20240506CAP to Staff 23-42.pdf

RECEIVED
2024 May 6, 3:45PM
IDAHO PUBLIC
ROBERT PRICE UTILITIES COMMISSION
PRESIDENT
CAPITOL WATER CORPORATION
2626 ELDORADO ST.
BOISE, IDAHO 83704-5926
208-375-0931
info a,capitolwatercorp.com
www.capitolwatercorp.com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
CAPITOL WATER CORPORATION )
FOR AUTHORITY TO ) CASE NO. CAP-W-24-01
INCREASE ITS RATES AND CHARGES FOR )
WATER SERVICE IN THE STATE OF IDAHO. ) SECOND PRODUCTION
REQUEST RESPONSE
OF CAPITOL WATER
CORPORATION TO THE
COMMISSION STAFF
Capitol Water Corporation provides the following responses to the Second Production
Request of the Commission Staff to Capitol Water Corporation.
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.
COMPANY RESPONSE: A current map of the water system is attached as "PR 23
PDF Map of Capitol Water System."
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 1 MAY 6, 2024
TO COMMISSION STAFF

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.
COMPANY RESPONSE: The Company is continuing to compile the requested
information for items a, b, f, g, and h, and will send the requested information when the research
has been completed. As to items c, d, and e, the Company does not have any storage tanks or
booster pumps. The Company recommends an onsite visit with the Water Operator for a more
thorough understanding of the water system.
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 2 MAY 6, 2024
TO COMMISSION STAFF

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.
COMPANY RESPONSE: The capacity and the sizing of the system can be found in the
Company annual reports, including annual consumption and peak consumption. Historically, the
Company has been able to meet peak system demand. The Company's service area has limited
room for growth; therefore, the Company anticipates it will continue to meet future peak
demand. The Company recommends an onsite visit with the Water Operator for a more
thorough understanding of the water system.
REQUEST NO. 26: For each well used by the water system, please provide the
following:
1. The Idaho Department of Water Resources ("IDWR") Well Tag Number(D-Tag
Number) that is currently on-file with IDWR; and
2. Location (Township, Range, Section, and Tract).
COMPANY RESPONSE: A copy of the requested information, as found on the Idaho
Department of Water Resources, is attached as an excel spreadsheet, "PR 26 Wells with D Tags
and Range Township Location.xls."
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.
COMPANY RESPONSE: The monthly power bills indicating the amount of electricity
(kWh) used and corresponding electricity cost(in US Dollars) for each well (the Company has
no booster pumps) for the years 2019 through 2022 have been provided to Commission Staff in
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 3 MAY 6, 2024
TO COMMISSION STAFF

the Company's annual PPCA filings. Please see Case No. CAP-W-20-01 for the 2019 power
bills; Case No. CAP-W-21-01 for the 2020 power bills; Case No. CAP-W-22-01 for the 2021
power bills; Case No. CAP-W-23-01 the 2022 power bills. Copies of the 2023 power bills are
provided in a zip file, "Power Bills and Journal Entries for 2023.zip."
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.
COMPANY RESPONSE: The monthly metered amount of water (gallons)pumped
from each well from January 2019 through December 2022 has been provided to Commission
Staff in the Company's annual PPCA filings. Please see Case No. CAP-W-20-01, Case No.
CAP-W-21-01, Case No. CAP-W-22-01, and Case No. CAP-W-23-01 for this information.
Copies of the 2023 well logs, which include the daily meter and pressure readings, are provided
as PDFs as "PR 28 Well Logs."
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.
COMPANY RESPONSE: The Company does not have this information in a manner
that is convertible into a spreadsheet format. Each monthly meter reading is included in the
yearly meter books and these books are available for review onsite. The Company did prepare a
similar spreadsheet for the test year, 2022, and it is attached as "Metered Data for 2022."
Pictures of the last page for each month in 2022 have been informally provided to Commission
Staff. If necessary, these photos can be provided formally upon request if deemed necessary.
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.
COMPANY RESPONSE: The majority of the Company's customers are flat-rate
customers. As such, the Company is not able to provide an estimate of unaccounted water
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 4 MAY 6, 2024
TO COMMISSION STAFF

losses. The Company is diligent in monitoring its system for leaks, promptly repairing any leaks
it finds or becomes aware of through notification by its customers.
REQUEST NO. 31: Please provide a copy of the Company's latest Idaho Department of
Environmental Quality ("IDEQ") Sanitary Survey.
COMPANY RESPONSE: Attached, please find the Company's latest Idaho
Department of Environmental Quality Sanitary Survey labeled, "PR 31 Latest Sanitary
Survey.pd£"
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.
COMPANY RESPONSE: The monthly pressure data is recorded daily at each well and
is included in the Well Logs provided in response to Production Request No. 28.
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.
COMPANY RESPONSE: The Company upholds its fiduciary duty to its customers by
managing its construction projects with careful consideration of cost-effectiveness and quality.
While there is not a standardized methodology or a formal policy manual governing the
construction process, Capitol Water Corporation prioritizes efficiency while ensuring the safety
and satisfaction of its customers.
Capital Water Corporation relies on established relationships with trusted contractors and
leverages its accumulated expertise to oversee every stage of project development, execution,
and completion. The Company exercises judgment honed by experience to make informed
decisions throughout the project lifecycle.
Recognizing its paramount obligation to its customers—the rate payers—the Company
diligently allocates funds for capital projects. It remains steadfast in its commitment to providing
safe potable water at reasonable rates. Consequently, all projects are undertaken with a focus on
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 5 MAY 6, 2024
TO COMMISSION STAFF

minimizing costs while upholding safety standards for both customers and employees. The
President of Capitol Water Corporation is deeply cognizant of his role in serving the customers,
understanding that their needs and interests guide every decision made by the Company.
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;
iii. 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).
COMPANY RESPONSE:
1. Analysis of Need: The decrease in well efficiency necessitated the need for cleaning
and rehabbing the pump and well. Order No. 34783, Case No. CAP-W-20-01, states,
"The pumping efficiency of Capitol Water's wells has a direct impact on the
Company's customers. Consequently, we urge the Company to continually monitor
and maintain its system so that it is operating in a safe, efficient, and cost-effective
manner." (Order on page 4. See also Order No. 35224, Case No. CAP-W-21-01; and
Order No. 35582, Case No. CAP-W-22-01.) Order No. 35999, Case No. CAP-W-23-
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 6 MAY 6, 2024
TO COMMISSION STAFF

01 states, "The efficiency of the Company's wells is a crucial concern given that
increased electricity costs due to well inefficiency are passed directly to the
Company's customers. We are satisfied with the Company's proactive actions in
servicing Well. No 5 — as well as the steps taken thus far to schedule a servicing or
cleaning of Well No. 7." (Order on page 4). The Company did not conduct a
cost/benefit analysis comparing alternatives.
2. Least Cost: The Company receives a bid from its preferred contractor. There are
limited contractors able to do the work required by the Company. Therefore, the
Company retains the same contractor to do the cleaning since the contractor is
familiar with the Company's wells, and the Company is satisfied with the work
performed by the contractor. The least cost is not always the lowest cost. If the
Company did not proactively clean and maintain its wells, the pump efficiency would
continue to decline, and power costs would increase. This approach would be the
lowest cost approach in the short run, that is, until the pump begins to fail.
3. Project Plan: The Company does not have a formal project plan, rather it confers
with its preferred contractor and schedules the work to be done at a time that is least
likely to impact customers, in conjunction with the schedule of the contractor. The
preferrable time for this work is in the spring, when customer usage is low and thus
the well can be taken off-line without compromising the safety, reliability, and
functionality of the system, or in the fall, after the sprinkling season has ended, and
customer usage is again low.
4. Requests for proposals: The Company does not conduct a formal request for
proposals or quotes. Rather, it collaborates with its preferred contractor for an
estimate of the needed work.
5. Project construction documentation: The Company receives documentation from the
Contractor as to the work performed once the work has been completed. The detailed
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 7 MAY 6, 2024
TO COMMISSION STAFF

invoice for cleaning and rehabbing Well No. 5 is attached as "PR 34 Well No. 5
Cleaning Rehab Documentation."
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).
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 8 MAY 6, 2024
TO COMMISSION STAFF

