20150724Staff 67-78 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 t2t334-03 18
IDAHO BAR NOS .3366/8370
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
UNTTED WATER rDAHO rNC FOR ) CASE NO. UWr-W-1s-01
AUTHORITY TO INCREASE ITS RATES AI\D )
CHARGES FOR WATER SERVICE IN THE ) THIRD PRODUCTION
STATE OF TDAHO. ) REQUEST OF THE
) COMMISSION 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 Attorneys General, request that United
Water provide the following documents and information as soon as possible, or no later than
FRIDAY, AUGUST 14,2015
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 identifu the name, job title, location and telephone
number of the record holder.
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO JULY 24,2015
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. 67: Please describe the capital expenditure process (including but not
limited to) identification of need, request for project approval and the necessary paperwork,
project management and project closure into plant in service. Please also provide documents
(policies, procedures and sample requests) supporting this process.
REQUEST NO. 68: Please provide the policy that identifies the approval levels
(generally based upon dollar amount) for capital projects.
REQUEST NO. 69: Please update Exhibit No. 11, Schedules 1,3,4,5 and 6 with actual
cost information for each month available. Please also update related exhibits and schedules
(such as depreciation expense, accumulated depreciation, accumulated deferred income taxes to
name a few) to reflect the actuals for plant additions, contributions in aid of construction, and
advances for construction.
REQUEST NO. 70: Please update Exhibit 3 to include the most recent actuals and
include within your response an update to the in-service dates.
REQUEST NO. 71: Please provide an updated copy of all leases, purchase agreements
or other contracts for vehicles and heavy equipment for 2011-2014.
REQUEST NO. 72: Please provide work papers and documentation (including original
cost, depreciation schedule and sale/auction proceeds) from sale/auction ofvehicles for the three-
year average2013 through April 2015 actual amount of $88,700 from J. Cary Exhibit No.
10.1. I 6.
REQUEST NO. 73: Please provide an explanation for the use and justification of
74.06% as the Transportation Pro Forma O&M ratio as documented in J. Cary Exhibit No.
I 0.1 .1 6.
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 JULY 24,2015
REQUEST NO. 74: Please provide the invoice and proof of payment for Gowen tank
interior painting requested for inclusion in the 2015 rate case.
REQUEST NO. 75: Please provide all initial costs and deferred amortization schedules
for remaining tanks/reservoirs listed on Company Witness Cary's Work papers, Exhibit No.
10.1.2t.
REQUEST NO. 76: Please explain which expenses are included in the OPEX line for
2014 inthe response to First Production Request No. 16.
REQUEST NO. 77: Regarding adjustment No. 10 Energy, please provide work papers
showing the ($34,832) EnerNOC activity summaries and payment received in January 2015, as
given by Company Witness Cary in page 8 of her testimony.
REQUEST NO. 78: Regarding Production Request No. 31, how were increases in the
numbers of customers in each classification determined?
DATED at Boise,Idaho, thisTYbdurof July 2015.
Technical Staff: Patricia Harms (67-70)
Amber Christenso n (7 7 -7 7)
Mike Morrison (78)
i:umisc:prodreq/uwi I 5. I dhdjhrpsjbmechjbojtphtcmmac prod req 3 to UWI
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO
DaphndHuang
Deputy Attomey G
JULY 24,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24th DAY OF JULY 2015, SERVED
THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION
STAFF TO UNITED WATER IDAHO INC, IN CASE NO. UWI-W-I5-01, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DEAN J MILLER
MoDEVITT & MILLER LLP
420 W BANNOCK
BOISE ID 83702
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N ITTH STREET
BOISE TD 837092
E-MAIL : [e-mail]
E-MAIL ONLY: i [e-mail]
gre g. wyatt@unitedwater. com
j erry. healy@unitedwater. com
gary. prettyman@unitedwater. com
walton.hill@unitedwater. com
debra.visconti (o unitedwater.com
marshall.thompson@unitedwater. com
KEVIN H DOHERTY
UNITED WATER MANAGEMENT
AND SERVICES CO
2OO OLD HOOK ROAD
HARRINGTON PARK NJ 07640
E-MAIL : [e-mail]
heather@ mcdevitt-miller. com
CERTIFICATE OF SERVICE