20150803Staff 79-112 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 r2t 33 4-03 1 I
IDAHO BAR NOS .336618370
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
t" ' ' ', . ,) I,,- ?, 1-2
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
UNTTED WATER IDAHO rNC FOR ) CASE NO. UWr-W-1s-01
AUTHORITY TO INCREASE ITS RATES AND )
CHARGES FOR WATER SERVICE IN THE ) FOURTH 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 Attorneys General, request that United
Water provide the following documents and information as soon as possible, or no later than
MONAY, AUGUST 24,2015
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.
FOURTH PRODUCTION REQUEST
TO LINITED WATER IDAHO AUGUST 3,2015
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. 79: Please provide a corporate organization chart beginning with Suez
Company down. Please include only those corporations that are in North America.
REQUEST NO. 80: Please provide access in Boise to all Board of Directors and Board
Committee minutes for United Water and its affiliates for 2014 and 20 I 5. Please also provide
access to all reports and materials discussed during the board and committee meetings.
REQUEST NO. 8l: Please provide copies of any reviews and reports of the Service
Company including those provided to andlor performed by other regulatory commissions.
REQUEST NO. 82: Please provide a list of all policy, operations accounting and cost
allocation manuals affecting United Water Idaho, Inc. including a description of each manual
and documented set of procedures that includes the date the materials were last updated.
REQUEST NO. 83: Please provide the current calculations for each of the allocations
from the Service Company. For example, Administrative, Purchasing, Insurance and General
Services are allocated based on one third in proportion to the number of employees, one third in
proportion to the number of customers served, and one third in proportion to operation and
maintenance expenses for the preceding calendar year. Please provide the inputs for the
calculation and show where each input comes from, whether from regulated, unregulated,
corporate, etc. for the current allocation factor, and for the factor that is utilized in the test year.
REQUEST NO. 84: For each and every item allocated to United Water Idaho other than
under the M&S agreement, please provide the "Corporate Assumptions" or similar document
and the methodology for allocating or assigning costs to United Water Idaho, if not included in
the Corporate Assumptions or similar document.
FOURTH PRODUCTION REQUEST
TO TINITED WATER IDAHO AUGUST 3,2015
REQUEST NO. 85: If not included in the Corporate Assumptions or similar document,
please identify how the Customer Care and Billing System is allocated to United Water Idaho
and all other entities. Please provide these in Excel format, with formulas and figures intact.
REQUEST NO. 86: Please provide the following as they relate to the Customer Care &
Billing (CC&B) system:
a. The Capital Expenditure Authorization and/or other document(s) demonstrating need
for the new system and savings (including personnel savings) to be achieved.
b. Please provide a listing of each and every business unit in the Business Segments of
United Water that will be using the new CC&B system.
c. Please provide the number of customers in each business unit.
d. If not detailed above, please list all of the water and wastewater utilities in the
Regulated Business or similar segment with the allocation to each for CC&B
including those with zero allocation. If there is no allocation of costs from CC&B,
please identify why.
e. If not detailed above, please describe and list the public-private partnerships in the
Contract Operations or similar business segment that will be using the CC&B system
with the allocation to each for CC&B including those with no allocation. If there is
no allocation of costs from CC&B, please identify why.
f. If not detailed above, please describe and list the contracts in the Asset Management
or similar business segment that will be using the CC&B system with the allocation to
each for CC&B.
g. Please list those contracts and provide the number of customers in each of the
contracts that will be utilizing the CC&B system.
REQUEST NO. 87: Please provide the Company's Exhibits and Schedules in native
format with formulas intact. Please include within your response the underlying support
(accounting detail, reports, and forecasts) for these Exhibits and Schedules.
