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HomeMy WebLinkAbout20150828UWI to Staff 128,130.pdf(208) 343.7s00 (208) 336-6912 (For) McDevitt & Miller r.rpLawyers :ii:lf,Llil In 420 West Bannock Stteet :', ,. . p.O. Box ?;,67.-g371t:i ili-l-ii,-i:: ', Boise,Idaho 83702 August 28,2015 P["1 l: I I .'' ,'.,,..iiglias. F. McDenitt DeanJ. (oe) Miller Celeste trL Miller Via Iland Delivety JeanJewell, Secteary Idaho Public Utilities Commission 472W. Washington St. Boise,Idaho 83720 Re: U\[I-W-15-01 Deat Ms. Jewell: Enclosed for filing, please find an original and three (3) copies of United Water Idaho, Inc.'s First Response to the Commission Staffs Sixth Ptoduction Request Nos. 128 and 130. Kindly retutn a file sramped copy to me. Very Truly Yourq McDevitt & Miller LLP b,tu12- DeanJ. Mller DJU/r,l Cc United Watet Idaho, Inc. Dean J. Miller (lSB No. 1968) McDH/ITT & MILLER LLP 420 West Bannock Street P.O. Box 2564,-83701 Boise, lD 83702 Tel: 208.343.7500 Fax 208.336.6912 ioe@mcdevitt-miller.com Attomey for United Water ldaho, lrtc. IN THE MATTER OF THE APPLICATION OF UNITED WATER IDAHO INC. FOR AUTHORIW TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO i , il Gase No. UW-W-15{,1 UNITED WATER IDAHO INC.'S FIRST RESPONSE TO SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF i';i l: ll BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION United Water ldaho lnc., ("United Water') by and through its undersigned aftorneys, hereby submits its First Response to the Commission Staffs Sixth Production Request Nos. 128 and 130. DATED this flltay of August, 2015. UNITED WATER IDAHO INC. UNITED WATER IDAHO INC.'S FIRST RESPONSE TO SIXTH PRODUGTION REQUEST OF THE COMMISSION STAFF.l DeaE J. Miller (lSB No. 1968) Attomey for United Water ldaho, lnc. CERTIFICATE OF SERVICE I hereby certify that on the -<Say of August, 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 P.O. Box 83720 Boise, lD 83720-0074 i iewel l@ puc. state. id. us Donald L. Howe!!, ll Daphne Huang Deputy Attomey Genera! ldaho Public Utilities Commission P.O. Box 83720 Boise, ldaho 83720-007 4 don. howell@puc. idaho.sov daphne. huano@puc. idaho.qov Brad M. Purdy Attorney at Law 2019 N. 17th Street Boise, lD 83702 bmpurdv@hotmail.com Fed. Express Email Hand Delivered U.S. Mail Fax Fed. Express Email Hand Delivered U.S. Mail Fax Fed. Express Email IL &lta tJ ,C UNITED WATER IDAHO INC.'S FIRST RESPONSE TO SIXTH PRODUCTION REQUEST OF THE COiTMISSION STAFF.2 UNITED WATER IDAHO INC. GASE UW!-W-15-01 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Roger Greaves 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. RESPONSE NO. 128: The policy and procedure for overhead is in the attached exhibit (Request No. 128 exhibit 1.pdf). Additionally, the calculated overhead rates are included from the time period of 2012 to the present, on a month by month basis (Request No. 128 exhibit 2.pdf). United Water Capital Expenditure Control Policy and Procedure Manual Capital Overheads United Water has a standard policy for capturing and allocating capitalized overheads. A common overhead policy is required to ensure that all costs are tracked and allocated in a uniform and consistent manner across all companies. Capitalized overhead charges are capital related costs incurred by executing capital project related activities and include three main types of expenses: Labor, ContractorlN4aterials and General Expenses. Also included are benefits and vehicle allocation costs that are applied to labor hours as part of the Benefit and Vehicle allocation processes. Operating Expenses should not be charged to capital overhead. Local operating company General Manager or Regulated Segment Controller shall make the appropriate determination if a specific charge should be recorded in capital overhead. Detailed descriptions for water utility expense accounts can be found in "Uniform System of Accounts for Class A Water Utility" under the 600 series accounts for "Water Operation and Maintenance Expense Accounts". General There are five components of capital overhead charges:. Local overhead chargeso Segment overhead chargeso Corporate overhead charges o Vehicle allocations. Benefits allocations All capital overheads are allocated monthly using the Project Costing system. The overhead costs are collected each month in accounts 10700 (reg segment) or 12 I 00 (for the non-reg segment). The naming convention for these overhead projects is: 6.1 o Project IDo Activity Uniled Water Capital Control Expenditure Policy and Procedure Manual Revised 20 I 2 Page 35 Overhead_BU# where BU# Business Unit Number Local (Local), Segment (Reg), Corporate (Corp) The Capital Overhead allocations are run in the following order: l. Local 2. Segment 3. Corporate The Vehicle and Benefit Allocation Processes are run each month before the Capital Overhead Allocation is begun. As a result, Vehicle costs and Benefit Overheads will be included in the Local overhead base. Segment overheads are compounded on top of the Vehicle, Benefit and Local charges and Corporate Overheads are calculated on all costs including Vehicle, Benefits, Local and Segment overheads. Listed below are several key points relating to the overhead allocation process. Capital allocations for Local, Segment and Corporate overheads will be applied to current month CWIP expenditures in Project Costing, including direct purchases, vehicle and benefit costs. CWIP expenditures are defined as costs charged to account 10700 (water & wastewater) or 12120 (non- reg) All capital-related expenditures must be charged to a CWIP account. All charges made to CWIP must have a Project ID and an Activity, in order to be tracked in Project Costing. PeopleSoft requires that a Project ID and Activity be entered when entering costs to a CWIP account. Overhead allocation rates will be determined by UW M&S engineering and accounting at the beginning of each year for each Business Unit, and should be monitored and adjusted, if necessary, on a regular basis throughout the year. The Segment and Corporate overhead rates are set by the UW M&S Company for all Business Units. Local overhead rates are calculated and approved for each Business Unit by the Segment Controller for that unit. Benefit and Vehicle rates are calculated for each Business Unit (Details as to how the rates are determined will be discussed in subsequent sections of this document). Each overhead pool should be allocated as completely as possible at each year end. All capital overhead charges at the Local Business Unit must be made to the "Local" Activity. Segment and Corporate Activities should not be charged. United Water Capital Control Expenditure Policy and Procedure Manual Revised 2012 Page 36 6.2 Overheads will be applied to preliminary Survey and Investigation projects. These projects will be tracked in the Project Costing system using the "M" (water) or "X" (sewer) project coding described in the capital Expenditure Policy and Procedure Manual. Overhead is not calculated on AFUDC. Overheads are not calculated on accruals if Source type MISC ACCRL and the Category ACCRL ACCRL is used when posting to the General Ledger. Overheads will not post to any General Ledger entry that uses a Source type of MISC and a Category type of TRNFR. This coding should not be used except in special circumstances when it is necessary to move costs between projects and additional overheads are not required. Each of the overhead allocations will be distinguished by a separate Category (ex Local, Seg, Corp) within project costing. The category field is a breakdown within the Source field OHEAD. Reports can be run on the Category field to gather total overheads for a period or to retrieve a breakdown by overhead category. Benefits and Vehicle costs are identified by BENEF and VEHIC respectively. Overhead will be tracked in the Project Costing module using reports written for that purpose (ex. Report UWPC60M provides a breakdown of costs for any project. Running the Overhead_BU# project on a life to date basis provides the user with the amount of overheads that have not been distributed to date) The General Ledger should not be used to track overheads or any other project. All project tracking should be done from the Project Costing module. Local Overheads Local Overheads are capital related expenditures incurred by local Business Units and include three main types of expenses: Labor, Materials and General expenditures. Also included are benefits and vehicle costs that are applied to labor hours as part of the Benefit and Vehicle