20090828Staff 1-27 to BCS.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
RECE.IVED
2009 AUG 28 PM 2: 53
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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, )
INC. FOR AN ORDER AUTHORIZING AN )
INCREASE IN THE COMPANY'S RATES )
AND CHARGES FOR THE WATER SERVICE )
IN THE STATE OF IDAHO. )
)
)
CASE NO. BCS-W-09-2
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 Woodbur, Deputy Attorney General, requests that Bar Circle "8" Water Company
(Company; Bar Circle "S") provide the following documents and information on or before
FRIDAY, SEPTEMBER 25, 2009.
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 IDAP A 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 AUGUST 28, 2009
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: The Company indicated in the Application that Avondale
Constrction, an affiliated company, provides a flat monthly fee to operate, maintain and manage
the water system. Please provide any written contract documenting the relationship between the
Company and Avondale Construction Company. Also, please provide the names of the certified
primar and back-up water operators from Avondale Construction.
REQUEST NO.2: The Company indicated in the Application that it has contacted three
independent companies that provide water master management and maintenance services in the
region to compare the cost of similar services. Please provide a list of these companies and
contact information.
REQUEST NO.3: The Company indicated in the Application that it has contacted an
independent billng company that provides biling and maintenance of customer records to
compare cost of similar services. Please provide the name of this company and contact
information.
REQUEST NO.4: Please provide the Company's rationale for proposing an across the
board rate increase of 119.45% to all rates and charges contained in the Company's curent rate
schedules.
REQUEST NO.5: Please provide a list of all water quality tests for all water sources
(wells) and within the distribution system as required by the Idaho Department of Environmental
Quality. For each type of test, indicate the frequency, total costs per test and the prorated yearly
FIRST PRODUCTION REQUEST
TO BAR CIRCLE "S" WATER 2 AUGUST 28, 2009
(normalized) costs. For example, Well No.1, arsenic test, every 3 years, $20 per test, $6.67 per
year; Well No.1, nitrate test, yearly, $20 per test, $20 per year, and so on.
REQUEST NO.6: Please provide monthly data and appropriate yearly total of water
production and consumption for Calendar Years 2006, 2007 and 2008.
REQUEST NO.7: The Company is proposing to model the non-recurring tarff of
"connection fee" or "hook-up fee" for new customers connecting to the system for the first time
after the Commission-approved tariff for the Diamond Bar Estates Water Company. Diamond
Bar Estates' new customer connection charges are broken down into two types: a) first time
connection charges when an existing service line and meter base are already in place on the
property; and b) when there is no service line tap to the Company's water mains or meter box in
place on the property. Please identify how many connections for each type (Items a and b above)
are expected for full build-out (excluding the proposed Double T Ranch). .
REQUEST NO.8: Please provide a detailed description (IDEQ-approved construction
drawing) of the typical installation for a new hook-up for Items a and b as described in Request
NO.7.
REQUEST NO.9: The Company is proposing to charge a $480 "connection fee" or
"hook-up fee" for new customers when an existing service line and meter base are already in
place. Application, pg. 3. Please provide a detailed cost estimate (i.e. meter cost, installation
cost, etc.) included in a typical installation as described if1 Request No.8, Item a.
REQUEST NO. 10: The Company is also proposing to charge a $2,500 "connection
fee" or "hook-up fee" for new customers when there is no service tap to the Company's water
mains or meter box in place on the property. Application, pg. 3. Please provide a detailed cost
estimate (i.e. service lines, meter boxes, meters, installation cost, etc.) included in the tyical
installation as described in Request No.8, Item b.
FIRST PRODUCTION REQUEST
TO BAR CIRCLE "S" WATER 3 AUGUST 28, 2009
REQUEST NO. 11: Please provide the date when the following projects were
completed and put into service, or tageted completion date: a) pump replacement; b) installation
of6-inch recording flow meter at the discharge line of the four booster pumps; c) abandonment
of unused 6-inch well; d) conversion to electronic meter reading; and e) replacement of the 60-hp
pump destroyed by lightning (large pump at Well No.2). Related to Request No. 11, please
identify also the size and designation of this pump.
REQUEST NO. 12: Regarding Request No. 11(e), the Company indicated that the
pump motor was destroyed by lightning. Please explain if the Company plans to instal lightning
protection devices to protect the Company's pump/motors and other equipment from lightning
strikes in the future.
REQUEST NO. 13: The Company's Application indicates that it would cost $10,000 to
replace the 60-hp motor destroyed by lightning. Application, Exhibit 1. Please provide a copy
of vendor's bid for this project or actual invoice(s) if this project is already completed.
