20150917Staff 153-166 to UWI.pdf

DONALD L. HOWELL, II
DAPHNE HUANG
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 12t33 4-03 18
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.
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CASE NO. UWI-W-15-01
NINTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
UNITED WATER IDAHO INC.
I
, l.-i i
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Donald L. Howell and Daphne Huang, Deputy Attomeys General, request that United
Water provide the following documents and information as soon as possible, or no later than
THURSDAY, OCTOBER 8, 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.
NINTH PRODUCTION REQUEST
TO UNITED WATER IDAHO SEPTEMBER I7,2OI5
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. 153: As a follow up to Production Request No. 92,please provide
documentation of any legal easements or other legal provisions for road use that were obtained
with the purchase of the Marion Smith property.
REQUEST NO. 154: As a follow up to Production Request No. 92,please provide
documentation regarding any future plans for use of the Marion Smith property.
REQUEST NO. 155: Please provide a detailed comparison analysis of the costs for
power before the Marion Smith property was purchased and the costs (including generator
purchase, land, operation and maintenance and all other costs) of the power provided by the
generator on the Marion Smith property.
REQUEST NO. 156: As a follow up to Production Request Nos. 103 and 109, please
provide a cost-benefit analysis for project C15G005 AMI Network. Staff has received the
vendor cost comparison provided in response to Production Request No. 103.
REQUEST NO. 157: As a follow up to Production Request No. 109, please provide
contracts and cost-benefit analyses for the following projects: C14K201 Headquarters
Relocation, Cl2J950 System Enhancements, C14Jl06 PeopleSoft and C14Jl07 Power Plan. For
those projects that are allocated to Idaho, please identify the allocation percentage for Idaho and
on what basis it is applied to the projects. Please include within your response the calculation
components of the allocation percentage.
REQUEST NO. 158: Please provide the number of mailings and postage expenses for
each month from January 2011 to present.
REQUEST NO. 159: Referencing the e-billing option, please provide running totals by
month of the number of enrollees from Jan20l1 to present.
NINTH PRODUCTION REQUEST
TO LTNITED WATER IDAHO SEPTEMBER I7,20I5
REQUEST NO. 160: Please provide current savings and the expectations of postage
savings anticipated by the e-billing and e-pay options.
REQUEST NO. 161: Please provide the hours and benefit dollars related to personal
use of company vehicles that occurred for each year from 20ll to present.
REQUEST NO. 162: Following up on Production Request No. 111, please provide the
capitalization ratio and dollar amount for each of the following positions' compensation used for
capital projects for2014 and 2015 to date.
o Accounting Clerk
o Construction Coord
o Cross Conn Control Specialist
o Field Customer Serv Supv
o General Mgr
o Manager Customer Service
o Manager Finance
o Manager Operations
o Mechanic
. Mgr Finance & Rates
o Mgr Production
o Staff Assistant
o Water Quality Spec
REQUEST NO. 163: Following up on Production Request Nos. 4 and 111, please provide a
list of all the specific target incentives for the following positions, please include the amount
awarded for each of the incentive levels in2014 and 2015 to date.
o Accounting Clerk
o Construction Coord
o Cross Conn Control Specialist
o Field Customer Serv Supv
o General Mgr
o Manager Customer Service
o Manager Finance
o Manager Operations
o Mechanic
. Mgr Finance & Rates
o Mgr Production
o Staff Assistant
o Water Quality Spec
NINTH PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 SEPTEMBER 17,2015
REQUEST NO. 164: Please provide a list and documentation supporting the
requirement for all pension payments paid or planned, with dates and amounts, for 2015 but not
yet paid as of July 31,2015.
REQUEST NO. 165: Following up on Production Request No. 11, Please provide a
schedule showing at least the following for M&S Fees by year from 2011 to present:
o A list ofeach cost category to be allocated.
o The total M&S Fees by category and in total.
o A list of each affiliate.
. The allocation ratio and calculation method for each category of M&S Fees to each
affiliate.
. The dollar amount allocated or assigned to each affiliate by year and category.
Please provide this schedule in its native electronic format with formulas intact.
REQUEST NO. 166: Following up on Production Request No. 84, please provide the
amounts allocated to each affrliate for the categories mentioned in the response to Production
Request No. 84 for the years 201 1,2012,2013, and20l4.
DATED at Boise,Idaho, this / ThO^rof Septemb er2Ol5.
Technical Staff: Patricia Harms (153-157)
Joe Terry (158-166)
i:umisc:prodreq/uwil5. I dhdjhrpsjbmechjbojtphtcmmac prod req 9 to UWI
NINTH PRODUCTION REQUEST
TO LINITED WATER IDAHO
uang
ttorney General
SEPTEMBER I7,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7th DAY OF SEPTEMBER 2015,
SERVED THE FOREGOING NINTH 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
2019 N 17TH STREET
BOISE TD 837092
E-MAIL: [e-mail]
E-MAIL ONLY: [e-mail]
gres. wyatt@unitedwater. com
i erry. healy@unitedwater. com
gary.prettyman@unitedwater. com
walton.hill@unitedwater. com
debra.visconti @ u nitedwater.com
marshal I.thompson@unitedwater. com
KEVIN H DOHERTY
UNITED WATER MANAGEMENT
AND SERVICES CO
2OO OLD HOOK ROAD
HARRINGTON PARK NJ 07640
E-MAIL: kevin.doherty@,unitedwater.com
heather@mcdevitt-miller. com
CERTIFICATE OF SERVICE