COMPANY RESPONSE:
1. Cleaning and rehabilitation of Well No. 7 ($91,593). Please see the response to
Production Request 34 for the analysis of need, least cost evaluation, and project plan.
Currently the Company anticipates that it will have the necessary funds to complete
the work on Well No. 7 in the fall. Attached as "PR 35 Well 7 Rehab.pdf' is the
quote from the Company's preferred contractor.
2. Safety fencing at Well No. 4 and at Well No. 7 for water source protection ($37,510).
The need for the fences at Wells No. 4 and 7 is a requirement by the DEQ. The
Company is planning to have the fencing done this coming summer, and the
Company is working with the contractor to schedule the work. Quotes for the fencing
are attached as "PR 35 Fencing."
3. New customer billing software system($45,000). The Company needs a new billing
software system because its current billing system is antiquated, inefficient, and
expensive to maintain; the dot matrix printer is nearing the end of its life; and the
green-bar paper used by the printer is scarce and expensive when available. Because
of the limitations of the system, the Company does not have the ability to provide
Commission Staff with the information in the format requested. The Company has
adopted, beginning in 2024, QuickBooks for its general ledger, and is in the process
of obtaining quotes for a new customer billing system that will interface with
QuickBooks. At this time, the Company has had three demonstrations of billing
systems, but has not received any formal quotes. These will be made available once
they have been received.
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.
COMPANY RESPONSE: The Company does not expect customer growth, given the
boundaries of its service area. Recently it has experienced growth, however the majority of any
properties available for infill have been developed.
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 9 MAY 6, 2024
TO COMMISSION STAFF

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
Year Revenue) and 10 (Revenue Requirement). This should include the billing determinates
categorized by schedule and service size.
COMPANY RESPONSE: The exhibits provided with the Application provide this
information. The Company is not asking to change the rates by schedule and service size; the
Company is requesting a service charge.
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.
COMPANY RESPONSE: The Company had no insurance claims in 2022.
REQUEST NO. 39: Please provide supporting documentation for the debenture bonds
listed in the "Costs of Capital" workpaper.
COMPANY RESPONSE: The requested information is available onsite.
REQUEST NO. 40: Please provide supporting documentation for the note listed in the
"Cost of Capital" workpaper.
COMPANY RESPONSE: Please see the attached documentation, "PR 40 Note Payable
R Price."
REQUEST NO. 41: Please provide supporting documentation for the vehicle tax
recorded on the balance sheet to account 408.13 in 2022.
COMPANY RESPONSE: The Company's Annual Report for 2022 lists Vehicles as the
line item recorded to Account 408.13 is. The amounts recorded are actually payments to the
Nampa& Meridian Irrigation District. Please see the attached documentation, "Account
408.13.zip."
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 10 MAY 6, 2024
TO COMMISSION STAFF

REQUEST NO. 42: Please provide supporting documentation for the interest and
dividend income recorded on the balance sheet to account 419 in 2022.
COMPANY RESPONSE: Due to the confidential information in the bank statements,
the Company will make these available for review onsite.
DATED at Boise, Idaho, this 6th day of May 2024.
A/,
H. Robert Price
President, Capitol Water Corporation
SECOND PRODUCTION REQUEST RESPONSE
OF CAPITOL WATER CORPORATION 11 MAY 6, 2024
TO COMMISSION STAFF