20150710UWI to Staff 23-31,33.pdf

(208) 343-7s00
Q08)33G6912 (Fa*)
McDevitt & Miller u,p
Lawyers
420 West Bannock Sueet
P.O. Box 256+8t3701
Boiser ldaho 83702
ChaE. F. McDevitt
Deant. floe) Milter
Celeste K. Miller
July 10,2015
Via llaad Delie,ery & US MaiI
JeanJe*"Il, Sectetary
Idaho Public Utilities Commission
472W. l7ashington St
Boise,Idaho 83720
Re [J$7I-W-15-01
DeatMs.Jewell:
Eoclosed fe1 filin& please find an odgind and three (3) copies of United lTater Idaho's Response to
Commission Saffs Second Ploduction Request Nos. 23, 24,25,26,27,28,29,30,37 and 33.
Kindly retum a file stamped copy to me.
Very Tnrly Youts,
McDevitt & MlletLLPM
DJM/hh
Cc: United Watet ldaho, Inc.
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ORIGINAL
Dean J. Miller (lSB No. 1968)
McDEVITT & MILLER LLP
420 West Bannock Street
P.O, Box 2564.-83701
Boise, lD 83702
Tel: [phone]
Fax [phone]
ioe@mcdevitt-m i ller. com
Attomey for United Water ldaho lnc.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
lN THE MATTER OF THE APPLICATION I Gase No. UW-W-154{
OF UNITED WATER IDAHO INC. FOR
AUTHORIW TO INCREASE ITS RATES I UNITED WATER IDAHO'S
AND CHARGES FOR WATER SERVICE I RESPONSE TO SECOND
IN THE STATE OF IDAHO PRODUCTION REQUEST OF THE
COMMISSION STAFF
United Water ldaho lnc., ("United Wate/') by and through its undersigned
attorneys, hereby submits its Response to the Gommission Staffs Second Production
Request Nos. 23, 24, 25, 26, 27, 28, 29, 30, 31 and 33.
DATED this _tv_day of July, 2015.
UNITED WATER IDAHO'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
Goi,lMtssroN STAFF - r
UNITED WATER IDAHO INC.
(lSB No. 1968)
Aftomey for United Water ldaho lnc.
CERTIFICATE OF SERVICE
I hereby certify that on ,n" dday of July, 2015, I caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary Hand Delivered
ldaho Public Utilities Commission U.S. Mail
472 West Washington Street Fax
,x-
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P.O. Box 83720
Boise, lD 83720-0074
[e-mail]. id. us
Donald L. Howell, ll
Daphne Huang
Deputy Attomey General
ldaho Public Utilities Commission
P.O. Box 83720
Boise, ldaho 83720-0074
don. howell@puc. idaho.qov
daphne. h uanq@puc. idaho.qov
Brad M. Purdy
Aftorney at Law
2019 N. 17th Street
Boise, lD 83702
[e-mail]
Fed. Express !iEmail d
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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McDevrr& Mrulen LLP
UNITED WATER IDAHO'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
GOMMBS|oN STAFF.2
UNITED WATER IDAHO INC.
GASE UW!-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Paul Herbert
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.
RESPONSE NO. 23:
The workpapers related to monthly billing datra and Palmer Z-lndex data are attached.
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UNITED WATER IDAI.IO INC.
GASE UWI-W-I5-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
PrepareriSponsoring Witness: Paul Herbert
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.
RESPONSE NO.24:
Please see data attached in the response to Request No. 23 for the usage data and Palmer Z-
lndex data used in the trend line calculations. Please see the attachment to this response for
the regression results used in the trend line calculations and the regression results used in the
determination to not use the drought index in the commercial trend line calculations. Please
note also that the commercial regressions use the data for the period 2002-2011 due to a
change in the way customers were counted starting in 2012, as explained in detail in the
response to Request No. 29.
The coefficients of the regression equations and their associated statistical confidence level as
measured by "P-Value" are highlighted on the attached work paper. The coefficients are the
values used in the equations to calculate the trended usages. The P-Value is one of the
available measures of confidence in the statistical significance of the associated coefficient.
Roughly speaking, the P-Value represents the probability that the associated variable (ie., time
trend, weather) has no effect on usage, given the pattern of data that were input into the
regression equation. Analysts typically look for a P-value of 5% or lower in deciding whether to
use regression coefficients.
The regressions used in the trend analysis for residential indoor usage, residential irrigation
usage, and commercial total usage have P-values well under this 5 percent threshold.
The results shown for the regression of commercial irrigation on time and weather show clearly
why the weather variable was not used in the commercial trend analysis. All of the P-values for
the coefficients in that equation are well over 20 percent.
See the attached workpaper for the relevant P-Values and the adjusted R-squared values. All
of the values in the table are direct output from the Excel Data Analysis Toolpack.
United Water ldaho
Case [JW-W-15-01
Request No. 24 Attachment
Page 1 ofl
R.grc..lon R.art3 for Trqdlln AillytL (co.ftd(lb ars ln I ,0ll0 g.llon )
R.d(hn0.l hdm m Y!u, 200t201/t
Rg(rlstm Stsdsdcs
Multde R 0.9697Rsquare 0,9404Adjust€dRsquare 0,9329
Stiandard Efior 0.8604-@-19.
R.tLLntd Htrd6 o Yor ud W.rtrr, 2*rm11
Re@so., SlEtisrtgi lflide R 0.961Rsquare 0.921
Adjusbd Rsquaro 0.903
Standad Enor 1.9'19
Obeflatims
ANOVA
Rsgrslon 2 315317235 157.658618 42.79 0.01%
R8sidual
Tolal
7I ?5.7887402 3.6841086
341.105096
Cmrcld Totd 6 Yrr,2002-20ll
Ra@sb, SlHldbs
Multple R 0.901
R Squaro 0.811
Ad,iustsd Rsquaro 0.766
Standard E ror 21.fi5Ob€ffi|iffi t0
A,.tovA
dtssrrsFFRaglgssion 1 20,703.m 20,763.00 34.41 0.04%
Residual
Total
8I 4,827.9 603.,t5
25,590.50
Carmichl htdm sY[r udW.rtlrr, m02-2011
l.lot 6ed in €hulatirE trerldine. tl,one of the oefhcients ae signifiGnt
R Squars
Adlrrst€d RSquars
Slandard Ero.
Ob6ffitom
0.5070.&
16.655
t0
8 0.@546506 0.75068313Total I 100.730052
dfssMSFFRagrsion 2 2,878.41 l,4i}92'l 5.19 1.'l5ohR6idual 7Total I 'l,u'1.74
4,820.'10
n739
UNITED WATER IDAHO INC.
CASE UWI-W.I5-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Paul Herbert
REQUEST NO. 25:
ln 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.
RESPONSE NO. 25:
a. The primary objective of the consumption analysis is to determine the time
trend of usage. The complicating factor in determining the time trend is the
fact that there is variation in weather that causes variation in usage from year
to year. For example, if there were a general trend towards drier weather
later in the analysis period, then the time trend would look flatter than it
actually is, and future consumption would be overestimated. Conversely, if
there were a general trend towards wetter weather, the time trend would look
steeper than it actually is, and future consumption would be underestimated.
Separating out the weather-dependent component of usage provides for a
more reliable coefficient for the time trend.
b. Actually, multiple regression is used in estimating the residential irrigation
equation. That is, residential irrigation has two independent variables:
weather (Palmer Z-index) and year. Doing so addresses the concern raised
above about measuring a time trend without accounting for the effects of year
to year variations in weather. Multiple regression on the indoor usage would
Page 1 of 2
UNITED WATER IDAHO INC.
CASE UWI.W.15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
not be appropriate because there is no reason for a weather influence on
indoor usage. Multiple regression could be performed on total usage, but it
would be less accurate than separate regressions for indoor and irrigation
usage because it includes a component that is not weather dependent. Also,
running separate regressions has the advantage that it allows for a difference
in the time trend of irrigation usage from the time trend of indoor usage.
