20110331Staff 1-30 to BRN.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF BRIAN WATER CORPORATION FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES.
)
) CASE NO. BRN-W-ll-01
)
)
) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO BRIAN WATER
) CORPORATION
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Brian Water Corporation (Brian Water;
Company) provide the following documents and information on or before THURSDAY, APRIL
21,2011.
This Production Request is to be considered as continuing, and Brian Water is requested to
provide, by way of supplementar responses, additional documents that it or any person acting on
its behalf may later obtain that wil augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
FIRST PRODUCTION REQUEST
TO BRIAN WATER 1 MARCH 31, 2011
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.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO.1: Please provide a copy of a map showing the general layout of Brian
Water's system including wells and pumps, main/distribution systems and general area/lots served
by the Company.
REQUEST NO.2: The Company indicated in its 2010 Annual Report that it provides
water service to 46 residential customers. Please confirm if this total number of customers is stil
46 to date.
REQUEST NO.3: During the Company's last rate case (BRN-W-07-01), Staff
recommended the installation of a master meter on the Company's primar and backup wells and a
program of testing and replacement of individual meters. The Commission also stated "water is a
resource that must be conserved and not wasted. We encourage the Company to take steps to better
manage and husband this resource." (Order No. 30516). Please confirm if flow meters have been
installed and the date they were installed. If not, please explain why they were not installed.
REQUEST NO.4: Please provide a copy of the well driler's report for Well NO.1 (older
well).
REQUEST NO.5: The Commission also directed the Company to initiate a program of
testing and replacement of individual customer meters. (Order No. 30516). Please confirm if such
program was initiated by the Company and explain the status of the program. If not, please explain
why they were not initiated.
FIRST PRODUCTION REQUEST
TO BRIAN WATER 2 MARCH 31, 2011
REQUEST NO.6: Staff understands that the Idaho Department of Environmental Quality
conducted a Sanitary Survey of the Company's water system in 2008 and that several significant
deficiencies were discovered. Please explain the status of these system deficiencies and whether the
Company's response to these deficiencies have been accepted and/or approved by IDEQ.
REQUEST NO.7: Please provide the name of the licensed operator for Brian Water.
Please provide proof that the operator's license is curent.
REQUEST NO.8: If the flow meters at the wellheads as noted in Request NO.3 were
installed, please provide the total monthly volumes of water pumped from each well since those
meters were installed.
REQUEST NO.9: If no flow meters were installed, please provide the approximate
percentage of the total volume of water pumped from each well during the test period (2010).
REQUEST NO. 10: Please provide average monthly water consumption data for all
customers served and the appropriate total for six calendar years including 2005, 2006, 2007, 2008,
2009 and 2010.
REQUEST NO. 11: Please provide monthly biling information for each customer
showing the volume of water sold and the amount biled for three calendar years including 2008,
2009 and 2010.
REQUEST NO. 12: The Company did not propose any changes in rate design. Please
explain the Company's rationale for maintaining 4,000 gallons as the minimum charge volume
allowance.
REQUEST NO. 13: The Company proposes to raise its minimum customer charge from
$12.50 to $18.00 but did not propose any adjustment in commodity charge. Please explain the
Company's rationale why no adjustment was proposed for the commodity charge.
FIRST PRODUCTION REQUEST
TO BRIAN WATER 3 MARCH 31, 2011
REQUEST NO. 14: During the Company's last rate case (BRN-W-07-01), the
Commission directed the Company to read meters and bil customers on a monthly schedule. Order
No. 30516. Please confirm that this directive was implemented. If not, please explain.
REQUEST NO. 15: For the purpose of estimating future revenues, please provide the total
monthly excess usage per customer for calendar years 2008, 2009 and 2010.
REQUEST NO. 16: Please provide a copy of all water quality tests for all water sources
(wells) and within the distribution system that violated water quality standards promulgated by the
Idaho Deparment of Environmental Quality and EPA during the calendar year 2008, 2009 and
2010.
REQUEST NO. 17: Please provide a copy of any letters/notices received from IDEQ
directing the Company to meet water quality standards due to water quality violations within the
Company's drinking water system and your response(s) to IDEQ's directives.
REQUEST NO. 18: The Company indicated in the Application that IDEQ has directed
Brian Water to develop a longer range solution to keep the nitrate levels of water sold to customers
below the EPA's maximum contaminant level (MCL) of 10 mg/L. The Company asserts that a new
deeper well seems to be the best option. Please respond to the following questions:
a. Please provide a copy of engineering study describing this alternative.
b. Please provide the location and specification of the proposed well.
c. Please provide a copy of the groundwater/geological study that offers
conclusions/recommendations that driling a new well at targeted depth provides a
reasonable degree of success in encountering water supplies relatively free from nitrate
contamination.
d. Please provide detailed cost estimates or bids for driling the well and well
development/testing.
FIRST PRODUCTION REQUEST
TO BRIAN WATER 4 MARCH 31, 2011
e. Please provide detailed cost estimates or bids for the installation of pump and motor,
electrical/controls, mainline tie-in, other appurtenances, building facilty and
engineering.
REQUEST NO. 19: Did the Company analyze other alternatives to solve the high nitrate
levels in its water supply? If yes, please describe the various options analyzed, the total potential
costs for each option, and the reason(s) why any of these alternatives analyzed were not selected.
REQUEST NO. 20: If the response to Request No. 19 is no, please provide justification or
explanation why the Company considered drillng a new well as the best option.
REQUEST NO. 21: Please explain how you plan to finance the engineering study (if such
study has not been done), driling and developing a new well, and installng the pump and motor
and other appurtenances to make this option fully operationaL. Have you explored various financing
options (IDEQ Drinking Water Revolving Fund, IDWR Financing Program, NRW A/SDA, private
bans)? Please explain.' Have you explored possible grants for conducting an engineering study?
Please explain.
REQUEST NO. 22: Please provide a copy of the consent order issued by IDEQ.
REQUEST NO. 23: Please describe the Company's policy for collection of deposits.
Rule 101 and Rule 102 of the Utilty Customer Relations Rules (UCRR).
REQUEST NO. 24: Please provide a sample copy of a bil sent to a customer with no past
due balance and a sample copy of a bil sent to a customer with a past due balance. (UCRR Rules
201, 202, 204, 206, 207)
REQUEST NO. 25: Please provide a sample copy of the following Company documents:
Initial Notice to Terminate, Final Notice of Intent to Terminate Service (if mailed), and the written
information provided to customers following termination of service (door tag or notice if used), for
FIRST PRODUCTION REQUEST
TO BRIAN WATER 5 MARCH 31, 2011
each rate schedule or class of customers if the documents vary by schedule or class. Please provide
an explanation of how the Company conducts its termination process. (UCRR Rules 304, 305, 310,
311)
REQUEST NO. 26: Does the Company offer customers a pre-printed form for the
medical emergency certificate? If so, please provide a copy of the form. (UCRR Rule 308)
REQUEST NO. 27: Does the Company keep a written record of customer complaints?
Please provide copies of these records for the years 2009 through 2011 to date. (UCRR Rule 401)
REQUEST NO. 28: Please provide the number of customer complaints (oral and written)
received by the Company for calendar years 2009 through 2011 to date, broken into categories, e.g.,
disconnection, water quality, outages, etc. (UCRR Rule 403)
REQUEST NO. 29: Please provide a sample copy of the Company's Rules Summar
distributed to customers. How and when are customers given the summar? (UCRR Rule 701)
REQUEST NO. 30: Please provide a sample copy of the Explanation of Rate Schedule
distributed to customers. How and when are customers given the summar? (UCRR Rule 702)
Dated at Boise, Idaho, this ~13!day of March, 2011.
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Kr ine A. Sasser
Deputy Attorney General
Technical Staff: Gerry Galinato/I-22
Chris Hecht/23-30
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FIRST PRODUCTION REQUEST
TO BRIAN WATER 6 MARCH 31, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31sT DAY OF MARCH 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO BRIAN WATER CORPORATION, IN CASE NO.
BRN-W-II-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TONY BOWAR
BRIAN WATER CORP
STE C #228
5120 OVERLAND RD
BOISE ID 83705
, tVa~
SECRETAR
CERTIFICATE OF SERVICE