20230921Staff 1-5 to CAP.pdf

MICHAEL DUY AL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF CAPITOL WATER CORP. TO CHANGE )
ITS SCHEDULE NO. 3 PURCHASED POWER )
COST ADJUSTMENT RA TE )
)
)
)
) ___________________ )
CASE NO. CAP-W-23-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO CAPITAL WATER
CORPORATION
Staff of the Idaho Public Utilities Commission, by and through its attorney ofrecord,
Michael Duval, Deputy Attorney General, requests that Capital Water Corporation ("Company")
provide the following documents and information as soon as possible, but no later than
THURSDAY OCTOBER 5, 2023.1
This Production Request is to be considered as continuing, and the Company 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 or information produced.
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
1 Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at [phone].
FIRST PRODUCTION REQUEST
TO CAPITAL WATER CORPORATION 1 SEPTEMBER 21 , 2023
RECEIVED
2023 September 21 2:36 PM
IDAHO PUBLIC
UTILITIES COMMISSION
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide copies of all the monthly invoices for power
expenses for each well in 2022 and reconcile the amount to the Company's request in its
Application.
REQUEST NO. 2: Please provide Exhibit No. 1 in Excel format with all formulas
intact. Please also provide any backup information showing how the Company calculated the
Actual Power Costs from 2022 and its Power Costs Embedded in Base Revenue, as shown in
Exhibit No. 1.
REQUEST NO. 3: Please provide the following information for calendar year 2022 (or
alternatively make available onsite):
a. Monthly power bills indicating the amount of electricity (kWh) used by each well
and booster pump. In the power bills/statements, clearly identify the well number
to the respective electricity usage;
b. Monthly metered amount of water production (gallons) from each well, including
the Aquifer Storage Recovery ("ASR"). Please provide the data in Excel
spreadsheet format with formulas intact;
c. Monthly meter readings from each well (including the ASR). Please provide the
data in Excel spreadsheet format with formulas incorporated;
d. Monthly metered total customer demands/water usage data (gallons). Please
provide the data in Excel spreadsheet format with formulas incorporated; and
e. An estimate of total unaccounted water losses (gallons) due to leaks, wasted
water, etc. Please provide the data in Excel spreadsheet format with formulas
incorporated.
REQUEST NO. 4: Please provide details on any repairs or maintenance the Company
performed in calendar year 2022 to improve system-level water pumping efficiency of individual
FIRST PRODUCTION REQUEST
TO CAPITAL WATER CORPORATION 2 SEPTEMBER 21, 2023
wells as identified in Idaho Public Utilities Commission's Order No. 35582 (Case: CAP-W-22-
01).
REQUEST NO. 5: Please provide details on any investments the Company made
(purchasing and installing new equipment or components including but not limited to pumps,
motors, etc.) in calendar year 2022 to improve system-level water pumping efficiency of
individual wells as identified in Idaho Public Utilities Commission's Order No. 35582 (Case:
CAP-W-22-01).
Isl
DATED at Boise, Idaho, this 2 day of September 2023.
~l-C
Michael Duval
Deputy Attorney General
i:umisc:prodreq/CAP-W-23-01 PR# I
FIRST PRODUCTION REQUEST
TO CAP IT AL WATER CORPORATION 3 SEPTEMBER 21, 2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2l5t DAY OF SEPTEMBER 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO CAPITAL WATER CORPORATION, IN CASE NO.
CAP-W-23-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
ROBERT PRICE
PRESIDENT
CAPITOL WATER CORP
2626 ELDORADO
BOISE ID 83704
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE