20240625Staff 52-59 to CAP.pdf

RECEIVED
Tuesday, June 25, 2024 12:57:11 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 ) FIFTH 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
TUESDAY,JULY 16, 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.
FIFTH PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 1 JUNE 25, 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. 52: In reference to the Idaho Department of Environmental Quality
("IDEQ") Sanitary Survey conducted on April 1, 2024, please provide the Company's Corrective
Action Plan to address the two significant deficiencies identified in the Sanitary Survey.
REQUEST NO. 53: In reference to the IDEQ Sanitary Survey conducted on April 1,
2024,please provide the Company's plan to address the five deficiencies and the seven
recommendations identified in the Sanitary Survey.
REQUEST NO. 54: The workpaper titled"Increases to Plant in Service 2023"provided
as a supplemental response to Staff Production Request No. 5 includes a $34,942.72 cost in 2016
for line item description Various (Account 333 — Services) and a$15,619.24 cost in 2017 under
the same line item description. Please respond to the following:
a. Please explain what items are included in the Various (Account 333 — Services) line
item;
b. Please provide a justification of the need for all items included in Account 333 for
2016 and 2017;
c. Please provide invoices for all items included in Account 333 for 2016 and 2017; and
d. Please explain the reason for the variation in the total dollar amount between 2016
and 2017.
REQUEST NO. 55: The workpaper titled"Increases to Plant in Service 2023"provided
as a supplemental response to Staff Production Request No. 5 includes a $48,429.48 cost with a
line item description of Broadview PI Sub (Account 309— Supply Mains) and a $48,429.48 cost
with a line item description of Broadview PI Sub (Account 330—Dist Reservoir/Standpipe),both
occurring in 2019. Please respond to the following:
a. Please describe in detail what the Broadview PI Sub line item is;
FIFTH PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 2 JUNE 25, 2024

b. Please explain why the Broadview PI Sub line item is included in two different
accounts with the same total dollar amount;
c. Please provide invoices documenting these amounts; and
d. Please provide the amount and entries for any Contributions in Aid of Construction.
REQUEST NO. 56: The workpaper titled"Increases to Plant in Service 2023"provided
as a supplemental response to Staff Production Request No. 5 includes a $2,750.70 cost with a
line item description of Folding Machine (Account 340—Office Furniture &Equipment) and a
$2,930.84 cost with a line item description of Tool (Account 343 —Tools, Shop and Garage
Equipment),both occurring in 2019. Please respond to the following:
a. Please describe in more detail what the Folding Machine and Tool line items are;
b. Please provide justification for the need of the Folding Machine and Tool line items;
c. Please provide all invoices for the Folding Machine and Tool line items; and
d. Please explain if both the Folding Machine and Tool line items are currently working
and currently in use.
REQUEST NO. 57: The workpaper titled"Increases to Plant in Service 2023"provided
as a supplemental response to Staff Production Request No. 5 includes a $75,731.39 Lincoln
Aviator(Account 341 —Transportation Equipment) line item in 2020. Please respond to the
following:
a. Please provide a justification of the need for the Lincoln Aviator;
b. Please identify the model of Lincoln Aviator that was purchased;
c. If the Lincoln Aviator is not the base model, please explain the reasons for purchasing
this model over the base model;
d. Please provide all the alternative vehicles the Company considered when purchasing
the Lincoln Aviator and include any quotes for the alternative vehicles;
e. Please explain the Company's need for a luxury brand vehicle over a standard vehicle
brand; and
f. Please provide all invoices for the Lincoln Aviator that total to $75,731.39.
FIFTH PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 3 JUNE 25, 2024

REQUEST NO. 58: The workpaper titled"Increases to Plant in Service 2023" provided
as a supplemental response to Staff Production Request No. 5 includes four Well #5 Rehab
(Account 307 —Wells) line items in 2020 for the following amounts: $59.41, $14,687.50,
$20,050.09, and $600.00. Please respond to the following:
a. Please describe in more detail what the four Well #5 Rehab line items are;
b. Please provide a justification of the need for the four Well #5 Rehab line items;
c. Please provide all invoices for the four Well #5 Rehab line items;
d. Please explain the reason for why these four Well #5 Rehab line items in 2020 were
required in addition to the Well No. 5 cleaning and rehabilitation work in 2023; and
e. Please document if and how the 2023 expenditures were reduced as a result of the
2020 expenditures.
REQUEST NO. 59: The depreciation schedule provided as a response to Staff
Production Request No. 7 includes a $49,948.73 cost with a line item description of Wells
(Account 307—Wells) dated June 15, 2015. Please response to the following:
a. Please describe in detail what plant additions are included in the Wells line item;
b. Please provide a justification of the need for the plant additions included in the Wells
line item; and
c. Please provide all invoices for the plant additions included in the Wells line items.
DATED at Boise, Idaho, this 251h day of June 2024.
Adam Triplett
Deputy Attorney General
1:\Utility\UMISC\PRDREQACAP-W-24-01 PR#5.docx
FIFTH PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 4 JUNE 25, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS �'6 DAY OF JUNE 2024,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO CAPITOL WATER CORPORATION, IN CASE NO.
CAP-W-24-01, BY &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(cr�,gmail.com
BOISE ID 83704
E-MAIL: infoacapitolwatercorp.com
MARY GRANT .
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
PO BOX 500
BOISE ID 83701-0500
E-MAIL: mgrant(a-,cityofboise.org
BoiseCityAttorneygcityof boise.org
vV
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE