20050713Comments.pdf

DONOV AN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
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472 W. WASHINGTON
BOISE, ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF TERRA GRANDE WATER FOR
APPROVAL OF TARIFF SCHEDULE
NUMBER 2 AND 3 FOR NEW SERVICE
CO NNECTI 0 NS AND RECO NNECTI 0 N
FEES.
COMMENTS OF THE
COMMISSION STAFF
CASE NO. TGW-O5-
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Donovan E. Walker, Deputy Attorney General, in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 29809 on June 23, 2005 , and
submits the following comments.
BACKGROUND
On May 24 2005 Terra Grande Water (TGW) submitted Tariff Schedules No.2 and No.
regarding new service connections and reconnection fees respectively. Tariff Schedule No.2 deals
with new service connections to the Company s system, and was resolved as a tariff advice pursuant
to Order No. 29809.
Tariff Schedule No.3 deals with reconnection fees. This schedule proposes a reconnection
fee of$65.00 during the office hours of8:00 a.m. to 5:00 p., Monday through Friday, and
$100.00 for after hours reconnections. The Company states that this schedule was submitted
because the Company does not currently have a schedule detailing charges for reconnection fees.
STAFF COMMENTS JULY 13 2005
As a small water company with a small customer base, Terra Grande states that it cannot afford to
absorb the immediate financial hit it will take if it must perform reconnection without a means to
recover its costs.
STAFF ANALYSIS - Tariff Schedule No.
Staff has reviewed other water company reconnect tariffs approved by the Commission and
studied the time, effort and costs likely to be incurred by TGW to reconnect a customer. Based on
this review, Staff believes that the amounts proposed by TGW for its reconnect tariff are excessive.
TGW has proposed a reconnect tariff of$65.00 during business hours and $100.00 for after
business hours. The rates proposed by TOW are based on charges from the plumber who serves
TOW for maintenance, repairs and reconnection. The reconnection charges are documented in a
letter from D & D Plumbing in Attachment No.1. Staff finds D & D Plumbing s rates to be
consistent with hourly rates charged by a licensed plumber for service to a residential customer.
However, some of the work being done, as discussed with the owner and TOW's plumber, may
include installing a valve, vault or other equipment and goes beyond what Staff would normally
include in a reconnection charge. Furthermore, there is no reason to believe that the reconnect work
(accessing and turning a valve when there is no meter to be removed) requires an hour of time, even
when including travel time (the distance from D & D's business address to the TOW service area is
5 miles with a driving time of 10 minutes). Staffhas estimated a reasonable time of30 minutes to
perform the reconnect service, which includes 10 minutes travel each way and 10 minutes for the
reconnect. Additionally, there is no reason that this work needs to be performed by a licensed
plumber. A helper or other employee could be used for this work. A helper being paid $10.00 per
hour with a wage multiplier of 2.0 for overheads and profit would result in a cost to TOW of $20.
for the half hour service. This amount is also supported by a review of the approved reconnection
tariffs at other water companies, which shows that the average reconnection charge is
approximately $20.00 during business hours and $30.00 after business hours.
Staff s review also found an unusual service condition where only 50 % of the customers
have a vault with a shut-off valve installed. TOW is installing new vaults and meter sets on an as
needed basis. Staff believes this is appropriate. In particular, a meter vault, shut-off valve and
meter set should be installed, where they do not already exist, any time work is required on a
servIce.
STAFF COMMENTS JULY 13 2005
STAFF RECOMMENDATION
Staff recommends approval of a reconnection charge under Tariff Schedule No.3 of $20.
during normal business hours and $30.00 for non-business hours. These recommended amounts are
lower than the $65 and $100 respectively requested by the Company.
Respectfully submitted this
13
day of July 2005.
Dd'
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Donovan E. Walker
i" t7'/ Deputy Attorney General
Technical Staff: Harry Hall
Carol Cooper
Donn English
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STAFF COMMENTS JULY 13 2005
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FAX NO. : 3222569 Jun. 24 2005 03: 22PM P2
D & D Plumbing
5182 S Valley St
Boise, ill 83709
208-375-4586
June 24, 2005
To Whom It May Concern:
Connecting or reconnecting a water service requires a service call.
A service call is $65.00 minimum which is up to one hour including travel time. This is for a
caU between the hours of 8:00 am to 5:00 pm. All after hours work is charged at $97.50 an
hour.
A TT ACHMENT 1
CASE NO. TGW-W-05-
STAFF COMMENTS7/14/05
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF JULY 2005
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF IN CASE
NO. TGW-05-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE
FOLLOWING:
JOHN R HAMMOND
BATT & FISHER LLP
SUITE 500
101 S CAPITOL BLVD
BOISE ID 83702
BARBARA V CHILD
TERRA GRANDE WATER
10012 ESHELMAN
BOISE ID 83704
CERTIFICATE OF SERVICE