tested cross-connection assemblies; and (5)
number of cross-connection assemblies with failed tests.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO JUNE 25,2015
REQUEST NO. 53: Please explain whether the service or main line's meters have the
ability to detect flow directions, including reverse flow.
REQUEST NO. 54: Please explain whether the Company has detected reverse flow
from a customer's system (i.e., back in to the Company's system). If so, please provide
information on how often this situation has been detected since 2012, the customer outreach and
correspondence used by the Company, and the amount of time it took the Company to address
the risks of detected, active cross-connections.
REQUEST NO. 55: Testimony submitted in Thompson's DI, page 5, lines 12 - 16
describes a Company-proposed clarification for Rule 15 that "provides the Company with
authority to discontinue service without prior notice when a dangerous condition is present."
Please explain the following:
a. Rule 15 states that "In the event a backflow prevention device is required, it shall be
installed, maintained and tested at the customer's expense." Please explain whether
the current IDEQ rules require "backflow prevention devices" or "backflow prevention
assemblies," and explain under what circumstances each (i.e., device vs. assembly)
might be required.
b. Has the Company located backflow prevention devices or assemblies that are not
authorized? If so, are these owned by the Company or by customers? And, has the
Company obtained testing data, including water main water quality data, confirming
that a cross-connection of contaminated water has occurred? If so, please provide the
water quality test results and additional details of the situation.
c. Has the Company issued any coffespondence to customer-owners of un-authorized
backflow prevention devices or backflow prevention assemblies? If so, please provide
example copies.
d. Has the Company developed or prepared any correspondence of other written
materials to provide to customer-owners of un-authorized backflow prevention devices
or assemblies? If yes, please provide copies.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO JUNE 25,2015
Has the Company entered into compliance schedules with customers to repair or
replace backflow prevention devices or assemblies that are not authorized? If so, how
are the compliance schedules developed and who, within the Company, authorizes
them?
Under normal water main pressure conditions, is there an immediate danger of water
main contamination due to an un-authorized backflow prevention device or assembly?
Under what conditions might an un-authorized backflow prevention device or
assembly cause an immediate danger to water main contamination? How frequently
do these situations occur? Please provide the dates, durations, pressure zone locations,
and water quality test data that demonstrate the occurrence of water-main cross-
connections contamination.
REQUEST NO. 56: Has the Company conducted any surveys or assessments to
determine how many systems lack required cross-connection equipment? If not, why not?
REQUEST NO. 57: Has the Company conducted any surveys or assessments to
determine how many cross-connection devices lack necessary testing? If not, why not?
REQUEST NO. 58: Please provide the make, model, and price of Radio Frequency
Meter (RFM) and Automated Meter Infrastructure (AMI) installed by the Company for each
pressure zone, including how many of each type have been installed.
REQUEST NO. 59: Please provide a copy of the current contract(s) used to obtain
services for facility installations, new construction, and replacements. Please explain the
following:
a. term of the final contract (i.e., annual, project specific, etc.);
b. contract development process including whether it is a competitive process;
c. how any 'requests for proposals' are advertised, along with an example advertisement;
d. whether multiple companies are awarded contracts depending on various
specializations; and
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO JUNE 25,2015
e. whether the specific tasks conducted under the contract(s) are developed as task
orders.
REQUEST NO.60: Please describe the Company's contract services proposal review
process for facility installations, new construction, and replacements including whether the
proposals are reviewed by individuals, a committee composed of Company staff or management,
and whether specific review criteria are applied. If review criteria are applied, please explain
whether these criteriaare included as part of the 'requests for proposals' and, if not, please
provide a copy. Please provide a copy of the most recent orequests for proposals.'
REQUEST NO. 61: Are there specific services that are only provided by one contractor
(i.e sole-source)? Ifso, please describe these services.
REQUEST NO. 62: For services that are only provided by one contractor (i.e., sole-
source services), please provide a copy of the current contract(s). Please explain the following:
a. term of the final contract (i.e., annual, project specific, etc.);
b. contract development process, including how the Company addresses the non-
competitive process;
c. how any 'requests for proposals' are advertised, along with an example advertisement;
and
d. whether the specific tasks conducted under the contract(s) are developed as task
orders.
REQUEST NO. 63: Please describe the Company's proposal review process for sole-
source services including whether the proposals are reviewed by individuals, a committee
composed of Company staff or management, and whether specific review criteria are applied. If
review criteria are applied, please explain whether these criteria are included as part of the
'requests for proposals' and, if not, please provide a copy. Please provide a copy of the most
recent 'requests for proposals' for sole-source services.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO JUNE 25,2015
REQUEST NO. 64: Please provide a breakout both in dollars and percentages for all
plant additions and replacements conducted in-house, under annual contract services, and for
sole-source contractors.
REQUEST NO. 65: Please provide a copy of the current contract(s) used to obtain
services for engineering design. Please explain the following:
a. term of the final contract (i.e., annual);
b. contract development process including whether it is a competitive process;
c. how any 'requests for proposals' are advertised, along with an example advertisement;
d. whether multiple companies are awarded contracts depending on various
specializations; and
e. whether the specific tasks conducted under the contract are developed as task orders.
REQUEST NO. 66: Please describe the Company's proposal review process for
engineering design services including whether the proposals are reviewed by individuals, a
committee composed of Company staff or management, and whether specific review criteria are
applied. If review criteria are applied, please explain whether these criteria are included as part
of the 'requests for proposals' and, if not, please provide a copy. Please provide a copy of the
most recent 'requests for proposals.'
DATED at Boise, Idaho, this 2 E%^yof June 2015.
Technical Staff: Mike Morrison (23-38)
Johanna Bell (39-66)
i : umisc : prodreq/uwi I 5. I dhdj hrpsj bmechjboj tphtcmmac prod req 2 to UWI
SECOND PRODUCTION REQUEST
TO LINITED WATER IDAHO 10 JUNE 25,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25M DAY OF JUNE 2015, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO UNITED WATER IDAHO INC, IN CASE NO. UWI-W-l5-OI, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK
BOISE ID 83702
E-MAIL: i [e-mail]
E-MAIL ONLY: [e-mail]
gre g.wyatt@unitedwater. com
i erry. healy@unitedwater. com
gary. prettyman@unitedwater. com
walton.hill@ unitedwater. com
d e bra.visconti (@ u nitedwate r.com
KEVIN H DOHERTY
UNITED WATER MANAGEMENT
AND SERVICES CO
2OO OLD HOOK ROAD
HARRINGTON PARK NJ 07640
E-MAIL : kevin. dohe4v@unitedwater. com
CERTIFICATE OF SERVICE