20210921Staff 1-2 to Capitol Water.pdf

JOHN R. HAMMOND (rSB #5470)
RrLEY NEWTON (rSB #11202)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLTC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7 1334-0318
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Street Address for Express Mail:
472 W. WASHTNGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES 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-21.01
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,
ocToBER 6, 2021.r
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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Stafls attorney
at (208) 334-03s7.
FIRST PRODUCTION REQUEST
TO CAPITOL WATER
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1 SEPTEMBER 2I , 2O2I
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.
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 the monthly water consumption for each well that the
Company has operated over the past three years (from September 1,2018, through September l,
2021).
REQUEST NO. 2: Please describe the efforts that the Company has made to improve the
well effrciency since CAP-W-20-01. Specifically, please provide the following information in the
response:
a. Identiff wells worked on to improve efficiency?
b. What specific efforts have been made?
c. When did the Company make the efforts?
d. Staff expressed its concerns regarding Well No. 5 and Well No. 6 in its Comments in
CAP-W-20-01. Has the Company addressed Staff s concems? If so, please describe
how the Company addressed Staff s concerns.
^*Dated at Boise, Idaho, tltrsa/ day of September 2021.
J Hammond
Attomey General
i:umisc/prod req/capw2l.ljh prod req I
FIRST PRODUCTION REQUEST
TO CAPITOL WATER
2 SEPTEMBERZI,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF SEPTEMBER 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OT TITE
COMMISSION STAFF TO CAPITOL WATER CORPORATION, IN CASE NO.
CAP-W.2I.01, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
ROBERT PRICE
PRESIDENT
CAPITOL WATER CORP
2626ELDORADO
BOISE ID 83704
E-MAIL : [e-mail]
CERTIFICATE OF SERVICE