20240315Staff 1-22 to CAP.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
,,EC;EIVED
a`' KIP 15 Pik 3: I-1
'Ll; LIQ
is'�Fi; °:w1
?iT (Al ',!iSSI0N
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CAPITOL WATER
CORPORATION'S APPLICATION TO
INCREASE ITS RATES AND CHARGES FOR
WATER IN THE STATE OF IDAHO
CASE NO. CAP-W-24-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO CAPITOL WATER
CORPORATION
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Capitol Water Corporation ("Company")
provide the following documents and information as soon as possible, but no later than
FRIDAY, APRIL 5, 2024.
This Production Request is to be considered as continuing, and the Company 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 also identify the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 1 MARCH 15, 2024

In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide the general ledger for the years ended December 31,
2022 and December 31, 2023.
REQUEST NO.2: Please provide invoices and/or quotes for rate case expenses
included in revenue requirement.
REQUEST NO.3: Please provide salary percentage increases for each employee for the
years 2018 through 2024. Please list the implementation dates, as well as the increase
percentage. Please also list potential future increases with the projected implementation date.
REQUEST NO.4: Please provide the detailed studies and/or data the Company used to
evaluate compensation of employees.
REQUEST NO.5: Please provide a list of all plant additions similar to the workpaper
provided in the Application titled "Increases to Plant in Service 2023" that have occurred since
2009.
REQUEST NO.6: Regarding the workpaper titled "Pro Forma Plant & Depreciation
Adjustments", please state the completion dates and/or the projected completion dates of the
projects listed.
REQUEST NO.7: Please provide depreciation schedules for Plant in Service for each
item included in rate base.
REQUEST NO.8: Please provide a list of and the quantity of chemicals purchased from
years 2018 through 2024 with associated unit cost price ranges for each year.
REQUEST NO.9: Please provide the Summary Plan Descriptions and any other details
regarding the retirement accounts paid for by the Company and provided for employees.
FIRST PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 2 MARCH 15, 2024

REQUEST NO. 10: Please indicate whether the Company has a 401k matching policy
and what percentage, if any, the Company matches.
REQUEST NO. 11: Please provide the details of the life insurance policy that the
Company provides for employees.
REQUEST NO. 12: Please provide a list of all vehicles owned by the Company.
REQUEST NO. 13: Please indicate if the Company still owns the 2008 Ford F350 as
mentioned in the Application. Please indicate how many miles are currently on the vehicle or
how many miles were on the vehicle at time of disposition.
REQUEST NO. 14: Please indicate the date and number of miles on the 2023 Ford
Ranger XLT when purchased and also latest data regarding the number of miles on the vehicle.
REQUEST NO. 15: Please provide quotes for all vehicles considered before the
purchase of the 2023 Ford Ranger XLT was made. If quotes are not available, please indicate
what other options the Company considered and why the Company chose the Ranger XLT.
REQUEST NO. 16: Please list all features and add-ons that the 2023 Ford Ranger XLT
included at the time of purchase. Please provide supporting documentation on these details.
REQUEST NO. 17: Please state the reasoning for purchasing an XLT model 2023 Ford
Ranger as opposed to the XL base model.
REQUEST NO. 18: Please identify where the cost savings associated with the purchase
of the 2023 Ford Ranger XLT, such as fuel efficiency and lower maintenance costs listed on
page 7 of the Application have been included in the revenue requirement.
#7.
REQUEST NO. 19: Please provide all quotes received for cleaning and rehabbing Well
REQUEST NO.20: Please provide all quotes received for building fences around Well
#4 and Well #7.
FIRST PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 3 MARCH 15, 2024

REQUEST NO.21: Please provide quotes for all options the Company considered for
new billing software.
debt.
REQUEST NO.22: Please detail the Company's process for recording uncollectible/bad
DATED at Boise, Idaho, this 15'h day of March 2024.
Adam Triplett
Deputy Attorney General
[:\Utility\UMISC\PRDREQ\CAP-W-24-01 PR# I.docx
FIRST PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 4 MARCH 15, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF MARCH 2O24,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO CAPITOL WATER CORPORATION, IN CASE NO.
CAP-W-24-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
H. ROBERT PRICE
PRESIDENT
CAPITOL WATER CORP
2626 ELDORADO
BOISE ID 83704
E-MAIL: info(@canitolwatercorv.com
KATHY STOCKTON
2310 W LEMHI ST
BOISE ID 83705
E-MAIL: kantwwkrev(@gmail.com
Kin,1, ill il✓K�/�
S ECRETAkY
CERTIFICATE OF SERVICE