The usage data and Palmer Z-index values used in the residential analysis
are presented as an attachment in the response to Request Number 23. The
regression results used in the residential trend analysis are presented as an
attachment in the response to Request Number 24.
Page 2 of 2
UNITED WATER IDAHO INC.
CASE UWI-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Paul Herbert
REQUEST NO. 26:
ln his testimony, Mr. Herbert states that he analyzed residential water usage using data
for the period 2005 through 2014, and commercial water usage using data for the period
2002 through 2011. Later, in Exhibit 5, Schedules 5 and 7, he presents residential data
for the period 2000 through 2014, and commercial data for the period 2001 through
2014. Please explain why each time period was selected.
RESPONSE NO. 26:
The ten-year periods identified, 2005-2014 for residential and 2002-2011 for
commercial, refer to the periods used to fit the regression equations. Prior years' data
are presented in the data tables and charts for illustration but do not affect the projection
for the year 2014 consumption because they are not used to fit the trend lines. The ten
year period was selected in part to be consistent with the method for the prior study, but
even more so to capture the most current trends in usage patterns
The commercial regression analysis period could not extend beyond year 2011 due to
the change in the way commercial customers were counted and its impact on the usage
per customer values. The response to Request Number 29 provides a more detailed
explanation for the time period used in the commercial analysis.
UNITED WATER IDAHO INC.
cAsE uwt-w-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Paul Herbert
REQUEST NO. 27:
ln his testimony, Mr. Herbert indicates that he analyzed residential 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?
RESPONSE NO. 27:
The determination of which billing months to use to estimate baseline, indoor usage was
a preliminary analysis step. From the examination of seven years of billing data it was
considered sufficiently clear with this amount of data to conclude that billing months
from December through April best represented indoor usage and no additional
information from other years was needed.
The chart below illustrates the data that were examined to select which billing months to
use as representative of indoor usage. The chart illustrates that the billed usage for the
billing months December and January through April are the billing periods with
consumption tightly clustered over the seven years, whereas, starting with some of the
years' data for May, consumption is elevated from the base level that is used in the five
"winted' billing months.
Page 1 ot2
UNITED WATER IDAHO INC.
CASE UWI.W.15-01
SEGOND PRODUCTION REQUEST OF THE COMMISSION STAFF
United Water ldaho
Residential Consumption per Customer
60
50
40
30
20
10
0
Jan Feb Mar
+2008
+2009
-..F2010+2011
x2012+2013+2O14
Page 2 of 2
UNITED WATER IDAHO INC.
CASE UWI.W.15.O1
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Paul Herbert
REQUEST NO. 28:
ln 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?
RESPONSE NO.28:
The attachment in response to Request No. 23 includes the work papers for the
calculation of indoor, baseline usage per residential customer. The calculations are in
columns 15-19. The two-month billing cycle was accounted for when determining the
total days of consumption in each billing month. Each billing month of usage data
covers approximately sixty days. Total days for these five billing months was 302.
UNITED WATER IDAHO INC.
CASE UW!-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Paul Herbert
REQUEST NO. 29:
Please provide a detailed explanation for the adjustment described on lines 16 through
23 of page 11 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.
RESPONSE NO. 29:
a. A close review of its commercial customer rolls was occasioned by the
Company's implementation of new billing software. The Company removed
some accounts that it determined were no longer active.
b. Because the adjustment removed inactive customers that had zero usage, the
changes affected only the denominator (number of customers), not the
numerator (consumption) in the consumption per customer values. This change
makes the units incommensurable from the one period to the next.
c. lt was determined that shifting the time trend was a necessary solution to the
problem of the incommensurable units. The percentage decrease in the frtfed
consumption data for the last years of available data (from 2010 to 2011\ was 3.0
percent. This percentage decrease was applied to the year 2014 consumption
per customer in order to project year 2015 consumption per customer. This
action is roughlyequivalent to shifting the time trend line upwards to the new
(post 201 1) usage per customer basis. By doing so, the negative time trend
effect is preserved while the new consumption per customer basis is recognized.
d. See part c. above and attached work paper and data support.
