20150904Staff 149-152 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 12133 4-03 t8
IDAHO BAR NOS, 336618370
Street Address for Express Mail:
472W. 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.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. UWr-W-15-01
EIGHTH PRODUCTION
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, SEPTEMBER 25, 2015.
This Production Request (PR) 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.
EIGHTH PRODUCTION REQUEST
TO LINITED WATER IDAHO SEPTEMBER 4, 2015
In addition to the written copies provided as response to the requests, please
Excel and electronic files on CD with formulas activated.
REQUEST NO. 149: In response to Staff Production Request No. 58, Company
Witness Greaves stated that UWI had "recently adopted a new standard for radio based meter
reading without driven collectors" and "an AMI system is underway". Please provide a narrative
description of the system design and the detailed implementation plan, including timelines for
installing the necessary infrastructure and equipment, meter replacement, and customer
notification.
REQUEST NO. 150: Please provide sample copies of notices, letters, brochures or
other communication materials regarding the AMI system prepared for distribution to UWI
customers.
REQUEST NO. 151: On page 16 and 17 of Company Witness Cary's direct testimony,
she discusses a $35,000 donation made by UWI to the Boise Watershed Environmental
Education Center for an interpretive trail to be constructed near the West Boise Wastewater
Treatment Plant. Will UWI's donation be used for a specific purpose?
REQUEST NO. 152: Please explain in greater detail the plans and timelines for
construction of the trail, what its purpose is, and how it relates to wise water use and UWI's
water conservation program.
DATED at Boise, Idaho, thl Lf tnOurof September 2015.
Technical Staff: Beverly Barker (149-150)
Chris Hecht (l5l-152)
i :umisc : prodreq/uwi I 5. I dhdjhrpsjbmechjbojtphtcmmac prod req 8 to UWI
EIGHTH PRODUCTION REQUEST
TO LINITED WATER IDAHO 2
,II
SEPTEMBER 4,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF SEPTEMBER 2015,
SERVED THE FOREGOING EIGHTH 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
MoDEVITT & MILLER LLP
420 W BANNOCK
BOISE TD 83702
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
20I9 N 17TH STREET
BOISE TD 837092
E-MAIL: [e-mail]
E-MAIL ONLY: [e-mail]
gre g. wyatt@unitedwater. com
j erry.healy@unitedwater. com
gary.prettyman@unitedwater. com
walton. hill@unitedwater. com
debra.visconti @ 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]
[e-mail]
CERTIFICATE OF SERVICE