20081010Crowley Affidavit.pdf

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ORIGINAL
°ECE.IVC'"JI,". .,' .1,.,1Dean 1. Miler ISB #1968
McDEVIT & MILLER LLP
420 West Banock Street
P.o. Box 2564-83701
Boise,ID 83702
Tel: [phone]
Fax: [phone]
joe(fmcdevitt-miler.com
200S OCT I 0 PM I: 32
IDAHO PUBLIC
UTILITIES COMMISSION
Attorneys for Teton Springs Water & Sewer Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
TETON SPRINGS WATER AND SEWER
COMPANY LLC, INC, FOR THE ISSUANCE
OF A CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY, FOR
APPROVAL OF RATES AND CHARGES FOR
WATER SERVICE, FOR APPROVAL OF
RULES AND REGULATIONS GOVERNING
THE RENDERING OF WATER SERVICE.
STATE OF IDAHO )
County of Ada )
) Case No. TTS-W-08-01
)
) AFFIDAVIT OF LARRY A.
) CROWLEY
)
)
)
)
)
Larry A. Crowley, being first duly sworn upon an oath, deposes and says:
1. I have been retained by Teton Springs Water and Sewer Company LLC ("Teton
Springs") as its consultant in the preparation of this general rate case. My training and
experence in the area of public utility rate setting is set forth in Exhibit 4 attached to my Direct
Testimony, filed herein. I am over the age of21 years and make this affidavit based on my own
knowledge.
AFFIDAVIT OF LARY A. CROWLEY- 1
2. I prepared Exhibit No. 10 which is attached to the Company's Reply Comments. Exhibit
No. 10 presents Teton Springs' rebuttal position on the financial issues in this case. Exhibit No.
i 0 is tre and correct to the best of my knowledge.
3. The Staff Comments recommend disallowance of engineering fees incurred by Teton
Springs. Based on my review of Company records, it appears that Teton Springs contracted with
CH2MHil in 2007 to conduct a comprehensive plant inventory and valuation of the Teton
Springs' water and sewer systems. The work performed by CH2MHILL was prudent and useful
in the preparation of the obligatory certificate of convenience and necessity and rate filings to the
Idaho Public Utilities Commission, as are required to establish a regulated water utility. The
total engineering expenses incurred by Teton Springs in 2007 amounted to $8,672. These
expenses were included in the Company's initial rate fiing in Case No TTS-W-08-1. The
Commission staff eliminated all the engineering fees paid by Teton Springs (See Staff
Comments Attachment A, adjustment No 5). The fees covered the work required to classify the
operating water and sewer assets of the Company by account number and fuction. Without the
work product produced by CH2MHil, the Company could not have adequately prepared its
application for a certificate of convenience and necessity, which included a complete system map
and listing of all operating assets required for such an application.
On rebuttal, the Company realized that it had inadvertently allocated all the engineering
fees to the water utility rather than splitting the fees between the water and sewer operations. On
rebuttal the Company is proposing that only one-half of these expenses be allocated to the
regulated water utility ($4,336) and that these fees be included as par of the Company's rate
case application expenses and amortized together with the other expenses incured by the
AFFIDAVIT OF LARY A. CROWLEY - 2
Company in preparng its rate case. The information provided by the engineering study has been
used and referenced in preparng the case filed before the Commission.
4. Based on my knowledge of on-going regulatory requirements imposed on companes
subject to the jursdiction of the Commission, including preparation of an annual report, auditing
expenses and responding to Commission reporting requirements, I believe an allowance of
$2,500 per year is a reasonable allowance for recurng regulatory expense. I have included this
expense on line 27, page 1 of Exhibit No 10.
5. Furher your affant sayeth not.
Dated this /1) r day of October, 2008.
/f~~LarrA.C~
State of Idaho )
:ssCounty of Ada )
On this L day of October, 2008, before me, the undersigned, a Notar Public in and
said State, personally appeared Larr A. Crowley, known or identified to me to be the person
whose name is subscribed to the within instruent, and acknowledged to me that he executed the
same, and that the statements therein contained are tre to the best of his knowledge and belief.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my official Seal the
day and year in this certificate first above written.
&~Residing at: ~
Commission Ex ~2-
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AFFIDAVIT OF LARY A. CROWLEY- 3
r
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CERTIFICATE OF SERVICE
I hereby certify that on the i&¥àay of October, 2008, I caused to be sered, via the
method(s) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
iiewell(fpuc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Scott Woodbur
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, ID 83720-0074
jjewell~puc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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AFFIDAVIT OF LARY A. CROWLEY- 4