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MORNING VIEW CO-IDAHO PUBLIC UTILITIES
PO BOX 598
RIGBY, ID 83442-0598
Invoice
H ~': C ::: !Date Invoice #
LOill t1t\H .-1 ~.\\ 8: ~ 0
2/23/2007 1512
Bill To
" , , ,,
. ; Ie ,i i ~i'l rUU\. "I
, '
UTiLrflEs COiAiJi ~ l
Allen Bivins
3980 E 200 N
Rigby, ill 83442
O. No.Terms Project
Due on the 1st
Quantity Description Rate Amount
Detail Of Operating Expense - 1 Acre 35.35.
Customer Surcharge For Contingencies
Total $40.
208- 745-0021
MORNING VIEW WATER CO. INC.
3996 E. 200 North
POBox 598
Rigby. Idaho 83442
!llll!11 i lJg-.:i\:\,:I~HlI~,'ij!..(L\\':~I,n\:!
0 rJ If j,:J: '" 7 /Ji P, : .
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LEGAL NOTICE
--,
MQrning View Water Company, Inc. has filed an application with the Idaho Public
Utilities-Commission-r-equesting-a ratecine..~ase-o-Bhiny...fivepercentA tbirty-five~ -
percent increase would add the following amounts to your bill; ~ Acre $7.70 per
month, Yz Acre $10.10 per month, and 1 Acre $12.50 per month.
A rate increase is necessary to pay the increased cost of power, taxes, salaries,
repairs, maintenance, general operation costs, and to recover the depletedcontingency fund.
Ail increase in revenue is necessary for Morning View Water Co.. Inc. to continue
service without interruption.
Morning View Water Company last filed a rate case in September 2002. The
Commission granted a much smaller increase than was requested.
Any questions or comments may be directed to our office or to the Idaho Public
Utilities.
Morning View Water Co.,lnc.
3996 E. 200 N.
P~O:Box:598.
Rigby, Idahu'83442 ,
208- 745-0029
Idaho Public Utilities
472 W. Washington
O. Box 83720
, Boise~ Idaho 83720-0074
208-800-432~369
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SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTU..ITIES COMMISSION
PO BOX 83720
BOISE. IDAHO 83720-0074
(208) 334-0320
BAR NO. 1895
Street Address for Express Mail:
472 W. W ASlllNGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMl\flSSION
IN THE MATTRROF THE APPl.ICATIONOF )
MORNING VIEW WATER CO., 1Ne. TO
REVISE AND INCREASE RATES CHARGEDFOR WATER SERVICE.
CASE NO. MNV-W-O2-
COMMENTS OF
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commissloll, by and through its
attomey of record., Scott Woodbwy, Deputy Attorney General. and submits the following
commc:nl.. in rQ.ponsc to Lhe Notice of AppliC"dtion, Notice of Modified Pro(.-edure and Notice of
CommentIProtest Deadline issued on May 15, 2002.
On April 26 2002. Nolan Gneiting. president ofMoming View Water Co., Inc. (Morning
View; Company) filed an Application with the Idaho Public Utilities Commission (Commission)
requesting authority to increase rates for water service by $30 a month. an increase of 136%.
Current authorized tariff rates for Morning View are a $22 per month flat fee plus a public
drinking water fee of $6.67 per year. Base.rates have not been changed since June 21, 1990.
GENERAL
The Application was based upon the water company s average operating results tor the
last three years (1999-2001). Staff visited the Company s offices on May 16 2002 to audit the
STAFF COMMENTS JUNE 5, 2002
financial records of the Company for the three years upon which the Company s request was
based.
Morfurig VieW WateiC Orfipanyhas ridf filed' 'A:m1ua lRepOrt'Withthetdaho 'PubJi
~iIities(J()111miSS~()r1.sifice199LStafrhashadnUlIleroUscoIitacts with the 'owner, Mr. Nolan
Gneiting,regarding his failuretO:filetherequirec:irep()r~.S fiiffhasseve.ta.ltime&m the ,past
attempted to petforma. 1ihari.ciala1.1dit of the C().t1:Ip8riy s()p~rations~. Each audit was
discontinued due to a lack of adequate records.
The Company has made considerable improvement in its ability to provide adequate
documentation regarding its expenditures. During its ream audit.. Staff was able to track most
expenditures to determine whether or not they were just and reasonable. Staffhas made
numerous adjustments to the financial data submitted in the Company s Application. These
adju.c;tmentc; are detailed iTl AttachmeTlt~ A-4 and A-5 to these commeTlt~.