Request No. 29 Attachment
Commercial Consumption Trends, 2001 -2018
(gallons per customer)
Total Consumption per Customer
Year
Billed
Consumption
(2)
738,845
650,058
634,278
635,250
596,606
623,667
634,363
579,490
541,893
510,165
512,128
573,021
571,537
569,279
Trended on
2002-2011
Trendline
Shifted
Change
Along
Trendline
(1)
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
(3)
679,043
663,179
647,315
631,450
615,586
599,722
583,858
567,994
552,129
536,265
520,401
504,537
488,673
472,808
(4)
569,279
552,201
535,635
519,565
503,979
(5)
-23%
-2.4%
_2.5%
_2.5%
-2.6%
-2.6%
-2.7%
-2.8%
-2.9%l-3o%l
-3.0%
-3.1%
-3.2%l-3o%l
-3.0%
-3.0%
-3.0%
UNITED WATER IDAHO INC.
CASE UW!-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Paul Herbert
REQUEST NO. 30:
Some of the data presented in UW!'s 2011 rate case differ from those presented in the
current rate case. ln particular, there are differences in the commercial billed
consumption values tabulated on page 1 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.
RESPONSE NO. 30:
The commercial monthly billed usage per customer differs from the previous case due
to changes in the data that were available to complete the analysis. The differences are
extremely minor at less than one percent. For the current rate case, the Company
provided monthly billed usage and monthly customer counts for the period 2005 through
2014. These data were used to calculate monthly consumptions per commercial
customer, which were then summed to total annual consumption per customer. Monthly
and total annual consumption per customer for the years 2001-2004 were obtained
directly from the values in the previous, 2011 rate €se. Billed volumes and customer
counts per billing month for the years prior to 2005 were not provided for either rate
case, so it was not possible to use consumption per customer on the calculated basis
for the period prior to 2005. There is only a very slight variation in the values calculated
using the monthly usage and monthly counts from the consumption per customer values
provided directly by the company. All annual totals are less than one percent different
from the totals provided by the company and used in the prior case. The great majority
of calculated monthly amounts per customer are less than one half of one percent
different from the direct amounts per customer provided by the company for the
previous study.
Page 1 of 2
UNITED WATER IDAHO INC.
CASE UW!-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Please see the attachment for the data on billed usage, number of customers, and
consumption per customer.
Between the last rate €se and the present, the Palmer Z-lndex values were
recalculated by their provider, the National Climate Data Center. The Data Center
notes on its web site that reviewers had found an error in the code used to calculate the
various drought indices. This study used the most up to date available indices; there
was nothing to adjust.
