20190703Staff 1-4 to Capitol Water.pdf

JOHN R. HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
RECEIVED
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i-iTir.:ir COMMISSION
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIBS COMMISSION
IN THE MATTER OF THE APPLICATION OF
CAPITOL WATER CORPORATION TO
CHANGE ITS SCHEDULE NO.3 PURCHASED
POWER ADJUSTMENT RATE
CASE NO. CAP-W.19-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
CAPITOL WATER
CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond, Deputy Attorney General, requests that Capitol Water Corporation (Company)
provide the following documents and information as soon as possible, or by WEDNESDAY,
JULY 17,2019.1
This Production Request is continuing, and Capitol Water Corporation 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Capitol Water Corporation is reminded that
responses pursuant to Commission Rules of Procedure must include the name and phone number
t Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s attorney
at (208) 334-03s7.
FIRST PRODUCTION REQUEST
TO CAPITOL WATER
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1 JULY 3,2019
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 3r.01.0r.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 monthly water production for each well that the
Company operated during Calendar Year 2018.
REQUEST NO.2: Please provide monthly water consumption for each aquifer recharge
well that the Company operated during Calendar Year 2018.
REQUEST NO. 3: Please provide copies, or make available onsite, the power bills for
the months of January through December 2018.
REQUEST NO. 4: In Order No. 33876, Case No. CAP-W-17-01, the Commission, in the
discussion and findings section stated, "Going forward, the Company shall provide calendar year
information on total average number of customers, total volume of water pumped in gallons (gal),
and total electric energy used in kilowatt-hours (kWh) with its PPCA filing." The total electric
energy used in KilowatGhours is provided in the PPCA filing in the "2019 Idaho Power
Spreadsheet." Please provide the average number of customers and total volume of water pumped.
-")Dated at Boise, Idaho, this ) day of July 2019
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Deputy Attorney General
i:umisc/prod req/capwl 9. ljhrk
FIRST PRODUCTION REQUEST
TO CAPITOL WATER
2 JULY 3,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF JULY 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO CAPITOL WATER CORPORATION, N CASE NO
CAP-W-Ig-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
ROBERT PRICE
PRESIDENT
CAPITOL WATER CORP
2626 ELDORADO
BOISE ID 83704
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE