20150504Staff 1-14 to UWI.pdf

BRANDON KARPEN , :
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION ilii f,],ii!, -i, PIl 3, O IPO BOX 83720
BOISE, IDAHO 93720-0074 :-,,1,t.-,' ,, .
(2os)334-0357 l-| il.i.i -'t 1.., ,..,'.,,,...,...
IDAHO BAR NO. 7956
Street Address for Express Mail:
472 W , WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT )
APPLICATION OF UNITED WATER IDAHO, ) CASE NO. UWI-W-15-02
INC., AND THE CITY OF BOISE,IDAHO FOR )
APPROVAL OF AN AGREEMENT FOR ) FIRST PRODUCTION
REPLACEMENT AND OPERATION OF FIRE ) REQUEST OF THE
HYDRANTS AND RELATED RATE MAKING ) COMMISSION STAFF TO
TREATMENT.) UNITED WATER IDAHO INC.
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Brandon Karpen, Deputy Attorney General, requests that United Water Idaho Inc. (United
Water) provide the following documents and information as soon as possible, but no later than
MONDAY, MAY 25,2015.
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.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO MAY 4,20t5
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. 1: Please provide an investment and expense estimate by year for each
of the next 40 years associated with the proposed transfer of hydrant ownership to United Water.
Please clarify whether the estimates include or do not include inflation.
REQUEST NO. 2: Please provide an annual revenue requirement calculation for the life
of the hydrants from the date of the first replacement until the last replacement has reached the
end of its useful life (80 years). Please include documentation supporting the components of
revenue requirements including deferred taxes (tax and book depreciation over the life of the
project). Please also include the original electronic format, with calculations and formulas intact.
REQUEST NO.3: What benefit will United Water customers realize if the proposal is
approved?
REQUEST NO. 4: What consequence will United Water customers suffer if the
proposal is not approved?
REQUEST NO. 5: In addition to the estimate provided on page 5, lines 6-10 of Greg
Wyatt's testimony, please estimate the impact on customer rates for each successive year over
the 40-year transition period.
REQUEST NO. 6: Please explain why the hydrant ownership transfer is proposed on a
newly installed basis instead of an immediate transfer of all existing City-owned hydrants.
REQUEST NO. 7: Costs associated with Boise City ownership of fire hydrants are paid
through taxes, and taxes are assessed on the basis of property value. Costs associated with
United Water ownership of fire hydrants are generally recovered through customer charges,
which vary based on meter size. Because cost recovery would be much different under United
Water ownership than under Boise City ownership, please discuss the impacts and equity on bills
for the following types of customers:
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO MAY 4,2075
a large multi-story office building with little or no outdoor water use,
a large volume customer in which usage is exclusively or primarily for lawn and
landscape watering,
an average residential customer,
a large commercial or industrial customer with little or no outdoor water use.
REQUEST NO. 8: For those customers who would realize a substantial change in their
due to transfer of hydrant ownership, would any of them realize a coresponding change in
level or quality of fire protection? Please explain.
REQUEST NO. 9: Please provide documentation that supports a 4}-year depreciable
life for the hydrants UWI is planning to replace under this Application. Please also provide the
depreciation life for hydrants UWI currently owns and maintains. If these two amounts are
different, please provide supporting documentation as to the reason for the difference.
REQUEST NO. 10: Please provide documentation that supports the tax election UWI
plans for the hydrants it is planning to replace under this Application. Please also provide the tax
depreciation for hydrants UWI currently owns and maintains. If these two amounts are different,
please provide supporting documentation as to the reason for the difference.
REQUEST NO. 11: Please provide the costs to operate and maintain the hydrants UWI
is planning to replace, operate and maintain under this Application. Please provide within your
response the documentation used to calculate this amount.
REQUEST NO. 12: Please provide a list of hydrants requiring replacement under this
Application and all documentation of costs (including salvage value and/or cost to replace) that
supports the $765,000 capital investment contained within this Application.
REQUEST NO. 13: Please provide the supporting documentation including calculations
contained in original electronic format of the $l.45 per customer and $.24 per bill calculations
with formulas intact.
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO
a.
b.
MAY 4,2015
REQUEST NO. 14: Please provide any financial analyses prepared by United Water
and/or any related companies related to the Application. Please include within your response
elecfionic files with formulas intact.
DATED at Boise, Idaho, Ais Qbaay of May 2015.
Technical Staff: Rick Sterling (1, 3-8)
Patrioia Harms (2, 9-14)
i:umisc:prodreq/uwil5.2bkrpsph prod req I to UWI
FIRST PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 MAY 4,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF MAY 2015, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
srAFF TO UNITED WATER IDAHO INC' IN CASE NO. UWI-W-15-02, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
GREGORY P WYATT
UNITED WATER IDAHO INC
PO BOX 190420
BOISE rD 83719-0420
EMAIL: [e-mail]
CITY OF BOISE
ATTN: PUBLIC WORKS DIRECTOR
I5O NORTH CAPITOL BLVD
BOISE ID 83702
DEAN J MILLER
MoDEVITT & MILLER LLP
420 W BANNOCK
BOISE TD 83702
EMAIL: [e-mail]
DOUGLAS K. STRICKLING
BOISE CITY ATTORNEY'S OFFICE
I5O NORTH CAPITOL BLVD
BOISE ID 83702
EMAIL: [e-mail]
CERTIFICATE OF SERVICE