20240917Staff 64-67 to CAP.pdf

RECEIVED
Tuesday, September 17, 2024 10.45:54 AM
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 ) SEVENTH 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, OCTOBER 1, 2024. 1
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
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0318.
SEVENTH PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 1 SEPTEMBER 17, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
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. 64: Please provide calculations in Excel format for billing errors from
January 1, 2022, through July 31, 2024.
Request No 65: Please state how the Company is planning to address errors identified in
billing from January 1, 2022, through July 31, 2024. Please include calculations and schedules
for how balances will be issued to customers.
Request No 66: Please state whether overbilled customers and underbilled customers
will be retroactively billed.
Request No 67: Please provide a sample of retroactive billing explanations, which the
Company intends to send to customers. Please include an example for overbilled customers, as
well as underbilled customers, if applicable.
DATED at Boise, Idaho, this 17th day of September 2024.
Adam Triplett
Deputy Attorney General
L•\Utility\UMISC\PRDREQ\CAP-W-24-01 PR#7.docx
SEVENTH PRODUCTION REQUEST
TO CAPITOL WATER CORPORATION 2 SEPTEMBER 17, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17+-��DAY OF SEPTEMBER 2024,
SERVED THE FOREGOING SEVENTH 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(kgrnail.com
BOISE ID 83704
E-MAIL: info(a,capitolwatercorp.com
MARY GRANT
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
PO BOX 500
BOISE ID 83701-0500
E-MAIL: mgrantgcityofboise.org
BoiseCityAttorney( ,cityofboise.org
PATRICIA JORDAN SECRETARY
CERTIFICATE OF SERVICE