20240404Staff 23-42 to CAP.pdf

RECEIVED
Thursday,April 4,2024 2:40 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CAPITOL WATER )
CORPORATION'S APPLICATION TO ) CASE NO. CAP-W-24-01
INCREASE ITS RATES AND CHARGES FOR )
WATER IN THE STATE OF IDAHO ) SECOND 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
THURSDAY,APRIL 25, 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.
SECOND PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 1 APRIL 4, 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. 23: Please provide up-to-date and separate geo-spatial system maps
that outline all contiguous water utility systems operated by the Company. The map should
include the location and elevation of major equipment including wells, distribution piping,
storage tanks, booster pumps, shut-off valves, meters, fire hydrants, water treatment equipment,
etc.
NOTE: Please provide this map in electronic format (pdf) which can be scaled and
enlarged to identify all aspects of the system.
REQUEST NO. 24: Please provide a thorough and complete description of the water
system including the following details regarding the system as applicable:
a. The depth, width, length, capacity, construction materials of each well (including
backup wells, if any), and length of time in service;
b. The make, model, type, and rating of each well pump motor, and length of time in
service;
c. The make, model, capacity, and limit switch settings of each pressurized storage tank,
and length of time in service;
d. The make, model, capacity, and limit switch settings of each unpressurized storage
tank/reservoir, and length of time in service;
e. The make, model, and rating of each booster pump and motor, and length of time in
service;
f. The make, model, and capacity of all water treatment equipment, and length of time
in service;
g. The year, make, model, and capacity for backup generation supporting the well
pumps, and length of time in service. Indicate if the generation has an Automatic
Transfer Switch(ATS) or if it must be manually started; and
h. The distribution piping line size and materials specified in the installation, and length
of time in service.
SECOND PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 2 APRIL 4, 2024

REQUEST NO. 25: Please provide detailed information related to the capacity and
sizing of the system and the ability of the system to meet historical and future system peak
demands.
Provided information should include not only capacity or constraints of/or within the
system, but also consumption and consumption at peak periods. Please provide necessary
workpapers in spreadsheet format(such as Microsoft Excel) with formulas intact.
REQUEST NO. 26: For each well used by the water system, please provide the
following:
a. The Idaho Department of Water Resources ("IDWR") Well Tag Number(D-Tag
Number)that is currently on-file with IDWR; and
b. Location(Township, Range, Section, and Tract).
REQUEST NO. 27: Please provide the monthly power bills indicating the amount of
electricity(kWh)used and corresponding electricity cost (in US Dollars) for each well and
booster pump from January 2019 to December 2023. Please provide your responses in
spreadsheet format(such as Microsoft Excel) with formulas intact.
REQUEST NO. 28: Please provide the monthly metered amount of water(gallons)
pumped from each well from January 2019 to December 2023. Please provide your responses in
spreadsheet format(such as Microsoft Excel) with formulas intact.
REQUEST NO. 29: Please provide the monthly metered total customer water usage
data(gallons)by customer types from January 2019 to December 2023. Please provide your
responses in spreadsheet format(such as Microsoft Excel) with formulas intact.
REQUEST NO. 30: Please provide an estimate of total unaccounted water losses due to
leaks, wasted water, etc. by month from January 2019 to December 2023. Please provide your
responses in spreadsheet format(such as Microsoft Excel) with formulas intact.
SECOND PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 3 APRIL 4, 2024

REQUEST NO. 31: Please provide a copy of the Company's latest Idaho Department of
Environmental Quality("IDEQ") Sanitary Survey.
REQUEST NO. 32: Please provide the average monthly pressure data in the main
distribution line from January 2019 to December 2023. Please provide your responses in
spreadsheet format(such as Microsoft Excel) with formulas intact.
REQUEST NO. 33: Please describe the Company's methodology for developing,
managing, executing, and completing Capital Projects in a least cost manner. Please provide a
copy of all Company policies and procedures documenting the process.
REQUEST NO. 34: On page 9 of the Application, the Company discusses Well No. 5
cleaning and rehabilitation($65,761.60). Please provide the following documentation. If any of
the information requested below cannot be provided or is not available,please explain why.
a. Analysis of Need: a justification of need for the project and a cost/benefit analysis
comparing alternatives;
b. Explain how the Company ensured the project was completed at least cost;
c. Project Plan:
i. Initial project scope;
ii. Proposed schedule;
ill. Proposed budget; and
iv. Proposed budget-to-actual expense comparison;
d. Requests for proposals ("RFP") or requests for quotes ("RFQ"):
i. Project requirements and specifications;
ii. RFP/RFQ from winning bid; and
e. Project construction documentation including:
i. Construction contracts, invoices, etc.; and
ii. Contractors change order request(s).
SECOND PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 4 APRIL 4, 2024

REQUEST NO. 35: On page 9 of the Application, the Company discusses the following
items:
1. Cleaning and rehabilitation of Well No. 7 ($91,593);
2. Safety fencing at Well No. 4 and at Well No. 7 for water source protection ($37,510);
and
3. New customer billing software system ($45,000).
For each of the above-mentioned items,please provide the following documentation. If
any of the information requested below cannot be provided or is not available, please explain
why.
a. Analysis of Need: a justification of need for the project and a cost/benefit analysis
comparing alternatives;
b. Explain how the Company will ensure/have ensured the projects are/were completed
at least cost;
c. Project Plan:
i. Initial project scope;
ii. Proposed schedule;
iii. Proposed budget; and
iv. Proposed budget-to-actual expense comparison; and
d. Project construction documentation including:
i. Construction contracts, invoices, etc.; and
ii. Contractors change order request(s).
REQUEST NO. 36: Does the Company expect customer growth? If so,please provide
workpapers and documentation including but not limited to the potential number of customers
and type of customers by year for the next five years.
REQUEST NO. 37: Please provide workpapers showing the calculation that present and
proposed rates produce the revenues shown in Exhibit 6 on lines 8 (Company Proposed Test
SECOND PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 5 APRIL 4, 2024

Year Revenue) and 10 (Revenue Requirement). This should include the billing determinates
categorized by schedule and service size.
REQUEST NO. 38: Please provide a list of all insurance claims that occurred in the
2022 test year along with a brief narrative describing the damages and how they were caused.
REQUEST NO. 39: Please provide supporting documentation for the debenture bonds
listed in the"Costs of Capital" workpaper.
REQUEST NO. 40: Please provide supporting documentation for the note listed in the
"Cost of Capital"workpaper.
REQUEST NO. 41: Please provide supporting documentation for the vehicle tax
recorded on the balance sheet to account 408.13 in 2022.
REQUEST NO. 42: Please provide supporting documentation for the interest and
dividend income recorded on the balance sheet to account 419 in 2022.
DATED at Boise, Idaho, this 4th day of April 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\CAP-W-24-01 PR#2.docx
SECOND PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 6 APRIL 4, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF APRIL 2024,
SERVED THE FOREGOING SECOND PRODUCTIO 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 KATHY STOCKTON
PRESIDENT 2310 W LEMHI ST
CAPITOL WATER CORP BOISE ID 83705
2626 ELDORADO E-MAIL: kantwwkrev gmail.com
BOISE ID 83704
E-MAIL: info(ci)capitolwatercorp.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE