20081204Staff 1-5 to BCS.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
RECE1VED
200ft OEe - 1+ PH 2: 12
IDAHO PUBLIC,. ';
UTILITIES COMMISbIO¡~
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF BAR CIRCLE "S" WATER COMPANY TO )
AMEND ITS CERTIFICATE OF )
CONVENIENCE AND NECESSITY )
)
)
)
)
CASE NO. BCS-W-08-1
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO BAR CIRCLE "S" WATER
COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbury, Deputy Attorney General, requests that Bar Circle "s" Water Company
(Company; Bar Circle "S") provide the following documents and information on or before
MONDAY, DECEMBER 22, 2008.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Bar Circle "s" is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that wil augment the documents produced.
FIRST PRODUCTION REQUEST
TO BAR CIRCLE "s" WATER 1 DECEMBER 4, 2008
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 identify the name, job title, location and telephone
number of the record holder.
For all responses to the following requests, please provide all workpapers, CDs and
all underlying formulas in Excel language.
REQUEST NO.1: Please provide a copy of the signed water line extension agreement
between the Company and Double Tree Estates, the entity requesting water service.
REQUEST NO.2: The Company Application states "The only cost to be borne by
applicant wil be the cost of meters at the time a property is developed and service is requested."
Application at 2. However, the current Company tariff specifies that for non-recurring charges, a
charge of $500 for installation of the water meter and a charge of $250 for water hook-up fee.
Please explain this apparent discrepancy.
REQUEST NO.3: Please provide a map of suitable scale showing the location of the
construction or expansion and its relation to other public utilties, corporations, or persons with
whom the expanded utilty is likely to compete and the location of public utilties in the area that
offer or provide similar service. Reference IDAPA 31.01.01.112.02 and .03.
REQUEST NO.4: Please provide a detailed estimate of the cost to the Company of the
construction or expansion and the effects of the construction or expansion on Bar Circle's
revenue requirement. Reference IDAPA 31.01.01.112.05.
REQUEST NO.5: The application states that "Addition of this service area to the
existing system will have no adverse effect on the Company's existing customers." Application
at 2. The total number of new residential home sites from Double T Estates that could
potentially be added to the system is 47. Assuming that the subdivision is fully built out with a
total of262 (157 active connections + 58 additional approved connections-2008 Engineering
FIRST PRODUCTION REQUEST
TO BAR CIRCLE "s" WATER 2 DECEMBER 4, 2008
Report + 47 future connections at Double TEstate), the Engineering Report indicated that
several system improvements are necessar to comply with the IDEQ Rules: 1) a booster pump
is needed to provide additional pressure, 2) additional well wil be necessar, and 3) a back-up
power to Well NO.1 is necessary. Engineering Report at 6-7. It appears that there wil be some
impacts. Please explain the discrepancies between the Application and the Engineering Report.
DATED at Boise, Idaho, this ti11. day of December 2008.
Scott Woodbur
Deputy Attorney General
Technical Staff: Gerry Galinato
i:umisc:prodreqlbcsw08.1swgg prod req 1
FIRST PRODUCTION REQUEST
TO BAR CIRCLE "s" WATER 3 DECEMBER 4, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF DECEMBER 2008,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO BAR CIRCLE "S" WATER COMPANY, IN CASE
NO. BCS-W-08-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
ROBERT N TURNIPSEED
PRESIDENT
BAR CIRCLE "s" WATER CO
PO BOX 1870
HAYDEN ID 83835
E-MAIL: avondalecon(iverizon.net
ROBERT E SMITH
2209 N BRYSON RD
BOISE ID 83713
E-MAIL: utiltygroup(iyahoo.com
,b~SECRETARY ~-=
CERTIFICATE OF SERVICE