REQUEST NO. 14: Staff understands that IDEQ has to review engineering plans before
any significant change is done on the water system. Please provide any approval letter or other
proof that the proposed changes in the Company's water distribution system have been
reviewed/approved by IDEQ. This includes a) installation of a new recording flow meter at the
discharge line of the booster pumps, and b) replacement of manual read meters to electronic read
meters.
REQUEST NO. 15: Please provide the following information concerning the back-up
power generation unit for the booster pumps and fire pump: a) copy of any documents and
communication from IDEQ indicating approval of construction plans and operation of the
standby power generation unit, if such installation is required by ID EQ rules; b) if installation is
not required by IDEQ, please explain justification for installng the back-up generator; c) list of
all pumping loads (hp) being served by the stadby power generation unit; d) size of the standby
FIRST PRODUCTION REQUEST
TO BAR CIRCLE "S" WATER 4 AUGUST 28, 2009
power generation unit (kW); e) approximate date when the generation unit was put to service;
and t) total costs of installation (materials, labor, equipment rental, engineering, etc.).
REQUEST NO. 16: Please provide the following information concerning the water line
improvements completed in 2002 at a tota cost of $111,531 (Depreciation Schedule Table,
Worksheet): a) a description of this project and an explanation as to why it was built; b) as-built
project plans; c) a copy of any documents and communication from IDEQ indicating approval of
construction plans and operation of the project; and d) cost breakdown into various categories,
including, materials, equipment rental, labor, engineering, etc. for the development of the
project.
REQUEST NO. 17: Please provide an explanation of the specific well site
improvements made in 2003 ($9,777),2004 ($12,948), 2005 ($14,179), and 2006 ($1,000) and
justification for such improvements. Please provide copies of as-built plans and IDEQ approval
letters for these improvements. Please provide a breakdown of costs for these improvements into
various categories, including, materials, equipment rental, labor, engineering, etc.
REQUEST NO. 18: Staff notes that Avondale Construction, an affiliated company, has
provided construction/labor services for various past and proposed projects. Please provide an
explanation and documentation showing that cost control efforts have been applied to be sure
such projects were built as economically as possible.
REQUEST NO. 19: The Company's Application indicates that another utilty, the
Diamond Bar Estates Water Company, utilzes the same suppliers of materials, equipment and
labor as Bar Circle "S" Water Company. Please provide a list of these suppliers and the type of
materials and services they provide.
REQUEST NO. 20: The Application indicates that the Company curently provides
water service to approximately 160 residential and commercial customers. Please specify the
number of customers being served by the Company in each service class.
FIRST PRODUCTION REQUEST
TO BAR CIRCLE "S" WATER 5 AUGUST 28, 2009
REQUEST NO. 21: Please provide a copy of a customer biling to verify compliance
with the Utilty Customer Relations Rules (UCRR) - Rule 201 and Rule 202.
REQUEST NO. 22: Please provide a copy of initial notice of intent to terminate, final
notice of intent to terminate and door hanger to verify compliance with the UCRR - Rule 304
and Rule 305.
REQUEST NO. 23: Please provide an explanation of how the Company conducts its
termination process - Rule 304, Rule 305, Rule 310 and Rule 311.
REQUEST NO. 24: Please provide a copy of the Medical Certificate provided to
customers, if used by the Company - UCRR Rule 309.
REQUEST NO. 25: Please provide a copy of the Company's customer complaint file
for the past three years to verify compliance with the UCRR - Rule 401 and Rule 403.
REQUEST NO. 26: Please provide a copy of the Annual Rules Sumary and date of
last mailng to customers to verify compliance with the UCRR - Rule 701.
REQUEST NO. 27: Please provide a record of Bar Circle "S" customers disconnected
over the past three years, including account detail; disconnect date, reconnect date, past due
amount that created disconnect, etc.
DATED at Boise, Idaho, this eìlday of July 2009.
.~co ~ ury
Deputy Attorney General
Technical Staff: Joe Leckie/l-4
Gerry Galinato/5-20
Chris Hecht/21-27
i: umisc:prodreqlbcsw08. i swgg prod req 1
FIRST PRODUCTION REQUEST
TO BAR CIRCLE "S" WATER 6 AUGUST 28, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF AUGUST 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO BAR CIRCLE "S" WATER COMPANY, IN CASE
NO. BCS-W-08-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
ROBERT N TURNIPSEED
PRESIDENT
BAR CIRCLE "S" WATER CO
PO BOX 1870
HA YDEN ID 83835
E-MAIL: avondalecon(fverizon.net
ROBERT E SMITH
2209 N BRYSON RD
BOISE ID 83713
E-MAIL: utiltygroup(fyahoo.com
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SECRETARY
CERTIFICATE OF SERVICE