FOURTH PRODI.]CTION REQUEST
TO UNITED WATER IDAHO AUGUST 3,2015
REQUEST NO. 88: Please revise Exhibits 3,9,10, and 11 to reflect amounts through
September 30,2015 instead of November 2015. Please provide the following:
a. the information in native format with formulas intact,
b. the underlying support for these Exhibits and Schedules,
c. identify and quantify expenses and revenues that will change with revisions to these
Exhibits, and
d. update forecasts monthly to actuals as available.
REQUEST NO. 89: Please prepare revenue and expense adjustments to reflect the
September 30,2015 rate base. Such adjustments would include but not necessarily be limited to
postage (due to fewer meters in plant in service), chemicals, power and revenues (due to fewer
meters in plant in service). Please include the underlying supporting documentation and
workpapers to these adjustments.
REQUEST NO. 90: Please provide a detailed schedule of any land or property
dispositionsfor2012,2013,2014 and 2015 to date. The list should include, date of sale or
disposition, description of the items sold, the amount of the sales, the accounts involved and their
respective amounts.
REQUEST NO. 91: Please provide a list of land or property sales planned, under
consideration, or proposed for 2015 or 2016.
REQUEST NO. 92: Please provide an update on the Marion Smith property to include
the total square footage, square footage occupied by the diesel generator and any other use ofthe
property and accompanying square footage. Please include within your response the total cost of
the property.
REQUEST NO. 93: Please provide a schedule of all adjusting and closing entries for
December 31,2014 and through July 30, 2015 general ledger. The schedule is to include the
date of the entry, accounts posted, amount of the entry, type of entry, business unit posted and a
related explanation for each entry.
FOURTH PRODUCTION REQUEST
TO TINITED WATER IDAHO AUGUST 3,2015
REQUEST NO.94: Please provide the detailed annual capital budgets for2012,2013,
2014 and 2015 to date. Please include within your response the comparison to actual capital
expenditures for items within those budgets.
REQUEST NO. 95: Please provide the Procurement Review Form(s) or similar
document(s) for the 2015 annual contract(s) for the installation of water mains and services.
REQUEST NO. 96: Please provide the underlying supporting documentation and
calculations for all entries of actual data and forecasts contained in Exhibit 3 and Exhibit 1 1.
REQUEST NO. 97: Please provide a list of all capital projects suspended, abandoned or
discontinued during 201 I through2015 to date. Please include within your response a
description and the total cost of each project and when it was suspended, abandoned or
discontinued. Please also identify how the costs ofthose projects have been recorded and
excluded from the Company's case.
REQUEST NO. 98: Please provide an electronic copy, in Excel format, with formulas
intact, of the contractors advance and refund spreadsheet, or its current version, maintained by
the Company that is reconciled to the general ledger accounts 25200; or the currently used
accounts, for 2012 through 2075, as available.
REQUEST NO. 99: Please provide a description of the method by which materials and
supplies are recorded and or allocated to the accounting records in 2012, 2013 , 2014 and 2015 to
date. Please also provide a list ofand proposed changes for 2015 and 2016.
REQUEST NO. 100: Please state whether the Company is currently undergoing any
Federal or State tax return audit. Please include any notifications of audits which are not
currently underway.
FOURTH PRODUCTION REQUEST
TO I.INITED WATER IDAHO AUGUST 3,2015
REQUEST NO. 101: Please provide copies of all reports and or letters stating the
outcome of any Federal or state tax return audits for 2011,2012,2013,2014 and20l5, to date.
Please also provide the Company's responses.
REQUEST NO. 102: Please identify the expenses, plant additions and all other costs
included in the case related to the Brian Subdivision connection by account, month and by year.
REQUEST NO. 103: Please provide the cost-benefit analysis for the Company's AMI
program.
REQUEST NO. 104: Please provide a monthly comparison of actual expenses by
account to budgeted amounts for each month during 2014 and2015.
REQUEST NO. 105: Please provide the underlying support and calculations for
Adjustment No. 24, Equity Gross Up Amortization including the Equity Gross Up amount and
the calculation of the amortization rate.