Mr. Gneiting owns three separate business entities, Morning View Water Co. (utility)
Morningview Homes (real estate company) and Landco Building and Development Co. (land
development and home construction). Mr. Gneiting doe8 not adequately segregate his various
business,oac tiviti es .
'€~~
t1mv'2in.t:ifu!'tb.e van(')i!s blJ.Siness en tj'ti&'isciommitt 0\ed . atid"num.eroUs '
:,' ""' . '' "" "
t.)
, '
xp~ d.l t.Ui es 'froJjj .,
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the ~pcobmi accPu.n Fbaye ':beei:viriapp i"tjp~ IX. iD. cl t1Qed 85M: 0 mitt g
View
.~~
Co~"experises~
Staff believes that it has adequately separated costs not associated with operation of the
water utility from the financial data included in the Company s Application. Based upon its
analysis of the Company, Staff has determined that an increase in pro forma gross revenues of
49.0% or $7,244 is justified.
During the course of its investigation, Staff discovered that the Certificate of
Convenience and Necessity No. 314 issued by this Commission bas a rjpographieal error
identifying the service area to be ",ithin Section 30, Township 4 North, Range 38 East. The
Range is incorrect and should be 39 East. In addition, Staff learned that the water system has
expanded beyond the service area approved by the Commission.. The Company has extended its
service approximately Yz mile west of the certificated area. The legal description of the area .now
be.ing served is lhe Norlh Yz of lhe Northeast ~ of Section 30, Township 4 North, Range 39 East
(lhe original service are"d) and lhe North Y:z of Ihe Northwest YJ of Section 30, Township 4 North,
Range 39 East (the expansion area). The Commission received a letter :trom the Company on
May 31, 2002, requesting a revision to its Certificate to .include the expansion area.
ST AFro COMMENTS JlJNE 5, 2002
RESUL TS OF OPERATIONS
Attachments A-I through A-3 present a side-by-side comparison of the fInancial data
submitted. in the Company s Application with 8ta1I"s post audit adjusted. results tor the years
1999, 2000 and 2001. Attachment A-I compares the Company s 1999 reported net loss of
($10,312.74) with Staffs adjusted net loss for the year of ($2 629.73). The difference is the
result of numerous adjustments identified by adjustment number in the last column of the
attachment. The details of the adjustments for 1999 are shown on the top of Attachment A-4.
The . ma j 0 Ii tj"U f!ilie a djtiSOOen1#ai eLf #~p 'en dJ:taJ;eg!t1UJ;t ~t 0 pri a telYs h out d' h ave'.beenc: barged
tothe Ti3tidco'bfu.9ness.~tiOD..;Landco is the developer of four of the five subdivisions served
by the water company. The initial installation of a water system in a subdivision is the
responsibility of the subdivision developer. The Commission s Rule 103 for Small Wafer
IMufJi1nio; I"'-emJt11 ~ 1hat1he developer1"eCover!; tbe mitial CO!;t of the water ~y!;tem through the
'5ale-Df!ots. It fiuther presumes that the water system is contributed by the developer to the
water company resulting in no initial investment by the wate.r company in the development.
Other adjustments include items that should be capitalized as investment rather than expensed
persona! expenses of the owner. expenses that should be shared with other business entities and
property ta.."Ces.
Property taxes have been removed because of the special treatment used for dete.m:riiring
appraised value of utilities in Idaho. The Idaho State Tax Commission conducts appraisals of
utilities. Those appmisals depend heavily upon the Idaho Public Utilities Commission
determination of valuation for rate making pwposes. As discussed above, this Commission
assumes the initial water system is co.ntributed to the water company by the developelS.
Therefore, the valuation determined by the Co.mmission is zero until major compo.nents fail and
havc to be replaced with new investment. The Idaho State Tax Commission would therefore
consider the valuation to be zero.. resulting in no. property taxes.
-staff~~'fI:re,;ifd ijfioiSf#'t9lfliJt(~i()Jl wlI (rind! cared. tliaf~ If.. Ghei titt g has. .
18.i l~ .b!; tetUrJitJIa C -(jriiiri i ~siOO'-s.A RiJ.uat Rep 6~Fo rms d.~i ttfn l1ID. e co cefu 1 n de.rs . The
Idaho. State Tax Co.m.mission therefo.re assigned an arbitra.tyvaluatio.n of$60.000 to the system.
Had Mr. Gneiting filed /.he annual reports to this Commission and to /.he Slate Tax Commis:.ion
/he appraised valuation for (be W"dter system would have bcc::n properly established at zero. The
Staff also discovered that at least one of the well lots (included in the water company valuation)
has been separately appraised by IeffeI50n County and therefore has been counted twice
STAFF COMMENTS JUNE 5. 2002
resulting in double taxation on the property. Mr. Gneiting should immediately be in contact with
both the State Tax Commission and Jefferson County to correct the appraised valuation. StatI
has removed these taxes. The taxes were assessed due to water company managerial error and
should not be passed onto customers. Correcting the assessed valuation will eliminate these
taxes in the future.
Attachment A-2 compares the Company s 2000 reported net loss of($12,439.90) with
Staff's adjusted net loss for the year of ($1 020.92). The difference is the result of numerous
adjustments identified by adjustment number in the last column of the attachment. The details of
the adjustments for 2000 are shown on the bottom of Attachment A-4. Adjustments are similar
to those discussed above for 1999.
AttachmentA-3 compares the Company s 2001 reported net loss of ($6 685.50) with
StafFs adju.o;;led Tlel loss for the year of ($134.26). The difference is the remllt of numerou.o;;
adjustments identified by adjustment number in the last colunm of the attachment. The details of
the adjustments for 200 1 are shown on Attachment A- 5. Adjustments are simil8I' to those
discussed above for 1999. In addition. the Company s requested office space rent allowance of
$3.000 has also been removed on Attachment A- 3 but is addressed later on Attachment A- 7.
Attachment A-6 is a side-by-side comparison of the Company s Staff Adjusted Income
Statements for the three-year period. similar in format to the schedule attached to the Company
Application. It is apparent from looking at this schedule that the Company is moving toward
profitability as customers are added to the system.
Attachment A- 7 is a Pro forma schedule of operating results. This schedule builds rl.pbti.
the adjusted 2001 Income Statement from Attachment A-6. The intent is to annualize and
normalize certain items and provide for expenses not actually incurred but reasonable.
First, Staffhas normalized the revenues that the Company would collect from its existing
56 customers on an annualized basis. This adjustment adds $2 411 to the Company s reported
revenues for 2001.
Second, Staffhas normalized the Company s water testing expenses. The frequencies of
specific water tests vary. Some tests ace required monthly. Othet's have a frequency
quarterly, mmwilly. semi mmwilly. every 3 years IIIld every 6 years. This adjuslmcnt ~-prCHds the
cost of each test over its required frequency. OVcl' lime, the averdgc annual testing expense is
$750 for each water source. Mr. Gneiting has informed Staff that the Idaho Department of
STAFF COMMENTS JUNE 5, 2002
Environmental Quality has declared the aquifer from which Morning View draws water a well
field requiring only one set of tests regardless of the number of wells.
The Company in its Application requested (and actually paid to an affiliated company,
Landeo) office rent expense in the amount of $3 000 annually. During discussions with Mr.
Gneiting, Staff determined that the office space requirement for the water company was 100
square feel A phone call placed to a local commercial landlord by Mr. Gneiting produced
quote of $0.79 per square foot per month for office space. Staff independently searched the
Internet and found a realty company in Idaho Falls with commercial rental space available.
Those properties had monthly costs of $0.37 to $ 1.25 per square foot per month. Staff believes
that the $0.79 per square foot quote is reasonable. The building within which the Company
conducts its business is not owned. by the water company but rather by its affiliate Landco. Were
this space not availahle, the water company would have to seek space elsewhere fTom a non-
affiliated company. This allowance replaces the Company s requested $3,000 per year
allowance with an allowance of $948.
The last two pro forma adjustments are to provide compensation to Mr. Gneiting for the
time he spends managing and ma1tlUlining the water system. Ifhe were to hire a third party for
these activities, the water company would incur labor costs. Mr. Gneiting has not drawn a salary
from the Company. It is reasonable for him to expect to be compensated for his effort. Mr.
Gneiting requested an allowance of $10 000 per year in the application. The Company employs
a part-time employee to help with the office tasks and who often checks the pressure tanks as
welL At this time with only 56 customers connected to the system and a total of 149 lots on the
system (approximately 400/0 fill), Staff does not believe a $10,000 annual salary is justified for
the part-time operation of the water system. Staff has substituted a managerial allowance of
$4,160 (4 hours/week at $20/hour) and a maintenance allowance of $2.496 (4 hours/week at
$12/ hour). Staff's adjusbnents represent an allowance of approximately 20% of a 40-hour week
for Mr. Gneiting s time. 'St1iJI~li~v~t1liit'"Glleitingasth~deveI()~ra.;aiid\fu)ofthe
subijivisi onsri1ustffii'prppt!rc:dtotib:;t;tbstf.tIIc;ofthcop crating (Jas ts until. such .time .ss .the
suWl'Vj~i&tls.reachareas9.riaJ)le:fi1lIeV~tofJ()%tQ80%. As customers connect to the system
more of IY1r. Gnciting's time will be required bul!here will also be additional revenues to support.
reasonable int.Teases in his co.mpcnsation. SlaLTs pro fonna resulls produce a ne1loss for !he test
year 2001 of($5,414.32).
ST AFro COMMENTS ruNE 5, 2002
RATE BASE, DEPRECIATION AND REVENTm REQUIREMENT
Attachment A-8 is a calculation of the Company s rate base, depreciation expense and the
total revenue requirement StatiO believes is justitied in this case. The top part of this schedule
develops a rate base and depreciation expense tor the Company that Stair believes is reasonable.
The rate base is the investment the Company bas in physical assets that were not contributed by
developers. The items identified here arc investments the Company recorded as operating
expenses that Staff removed in its previous expense adjustments. The Company is allowed to
record and recover depreciation expense on these assets and earn a reasonable return on the net
undepreciated investment (rate base). The rate base determined by Staff is $6,373.66.
Depreciation expense on these assets is $596.79 annually.
The lower portion of Attachment A-8 is the calculation of total revenue requirement for
Morning View Water Company. A 12% return on the rate hase determined ahove produce!; a
return requirement of $764.84. This return must be grossed up to provide for an income tax
allowance. Staff used the minimum Idaho State tax rate- of 8% and the minimum federal tax rate
of 15% (after state tax deduction) to develop a pretax requirement of $978.99. The pro forma
2001 operating expenses of $20.452.24 from Attachment A- 7 and the depreciation expense of
$596.79 are added to the return to produce a total revenue requirement of$22,O28.02. Tills
revenue requirement is $7,244.02 greater or 49% more than the annualized revenue the Company
would collect from its current 56 customers at existing rates.
RATES AND SYSTEM DESIGN
As calculated by Staff, the annual revenue requirement determined by Staff is $22 028.
If this revenue is recovered. from all eustomclS with a unifonn customer charge, such as the
$22.00 per customer per month rate currently in place, thc rate would go to $32.78 per month.
This is an increase of $10.78 per month or 49%.
Although the system is not metered there is another rate design alternative that Staff
believes is more equitable. The five subdivisions served by Morning View Water are
predomin.a.ntly composed of lots in. three different sJus. The lots are quarter-acre, half-acre or
one-a('Te in size. The meter at the well indicates (hat f.he averdge cuswmer uses approximately
000 gallons per month in f.he lowest winter month and more than 10 times that amount in the
highest summer month, approximately 124 000 gallons. The extremely large amount of water
per customer pumped in the summer months indicates very substantial amounts of outside water
STAFF COMMENTS JUNE 5, 2002
use, presumably lawn and garden watering. Since larger lols have more potential for this kind of
use, a different monthly rate can be determined for each lot size. One such rate design that
recovers the Company s revenue requirement would charge customers on quarter-acre lols the
existing rate of$22.00 per month, balt:'acre lot customers would pay $29.75 per month and
customers on one-acre lots would pay $37.50 per month. There are two quarter-acre lot
customers, 30 half-acre lot customers and 24 one-acre lot customers. This rate design assumes
no increase for customers on quarter-acre lois, a 35% increase for customers on half-acre lots and
a 70% increase for customers on one-acre lots.
Complete equity in water bills is only achieved when every customer is metered and
every customer pays only for the water that he or she uses. Nearly all lots in the five
subdivisions were developed with meter boxes such that all that is required to meter the system is
the meter and some as.e;;ociated plumhmg, Mr. ('meiting estimates these coste;; to he approximately
$300.00 per service. The cost of metering, reading meters and calculating bills amounts to a few
dollars per month per customer. Along with equity as previously discussed, me.tering brings
some other advantages. It de.creases water consum.ptio~ which increases system water pressure
and delays the need tor additional pumping capacity and/or water storage facilities.
Staff does not recommend metering at this time but instead. proposes rates by lot size.
However, as additional water supply is needed or water pressure falls to unacceptable levels even
with such practices as alternate day lawn watering, all customers should be metered to capture
the benefits previously discussed. Morning View should plan on this transition in the next two
or three years.
The Idaho Department of Environmental Quality reviews water S".fstem plans to
determine ifwatcr volumes and pressures arc adequate. DEQ has approved Morning View
sys tc m. How CN e r~D ftiQ rpqriirqsaU systCtrjS"W;i tl1i116 IY- th ~11h~ Sciis t() JJ1(: is. 16 ha V'c tW ~or11l6rc
wells~y.lo~e customers. Mof1lingYi~\VWaterJ:J.asthree we11s. Qneofthey.rellsisnot
eCfI.JiPPe(f\'YithapuiriparidmQMJl'iI'11r1 n9tl;O:nn.~ted.t9ilie~~. The other two weIls are
identified as the large well and the small well. The large well is capable of producing 400 GPM
and the small well produces 150 GPM. The large well is providing the needs of the customers at
the c urren l Lime. AIl'ar!clilion tj.lval vcfi~ji~tO.pX:l1 pet lY.wJID.C(.:tth ~. s.mall wen .iO' lh e." ~YStc:JD.
To ~ JJ, void ~(J I ouiag c::siiV1i. en "the largc&WHFcq Uipmcm t 18' m' nee(luf rtp air ~ lli b . srnMI .W eU
needstobema~'DpCI'3tio&ttlLast win~ some repairs needed to be made on the large well~hmd customers were-without water for two or three days.
STAFF COMMENTS JUNE 5, 2002
Morning View Water's Tariff consists of two Schedule No. l's. One contains the current
flat rate charge of$22.00 per month for water consumption and the other a once a year charge
trom each customer tor the Department of Environmental Quality's Annual Assessment. The
DEQ tee has been incorporated in the over-all revenue requirement recommended by Statl" in this
case and need not be recovered through a separate tariff schedule.
CONSUl\tfE R COMMENTS
To date, three petitions from customers of Morning View Water have been received. One
petition was signed by 39 households; each of the other two petitions were signed by
individuals. The total number of signatures on the three petitions is 77. The Company initially
stated that it has 53 customers, although a more recent customer list shows 56 customers. Some
cu.~tomers readily acknowledged signing multiple petitions. Tn addition, eleven written
comments were filed. Many customers request that the Idaho Public Utilities Commission
(IPUC) hold a hearing in this case. Staff recommends that a workshop and hearing be held in
Rigby or another location near Morning View s service territory.
In the petitions and comments, customers expressed concern with the magnitude of the
requested increase. They also are concerned at the Jack of water pressure, the number of times
water is totally off, the slowness of repair when there is a problem, the safety of the water
supply, and the validity of the system costs as reported by the system owner. The Commission
authority is to set rates which are just and equitable to both the people and to the corporation.
(Idaho Code ~9 61-301 through 61-329). Some of the issues mised by customers concern the
development itself instead of the water system and are not under the purview of this
Commission. Subdivision covenants arc beyond the scope of the Commission s authority. The
request by customers to change the covenants so that residents can elect their own board and run
the water system, or allow them to drill their own well cannot be addressed by the IPUc.
Customers did not indicate that they had approached Mr. Gneiting '\Vith an offer to purchase his
water system so they can form a homeowners association and eliminate the need for regulation
by the IPUC. Water quality and the associated water safety issues fall Ullder the prima.ty
jurisdiction of Idaho Department of Environmental Quality (DEQ). which is rc.-ponsible for
monitoring water quality and enforcing environmenf.a.llaws and regulations.
The Company understands that it is required to follow the Commission s Utility
Customer Relations Rules (UCRR) and Utility Customer Information Rules (UCIR) as well as its
ST AFro COMMENTS JUNE 5, 2002
own approved tariffs for rates and charges as authorized by the Commission. Minor changes are
needed to bring Morning View s bills and disconnect notices into compliance with those rules.
The Company is working with Statrto make the necessary corrections.
