20150820Staff 125-130 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 121334-03 r8
IDAHO BAR NOS .336618370
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys 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.
CASE NO. UWr-W-15-0r
SIXTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
UNITED WATER IDAHO INC.
BEFORE THE IDAHO PUBLIC UTILITIBS COMMISSION
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
MONDAY, AUGUST 31, 2015.r
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.
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attomey at [phone].
SIXTH PRODUCTION REQUEST
TO I-INITED WATER IDAHO 1 AUGUST 20,2OI5
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. 125: Following up on Production Request No. 21, please provide a
listing of the services paid for in Corporate M&S fees (Account 90850) that explain the increase
in those expenses from 201 I to 2014.
REQUEST NO. 126: Following up on Production Request No. 21, please provide an
explanation for the decrease of $770,636 in Regulated M&S fees (Account 90851) from 2013 to
2074, and the increase of $805,272 to Corporate M&S fees (Account 90850) in the same period.
If these changes are related please explain what the relationship is and how they interact.
REQUEST NO. 127: The following questions pertain to Pro-Forma Tax Depreciation:
l. Please provide the underlying calculation of Pro-Forma Tax Depreciation - State and
Pro-Forma Tax Depreciation - Federal filed in Exhibit No. I l, Schedule 8, Line Nos.
l0 and 15.
2. Please provide the underlying calculation of Pro-Forma Tax Depreciation - State and
Pro-Forma Tax Depreciation - Federal contained within the response to Production
Request No. 69 Exhibit No. 1 1 , Schedule 8, Line Nos. 10 and I 5.
3. Please explain and reconcile these differences.
REQUEST NO. 128: Please provide a copy of the policy and procedures for overhead
loading including accounts and amounts used with related explanation as to their use in 2012,
2013,2014, and 2015 to date. Please include within your response the methodology used to
apply each overhead and the related percentage.
REQUEST NO. 129: Please provide a description of the method by which AFUDC is
calculated and applied. Please include copies of any related policies and procedures.
SIXTH PRODUCTION REQUEST
TO LINITED WATER IDAHO AUGUST 20,2OI5
REQUEST NO. 130: Please provide a table for uncollectible accounts that includes
Sales Revenue, Uncollectible Accounts and Uncollectible Account Rates for the past four years.
Please include within your response a comparison to the uncollectible rate included within the
Company's case and explanation for any differences between the rate in the case and that in
response to this request.
DATED at Boise, Idaho, this be$urof August 2015.
uang
ttorney General
Technical Staff: Joe Terry Q25-126)
Patricia Harms (l2l -130)
i :umisc: prodreq/uwi I 5. I dhdjhrpsjbmechjbojphtcmmac prod req 6 to UWI
SIXTH PRODUCTION REQUEST
TO UNITED WATER IDAHO AUGUST 2O,2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF AUGUST
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO UNITED WATER IDAHO, N CASE NO. UWr-W-15-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK
BOISE ID 83702
E-MAIL: j [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE TD 837092
E-MAIL: [e-mail]
E-MAIL ONLY: iarmila.cary@,unitedwater.com
gre e. wyatt@unitedwater. com
j erry.healy@unitedwater. com
gary. prettyman@unitedwater. com
walton. hill@ unitedwater. com
d e b ra.visco nti (o u n ite dwate r. co m
marshal l. 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-mil ler. corn
CERTIFICATE OF SERVICE