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Home My WebLink About980115.docxSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION) OF UNITED WATER IDAHO INC. FOR) CASE NO. UWI-W-97-6 AUTHORITY TO REVISE AND INCREASE) RATES CHARGED FOR WATER SERVICE.) THIRD PRODUCTION ) REQUEST OF THE )COMMISSION STAFF )TO UNITED WATER )IDAHO INC. __________________________________________) The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests United Water Idaho Inc. (UWI) provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before THURSDAY, FEBRUARY 5, 1998. This production request is to be considered as continuing, and United Water Idaho Inc. or United Water Resources (UWR) is requested to provide by way of supplementary responses, additional documents that you or any person acting on your behalf may later obtain that will augment the documents produced. Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder. REQUEST NO. 75: (Field Req 012-1) Please provide additional detail regarding Staff Field Request No. 005-3 (Starnet Information Technology) including total corporate (UWR) costs, contracts with providers, corporate-wide cost allocation calculations and sample vouchers showing the entries made to the accounting records of UWI. REQUEST NO. 76: (Field Req 012-2) Please provide additional detail regarding Staff Field Request No. 005-2 regarding rate case expense including copies of billings, contracts and detailed support calculations of estimated numbers. Provide this information for both internal and external costs. REQUEST NO. 77: (Field Req 013-1) Please provide a detailed analysis of costs reflected in the test year financial statements and workpapers detailing Mr. Healy’s Adjustment No. 21 for “Information Technology” expenses. (See Field Request No. 005-3) Include detail for each service provided by EDS (Electronic Data Systems) and any other provider, total cost to United Water Resources and all its affiliated companies, and detail of allocation method used. REQUEST NO. 78: (Field Req 013-2) Mr. Gennari’s workpapers, Tab “A”, page 6, Account No. 391B reflect additions of $2,224,853 between 12/31/96 and 2/28/98. Please provide a detailed explanation of each asset represented, its cost, benefits derived and assets replaced. REQUEST NO. 79: (Field Req 013-3) Explain why no retirements are reflected for assets replaced per Request No. 78 above. REQUEST NO. 80: (Field Req 013-4) Provide a schedule showing original cost and accumulated depreciation for each asset replaced per Request No. 78 above. REQUEST NO. 81: (Field Req 013-5) What was the total cost to UWR and all of its affiliated companies for the additions in Request No. 78 above and how were these costs allocated to UWI? REQUEST NO. 82: (Field Req 014-1) In the Company’s last case (UWI-W-96-3) the Commission by Order No. 26671 disallowed a portion of the Company’s vehicle leasing expenses. Mr. Healy’s Adjustment No. 20 indicates that the Company now has annual lease expenses of $271,044. A.Has the Company, since its last case, completed a cost/benefit analysis of leasing vs. owning its vehicle fleet? B.If yes, please provide a copy. C.If no, why not? REQUEST NO. 83: (Field Req 014-2) Please provide a schedule similar to Staff’s Exhibit No. 114 in Case No. UWI-W-96-3 for each company-owned vehicle disposed of in the last five years. REQUEST NO. 84: Please provide copies of the Form 10-K for 1996 and 1997 for United Water Resources. REQUEST NO. 85: Please provide copies of the Form 10-Q for 1996 and 1997 for United Water Resources. REQUEST NO. 86: Please provide a list of all line extension projects undertaken since labor-in-lieu-of-cash was allowed on residential projects. Please include a brief description of each project, the length of the extension, the project cost and whether labor-in-lieu-of-cash was provided by the developer. If labor-in-lieu-of-cash was provided on a particular project, please show remaining itemized charges assessed by the Company. REQUEST NO. 87: Please show peak day demand in the Main service level for 1993 and 1994. Please show peak day demand in the Gowen service level for 1993 through 1997. REQUEST NO. 88: Please provide a map showing the various service levels in UWI’s service territory. REQUEST NO. 89: With respect to project C96A007, please provide an itemized listing of common costs divided by project participants, the portion of the costs paid by UWI and the method used to apportion the common costs. What does UWI estimate these costs to have been had UWI undertaken the project alone? REQUEST NO. 90: Were materials and labor for projects C96A007 and C97D105 competitively bid? If so, please provide the names of the companies bidding the project and the total bid price. If not, why not and who did supply the labor and materials? REQUEST NO. 91: Please provide a copy of the December 5, 1997 agreement between the City of Eagle and UWI as described in response to Staff Production Request No. 12. REQUEST NO. 92: Are master meters installed at all points of interconnection between the systems of UWI and the City of Eagle? If not, why not? If meters have been installed, who paid for them? REQUEST NO. 93: Company witness Linam states in his testimony on page 13, lines 2 and 3, that demand in the Eagle area is currently 2.17 MGD. In response to Staff Production Request No. 18, the Company states that in ten years the demand will be 2.33 MGD when an additional 1,790 customers are served. The increase in demand after significant growth seems unreasonably small. Please explain the small change. REQUEST NO. 94: On page 13, lines 9 and 10, Company witness Linam indicates there is currently a 6 MGD deficiency in the Main service level. Please describe how this deficiency is manifested within the service level. When does the deficiency generally create problems? Where specifically do the problems occur? When did the problem occur in 1997? Please provide all test and/or monitoring information available to support your response. REQUEST NO. 95: In response to Staff Production Request No. 27, the Company indicates that water purchased from Garden City is of a quality that is less than desirable. Is the nature of the problem primary or secondary contaminants? Please provide detail. Please provide a recently obtained water analysis that demonstrates the poor quality of Garden City water. Does the water purchased from Garden City satisfy the contractual obligations of Garden City regarding said supply? If not, please provide detail and indicate what steps the Company has taken (if any) to enforce its contractual rights. DATED at Boise, Idaho, this day of January 1998. _______________________________ Scott Woodbury Deputy Attorney General Technical Staff:Robert Smith Terri Carlock Randy Lobb SW:RL:gdk//umisc/prodreq/ uwiw976.sw3