REQUEST NO. 106: Please identify how Allowance for Funds Used During
Construction (AFUDC) is eliminated from water rights' projects as ordered in Case No. UWI-
04-4, Order No. 29838 (page l2). If not eliminated, please identify AFUDC by project.
REQUEST NO. 107: Please provide the "In Seryice" reports for July 2011 to present.
REQUEST NO. 108: For the projects that cost over $200,000, in the "Monthly In-
Service and Close Reports" (Refer to Production Request Above) from July 201 1 through 2015
to date please provide the following information:
a. Brief Justification
b. Location
c. Addition Amount
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO AUGUST 3,2015
d. Retirement Amount
e. Removal Amount
f. Salvage Cost
REQUEST NO. 109: Please provide the accounting detail by activity (Vendor,
AFUDC, Payroll, Overheads, Contributions in Aid of Construction and the like), Construction
Work in Progress (CWP) reports, Capital Expense Authorization and/or other documents
establishing need for and approval ofthe project, cost-benefit analysis, related contracts, and
access to engineering section files for each of the following projects:
Project Number Description
C15D701 Broadway River Crossing
Cl4A502 Amity Well Re-Drill
Cl4B503 Fisk VOC Treatment
C15C503 Repl Bluffs Booster Station
Cl5D300 Developer Extensions
C15D650 Small GIP Main Repl Project
C15F501 Rep Isolated Services
Cl5G005 AMI Network
Cl4Jl06 PeopleSoft
Cl4Jl07 PowerPlan
Cl4K20l Headquarters Relocation
C13K302 Master Facility Plan Update
C14G501 Repl Customer Meters
Cl2J950 System Enhancements
C13D003 North Mountain to Scenic Phase 2
Cl2B503 Repl CWTP Membranes
C12E50l Bogus Basin Reservoir
Cl2A00l Water Rights
Cl4F001 Repl Security Equipment
Cl4F003 Repl Victory Office Toilets
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO AUGUST 3,2015
ct3D32t
ct4D70t
c13D348
ct4D327
ct4D3t2
Facility Cooling
CWTP Pond Access Improvs
Printer Replacements
Replace Hid Hollow #3 VFD
Repl Colorimeters-Cl Analyzers
REQUEST NO. 110: Please provide an explanation and accompanying list of projects
for the increase in office furniture and equipment from $10.7 million (2011Annual Report) to
$12.3 million (2014 Annual Report).
REQUEST NO. 111: Please provide a schedule showing all employee classifications,
number of employees in each classification, the dollar amount of salaries for each year 2011,
2012,2013, and2014 for each classification. Please break out the salary by basic wages,
overtime, bonus wages, and other expenses (such as on-call pay etc.).
REQUEST NO. 112: Please provide a job description for each of the employee
classifications.
DATED at Boise, Idaho, this y ofAugust2015.J/u^
i:umisc:prodreq/uwi I 5. ldhdjhrpsjbmechjbojtphtcmmac prod req 4 to UWI
FOURTH PRODUCTION REQUEST
TO UNITED WATER IDAHO
Technical Staff:Patricia Harms (79-l l0)
Joe Terry (l I l-1 12)
Deputy Attomey General
AUGUST 3,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF AUGUST 2015,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO UNITED WATER IDAHO, IN CASE NO. UWI-W-15-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK
BOISE TD 83702
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N ITTH STREET
BOISE tD 837092
E-MAIL: [e-mail]
E-MAIL ONLY: j [e-mail]
gre e. wyatt@unitedwater. com
j [e-mail]
gary. prettyman@unitedwater. com
walton. hill@unitedwater. com
debra.visconti@ unitedwater.com
marshall.thompson@unitedwater. com
KEVIN H DOHERTY
I.JNITED WATER MANAGEMENT
AND SERVICES CO
2OO OLD HOOK ROAD
HARRINGTON PARK NJ 07640
E-MAIL: [e-mail]
heather@mcdevitt-miller. com
CERTIFICATE OF SERVICE