allocation processes. Where possible, all costs should be charged direct to a valid project ID. However in some cases, charging to a valid approved project is not practical, such as time spent reviewing capital budgets. In this case, the time will be captured as local overheads and will be allocated to all projects through and overhead allocation process. United Water Capital Control Expenditure Policy and Procedure Manual Revised 20 I 2 Page 37 The Local Overhead charges should be restricted to costs that are definitely capital related and are not chargeable to a specific capital project. The Local Overhead charges are combined into a single total in order to calculate an overhead rate to allocate local expenditures. The Local Overhead percentage is determined by taking the budgeted Local Overhead costs and dividing by the Gross Capital Expenditures for the Business Unit excluding Local, Segment and Corporate Overheads and AFUDC. Total Budgeted Local Overhead Charges Overhead Yo- --- (Gross CapEx - Local, Segment, Corp Overhead Charges - AFUDC) The Local Overhead allocation is run each month after all costs have been recorded including the Benefit and Vehicle allocations. The Local Overhead Rate will be charged to every dollar in project costing charged to CWIP, including the Benefit and Vehicle allocation costs. Local engineering management should review the local overhead rates periodically and make adjustments by using the above calculation formula accordingly. Materials Materials associated with specific capital projects should always be charged direct to that project. Materials purchased for use on multiple non-specific projects should be charged to the Local Overhead project. An example of this is stone. which is usuallv purchased in bulk and used in many projects. Labor Payroll Expenditures associated with a specific capital project should be charged directly to that project. Time related to capital, but not specifically related to a specific project, should be charged to the Overhead Local project. Direct charging of small increments of time to specific projects is unrealistic. Common sense should be used when determining whether to charge directly to projects or to the Local Overhead project. All employee time spent on capital activities must be charged to a CWIP account, either directly to a capital project ID or to the Local Overhead United Water Capital Control Expenditure Policy and Procedure Manual Revised 2ol2 Page 3g 6.3 project. Time should be charged to the where the employee spends their time. General Expenditures General Expenditures are costs that cannot be charged directly to a specific Project ID but are recognized as a component of the capital process. Rent paid for office space for engineering personnel would be an expenditure that should be capitalized in the Local Overhead account. Other costs would include engineering supplies, telephone costs, etc. The decision as to what items should be capitalized as General Expenditures in the Local Overhead should be reviewed and approved by the local Company General Manager or Regulated Segment Controller. Segment Overheads Segment Overheads are costs incurred by employees of the Regulated Segment of United Water M&S Co. and are comprised mainly of Labor, Consulting and General Expenses. Also included are benefit costs that are applied to labor hours as part of the Benefit allocation process. Where possible, all costs should be charged direct to a valid approved project ID. However in some cases, charging to a valid approved project is not practical. For example, time spent reviewing capital budgets normally cannot be charged to a specific project. In this case, the time will be captured as Segment Overheads and will be allocated to all projects through an overhead allocation process. The Segment Overhead project should not be used erroneously or as a catch-all but should be restricted to costs that are definitely capital related and are not chargeable to a specific capital project. The Segment Overhead costs are combined into a single total in order to calculate an overhead rate to allocate local expenditures. The Segment Overhead percentage is determined by taking the total budgeted Segment Overhead costs and dividing by the Gross Capital Expenditures for the Business Unit less Segment and Corporate Overheads and Interest to construction (AFUDC). Total Budgeted Segment Overhead Charges Seg Overheado/o: (Gross CapEx - Seg & Corp Overhead Charges - AFUDC) United Water Capilal Control Expenditure Policy and Procedure Manual Revised 20 I 2 Page 39 6.4 The Segment Overhead allocation is run each month after all capital costs have been recorded including the local Overhead, Benefit and Vehicle allocations. The Segment Overhead Rate will be charged to every dollar in project costing charged to CWIP, including the Local Overhead, Benefit and Vehicle allocation costs. The segment overhead rate needs to be reviewed and adjusted periodically based on the latest capital investment level. Corporate Overheads Corporate Overheads are capital related costs incurred by employees of United Water M&S Co. and are comprised mainly of Labor, Consulting and General Expenses. Also included are benefits that are applied to labor hours as part of the Benefit allocation processes. Where possible, all costs should be charged direct to a valid approved project. However in some cases, charging to a valid approved project is not practical. For example, time spent reviewing capital budget is not normally charged direct to a project. In this case, the time will be captured as Corporate Overheads and will be allocated to all projects through an overhead allocation process. The Corporate Overhead project should not be used erroneously or as a catch-all but should be restricted to costs that are definitely capital related and are not chargeable to a specific capital project. The Corporate Overhead costs are combined into a single total in order to calculate an overhead rate to allocate local expenditures. The Corporate Overhead percentage is determined by taking the total budgeted Corporate Overhead costs and dividing by the Gross Capital Expenditures for the Business Unit less Corporate Overheads and Interest to construction (AFUDC) Total Budgeted Corp Overhead Charges Corp. Overhead%o: (Gross CapEx - Co.p Overhead Charges - AFUDC) The Corporate Overhead allocation is run each month after all costs have been recorded including the Local Overhead, Segment Overhead, Benefit and Vehicle allocations. The Segment Overhead Rate will be charged to every dollar in project costing charged to CWIP, including the Local Overhead, Segment Overhead, Benefit and Vehicle allocation costs. The corporate overhead rate should be reviewed and adjusted periodically based on the latest investment level. Transnortation Transportation costs on local Business units are to be charged to account 18420 Clearing-Transportation. These costs are then allocated to expense, capital, other Uniled Water Capital Control Expenditure Policy and Procedure Manual Revised 2ol2 page 4o 6.5 6.6 based on a Vehicle allocation process within the PeopleSoft system. This allocation does not apply to United Water M&S employees. Each local Business Unit is to identify those employees with access to Company vehicles or who receive a Vehicle allowance for use of their vehicle. The Local Company managers are responsible for reviewing this list semiannually to ensure that the list is complete and accurate. They are also responsible to ensure that any changes are made within the PeopleSoft system to correct any inaccuracies. A signed copy of this review is to be mailed to the Segment Controller's office, where it will be reviewed and filed as part of the annual CODIS compliance. The allocation of the Vehicle costs in PeopleSoft is accomplished by taking the balance in the 18420 Clearing - Transportation account at month end and allocating it to the current month payroll dollars of those employees included by the local Company manager on the vehicle list described above. Only the time of those employees are used in the vehicle allocation. The entry to record the data is to debit expense/capital/other and credit account 18420. The 18420 account should be zero at the end of each month. Emplovee Benefits Benefits are employee related expenses which are deemed to be a part of an employee's compensation and should follow the employee's time wherever it is charged. Benefits will be added to all labor charged to any capital project, including labor charged to a capital overhead project. The Benefit Overhead is based on an allocation of costs charged to certain benefit accounts in the General Ledger which have been identified as being appropriate for re-allocation from expense. This re-allocation is based on time sheets prepared by each employee. When capital is charged on the time sheet, a portion of the employee benefits are transferred from expense to capital to reflect the fact that these costs should follow an employee's time. Examples of costs included in the benefits calculation are: o Payroll taxes paid by the employero Pension Costso Post Retirement Benefit Costso Group Medical Costso 40lK Costs. Worker Compensation costs Because benefits don't flow into the General Ledger evenly throughout the year, a "Predicted monthly benefit amount" is calculated and used in the Benefit allocation process. The "Predicted monthly benefit amount" is calculated using the employee benefits from the annual operating plan and dividing those benefits by 12. United Water Capilal Control Expenditure Policy and Procedure Manual Revised 2012 Page 4l For example, if total benefits for the year are $1,200,000, the "Predicted monthly Benefit amounf'would be $100,000. This amount is allocated out each month based on total payroll costs. The amount is divided by total payroll dollars and is applied to each dollar of payroll in that month. If 20%o of the payroll costs are charged to capital, 20o/o of the fringes should follow. The $100,000 is billed out in the Fringe benefit allocation process which debits account 10700 CWIP and credits account 18410 Clearing- fringe Benefits. At Month end, another PeopleSoft process moves the actual Benefit costs on the General Ledger to the 18410 account as a debit. This allows anyone to see whether benefits have been over or under billed for the period simply by looking at the 18410 account. A debit balance in the account means that Benefits have been under billed, while a credit balance indicates that Benefit costs were overbilled. At year end, the balance in the account must be zero as all Benefits are required to be billed out during the current calendar year. Throughout the year the balance in account 18410 is monitored and adjustments are made to the "Predicted monthly benefit amount" as needed to be sure the account zeros by year end. Benefits are applied to all payroll dollars during the month and follow the labor to whatever account they are charged on the time sheets. United Water Capital Control Expenditure Policy and Procedure Manual Revised 2012 Page 42 United Water ldaho Overhead Rates United Water ldaho United Water M&S UW M&S - Regulated 1 2012 2012 2012 2012 8.30% 1.10o/. 3.50% 1 1 1 13.320/o United Water ldaho United Water M&S UW M&S - Regulated 2 2 2 2 2012 2012 2012 2012 9.90% 1.20% 1.30% 12.660/. United Water ldaho UniieO Water M&S UW M&S - Regulated 3 3 3 2012 zotz 2n12 2012 9.90% 1.20o/o 'l .30%o 3 12.66% United Water ldaho United Water M&S UW M&S - Regulated 4 4 4 2012 2012 2012 2012 9.30% 1.20o/o 1.30o/o 4 12.050/0 United Water ldaho United Water M&S UW M&S - Regulated 5 5 5 2012 2012 2012 2012 9.30% 1.20o/o 1.30o/o 5 12.05o/o United Water ldaho United Water M&S UW M&S - Regulated 6 6 6 6 2012 2012 2012 2012 9.30% 1.20o/o 1.300/o 12.050/o United Water ldaho United Water M&S UW M&S - Regulated 7 7 7 7 2012 20t2 2f'L2 2012 9.30% 7.20% 7.93% 72.75% United Water ldaho United Water M&S UW M&S - Regulated 8 8 8 8 2012 2012 2012 2012 9.30% 1.20% 7.93o/o 12.75% United Water ldaho United Water M&S UW M&S - Regulated 9 9 o I 2012 2012 2012 2012 930% !.200/o L.93% L2.75% United Water ldaho United Water M&S UW M&S - Regulated 10 10 10 10 20't2 2012 2012 2012 7.38o/o 7.840/o 2.68% \2.290/o United Water ldaho United Water M&S UW M&S - Regulated 11 11 11 2012 2012 2012 8.t4o/o 1..g40/o 2.68% United Water ldaho Overhead Rates 11 2012 t3.08% United Water ldaho United Water M&S UW M&S - Relulated 12 12 12 12 2012 2012 2012 2012 8.L4% L.84,r/" 2.20% L2.55o/o United Water ldaho United Water M&S UW M&S - Regulated 1 1 1 2013 2013 2013 2013 8.L{o/o L.84% 2.20% 1 L255% United Water ldaho United Water M&S UW M&S - Regulated 2 2 2 2013 2013 2013 2013 8.46% L.89% t8L% 2 L2.5lo/o United Water ldaho United Water M&S UW M&S - Regulated 3 3 3 3 2013 2013 2o1g 2013 8.46% L.89% l.8lo/o 125r% United Water ldaho United Water M&S UW M&S - Regulated 4 2013 2013 2013 2013 8.46% t.89% t.8L% 4 4 4 72.57% United Water ldaho United Water M&S UW M&S - Regulated 5 2013 2013 2013 2013 8.460/o t.8g% L3t% 5 5 5 L2.SLo/o United Water ldaho United Water M&S UW M&S - Regulated 6 2013 2013 2013 2013 8.46% L.89% L.8L% 6 6 6 12.5lo/o United Water ldaho UW M&S - Regulated UW M&S - Regulated 7 7 7 7 2013 2013 2013 2013 8.46% L.89% t.8L% L2.5t% United Water ldaho United Water M&S UW M&S - Regulated I 8 2013 2013 2013 2013 9.74% L.O5% 7.4L%I 8 12.46% United Water ldaho United Waier fUaS UW M&S - Regulated o I I 2013 2013 2013 9.74% 1.05% t.4LYo L2.46% United Water ldaho United Water M&S 10 10 2013 2013 7.L9% 4.84% United Water ldaho Overhead Rates UW M&S - Regulated 10 2013 2.75% 10 2013 L5.47% United Water ldaho United Water M&S UW M&S - Regulated 11 11 11 11 2013 2013 2013 2013 4.90% 4.84% 2.75o/o L3.OO% United Water ldaho United Water M&S UW M&S - Regulated 12 12 12 12 2013 2013 2013 201g 4.9Oo/o 3.Os% 1.08% 9.270/o United Water ldaho United Water M&S UW M&S - Regulated 1 1 I 2014 2014 2014 2014 7.50% 5.so% o.ooo/o 1 73.47% United Water ldaho United Water M&S UW M&S - Regulated 2 2 2 2 20t4 2074 2014 2074 7.so% 5.5Oo/o 0.00% L3.4Lo/o United Water ldaho United Water M&S UW M&S - Regulated 3 3 3 3 2014 2074 2074 2014 7s0% 5.5Oo/o o.o0% L3.41o/o United Water ldaho United Water M&S uw Mas - Regulaied 5 4 4 4 20L4 20L4 2014 201.4 7F0% 5.50o/o O.OOo/o L3,4L% United Water ldaho United Water M&S UW M&S - Regulated 5 4 2074 2014 20t4 2074 7.so% 5.50% O.OOo/o5 5 L3.4L% United Water ldaho United Water M&S UW M&S - negutated 6 6 6 6 2-0L4 7.50%o 5.50% o.oo% 20L4 )ou ioln t3. Lo/o United Water ldaho United Water M&S UW M&S - Regulated 7 20L4 2074 20t4 2074 7.50% s.so% o.oo% 7 7 7 L3.410/o United Water ldaho United Watei ruAS UW rVrAS - netutateO 8 2074 20t4 20t4 2074 7.s0% 5.50% o.oo% 8 8 8 73.47% United Water ldaho United Water M&S UW M&S - Regulated 9 9 9 20L4 20L4 2014 7.5oo/o 5.50% o.oo% United Water ldaho Overhead Rates 9 2014 t3.410/o United Water ldaho United Water M&S UW M&S - Regulated 10 10 10 10 20L4 20L4 20L4 20L4 7.50% 5.50% o.oo% t3.4L% United Water ldaho United Water M&S UW M&S - Regulated LL LL LL LL 20L4 20L4 20t4 20L4 7.so% 5.50% o.ooo/o L3.4t% United Water ldaho United Water M&S UW M&S - Regulated L2 L2 t2 L2 20L4 20L4 20L4 20L4 7.50% 5.50% o.oo% t3.47% United Water ldaho United Water M&S UW M&S - Regulated 1 I 1 2015 2015 2015 2015 7.500/o s.so% o.oo% I 13.47o/o United Water ldaho United Water M&S UW M&S - Regulated 2 2 2 2 2015 2015 2015 20L5 7.50% 550% O.OOo/o L3.4to/o United Water ldaho United Water M&S UW M&S - Regulated 3 3 3 3 2015 2015 201_5 2075 7.50% 5.50% O.OOo/o 13.4L% United Water ldaho United Water M&S UW M&S - Regulated 4 2015 2015 iots 2015 7.50% 5s0% o.o0% 4 4 4 t3.4Io/o United Water ldaho United Water M&S UW M&S - Regulated 5 2015 2015 2015 2015 8.9t% 5.50% o.oo% 5 5 5 t4.90% United Water ldaho United Water M&S UW M&S - Regulated 6 6 6 6 2015 2015 2015 2015 8.91o/o sso% o.oo% 14.9Oo/o United Water ldaho United Water M&S UW M&S - Regulated 7 7 7 7 20't5 2015 2015 2015 8.91% 550% o.oo% L4.90% United Water ldaho United Water M&S UW M&S - Regulated 8 8 8 2015 2015 2015 8.9to/o 5.50% 0.00% UNITED WATER IDAHO INC. GASE UWI-W.I5-01 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Jarmila Cary 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. RESPONSE NO. 130: Please see attached file #130 Bad Debt 2011-2014.x\sx. Exhibit 10, Adjustment 14 details the book revenue and bad debt expense along with the adjustments required for comparability for years 2012 through 2014. Adjustments to both bad debt & revenue were necessary due to: 1) the 2013 accounting standardization effort where leak and similar bill adjustments were no longer reflected as billing cancellations reducing revenue, but recorded as increases to uncollectible expense, 2) infrequent adjustments for the allowance for bad debt reserve, and 3) to exclude the extraordinary 2012 credit related to the IDEQ Drinking Water Fee payment. The uncollectible accounts expense rate included in the rate case of 0.4460/o, is the average of the total adjusted bad debt and revenue figures from years 2012 through 2014.