The Company s "Utility Agreement~ provided to customers says a $25 reconnect tee will
be charged in the event service is disconnected. A $25 reconnect fee falls within the reasonable
range of charges the IPUC has allowed other utilities for the reconnection of service. The
Company also charges a "finance charge" of $. 75 or 1.25%. whichever is larger, when a payment
is late. Apparently, this "Imance charge" is a late payment fee assessed on past due bills. To
date, the Company has not requested, nor has the Commission granted, approval of either a
reconnection or a "finance charge.'" Historically, the Commission has not allowed a late
payment fee when a utility has the ability to discontinue service for nonpayment, or when the
utjliLy s charge for ba.:;ic service js billed a month in advance. Morning View can and doe..:;
disconnect service~ therefore, Staff does not support a late fee or finance charge. Staff does
support implementation of a $25 reconnection charge.
The utility has required. eusiomers to sign a "Utility Agreement" in order to receive
service. The utility certainly can require a written application to identi..f)1 customers. However ,
the "U tility Agreement" appears to be a written contract that goes beyond the scope of an
application for service and it contains inaccurate information. Item 4 of the Agreement contams
rates which have not been approved by the Commission: $22 for each month plus a rate of $.45
per thousand over 20 000 gallons up to 100,000 gallons and $.35 cents per 1 000 gallons of water
used in excess of 100 000 gallons. The Agreement goes on to say that "'rates shall be subject to
adjustment and shall be approved by the Public Utilities Commission ofllie State ofIdaho." The
IPUC has not approved a usage-based rate. Indeed, such a rate design would be inappropriate
because customers do not have metered service.
Item 7 of the Agreement discusses deposits. Statements made regarding deposits are in
keeping with Commission Customer Relations Rules. The last sentence in Item 7 stated that "the
above captioned occupant is to remain responsible to the water company until a new occupant
pe.rsoJlally signs for the accoWlt with Morning View Water Co., Inc." A utility can require a
reasonable prior notice for a requesUo disconnect service for a customer moving to give the
utility time to s(:hedule the water shut off. An attempt to hold one party rc::.-punsible for water
service until another party signs up for service at that location is unreasonable and should not be
allowed. FurthemlOre. the utility is allowed to pursue collection of amounts owed by a previous
STAFF COMMENTS JUNE 5, 2002
customer, but it can only attempt to collect from that customer, not a new party moving into the
same address. The amounts owed remain with the customer of record., not the location of
service. Mr. Gneiting has agreed to discontinue use of the "Utility Agreement" which will make
changes to the "Utility Agreement" unne-eessary.
STAFF RECOMMENDATION
Staff recommends that a workshop and hearing (for public testimony) be scheduled in
Rigby or another location near Morning View s service territory.
Staff recommends that an annual revenue requirement of $22,028 be approved for
Morning View Water.
Staff recommends that monthly rates for Morning View Water be established by lot size
a~ follows:
LOT SIZE
0 Acre - 0.4 Acre
4 Acre - 0.8 Acre
8 Acre and Larger
MONTHLY RATE
$22.
29.
37.
Staff recommends that the "Schedule l - Public Drinking Water Fee" tariff be cancelled.
Slaffrecommends that a $25.00 reconneclion charge be approved and shown on
Schedule 2 - Miscellaneous Charges.
S#I ff -C() mrrre1t ci~" tltat thecl "5QGPM'weUbe,cmmected into.the, system '.and ., be
opera tio,:naI .""itlriri 3 Ooay:;,.()-rtliis(jrd,~r,CIlldth Ii tMI'.Grieitingno tifytheConmrissi on" bY-Jetter
when:"tbat1tas'OCct.ttted. .
Staff-recotttllm11ds.tbat Mom1ng View be required to bring its bills and notices into
cempliance-with the Commission s Customer Relations RuIes and Customer Information Ruies.
Staff recommends that the Company cease its practice of assessing a "finance charge" or
late payment fee on past due bills.
Stat!" recommends that the Company discontinue use of its presently dratted "Utility
Agreement. ..
Staff recommends that the Commission coaect the Company s existing Certificate No.
314 to properly identify the Company s existing service area to be within Section 30.iownship
N~Ra.ge39tasl
STAFF COMMeNTS JUNE 5~ 2002
Staff recommends that the Commission notice its intent to amend the Company
Certificate No. 314 to include the North Y2 of the Northwest V4 of Section 30, Township 4 North
Range 39 East
Respectfully submitted this day of June 2002.
Scott Woodbury
Deputy Attorney General
Technical Staff: Bob Smith
Marge Maxwell
Kcith Hessing
SW:i:umisccommenlvnm"",1)2.15wnume5kh
STAFF COMMENTS JUNE 5, 2002