Page 2 of 2
Commsrclal Usage per Custorner per Yoar
Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct
Commercial Bimonthly Usage (Thousand Gallons)
2005 218,553 227,859 202,848 246,184 284,607 37s,224 446,589 727,805 744,610 680,s002006 224,647 262,941 210,690 256,125 256,760 462,312 542,224 788,827 719,615 700,923
2007 234,871 248,351 222,64 254,55',1 297,581 544,619 613,722 827,521 738,223 725,6',15
2008 230,775 246,549 231,548 247,694 283,172 476,120 527,122 767,890 723,585 693,577
2009 225,096 211,663 201,220 222,771 263,716 470,fi4 510,979 678,787 671,320 687,603
2010 212,7s8 220,489 183,822 223,474 221,873 358,288 448,801 728,391 609,450 636,853
2011 215,512 217,794 189,223 216,753 222,766 329,146 430,839 664,151 653,801 690,508
2005
2006
2007
2008
2009
2010
2011
Request No. 30 Attachment
Nov Dec
384,445 301,745
446,845 301,148
436,',t47 287,356
414,808 299,878
401,647 258,256
413,262 288,574
444,441 299,708
Commercial Number of Customers (last three months of 20'1 1 adjusted to prior yea/s count, due to change in billing soft/vare that began Oct '1 1)3,909 4,142 3,994 4,066 4,007 4,074 4,033 4,087 4,036 4,097 4,047 4,109
4,053 4,108 4,060 4,168 4,060 4,176 4,069 4,206 4,087 4,264 4,089 4,298
4,099 4,298 4,096 4,312 4,104 4,334 4,116 4,465 4,155 4,488 4,169 4,5134,183 4,550 4,194 4,592 4,204 4,595 4,216 4,658 4,220 4,655 4,216 4,9354,191 4,632 4,206 4,629 4,213 4,635 4,231 4,642 4,233 4,641 4,227 4,651
4,226 4,650 4,230 4,659 4,249 4,654 4,243 4,666 4,238 4,657 4,234 4,662
4,262 4,651 4,267 4,659 4,268 4,662 4,280 4,669 4,280 4,657 4,234 4,662
Commercial Consumption per Customer2000 68.s4 63.35 66.002001 58.75 72.80 65.32
2002 63.53 65.26 56.35
2003 66.49 61.18 51.502004 57-26 5s.05 54.042005 55.91 55.01 50.792006 55.43 64.01 51.892007 57.30 57.78 54.36
2008 55.17 54.19 55.212009 53.71 45.70 47.442010 50.35 47.42 43.462011 50.57 46.83 44.35
139.86 156.88 210.36 181.59 176.72
124.06 174.98 203.12 222.10 186.06
122.23 't51.53 145.68 205.01 169.51
103.21 136.40 189.44 178.52 158.19
117.99 136.81 190.96 170.71 152.7192.10 110.73 178.08 184.49 166.10
110.71 133.26 187.55 176.07 164.38
125.66 149.11 185.34 177.67 161.68
103.62 125.03 164.85 171.47 149.00
101.52 120.77 146.23 158.59 14.1676.98 105.77 156.11 143.81 136.75
Total'
94.77 88.25 703.35116.75 87.88 738.U115.58 75.28 650.05122.06 79.79 634.28107.42 79.63 635.2595.00 73.44 596.61
109.28 70.07 623.67104.62 63.67 634.3698.39 60.77 579.49
95.02 55.53 541.8997.61 61.90 510.17
104.97 64.29 512.13
66.39 94.02
88.73 77.15
72.26 57.9056.47 65.3263.39 84.5260.55 71.03
61.45 63.24
59.03 72.5153.94 67.3648.13 62.6047_97 52.22
46.52 52.19 70.60 100.66 142.25 152.76 14a.27
'Sum of monthly amounts is divided by two due to the fact that each billing month represents two months.
UNITED WATER IDAHO INC.
cAsE uw-w-l5.01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Paul Herbert
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, 2015).
RESPONSE NO. 31:
See aftached workpaper for adjustment R2.
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UNITED WATER IDAHO INL.
cAsE uwt-w-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Paul Herbert (Jerry Healy)
REQUEST NO. 33:
Please provide work papers and data supporting adjustment R4 (Customer Leak
Adjustments).
RESPONSE NO. 33:
See the attached workpaper for the adjustment R4. The Company incurred a leak
adjustment of ($93,450) in revenue. The attached workpaper quantifies that adjustment
based on water usage, assuming 50% of the loss was at the winter rate and 50% at the
summer rate.
Request No. 33 Attachment
United Water ldaho
Adjustment to Test Year Revenue for Leak Adiustments
Leak Adjustment ln Test Year $ (93,450)
Calculation of Adjustment in CCF by Winter and Summer Rates
Average Rate - Per CCI
Winter S Lq1ql
Summer S 1.8310
TotalAdjustment
CCF Units
CCF Revenue
SOYo S
s0% s
$
0.7324
0.9155
1,.6479
(28,355)
(28,355)
(41,532)
(51,918)
s
s
(55,710)
(56,710)