960924.docx

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE,  IDAHO  83720-0074
[phone]
ATTORNEY FOR THE COMMISSION STAFF
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION
IN THE MATTER OF THE APPLICATION)
OF CAPITOL WATER CORPORATION ) CASE  NO.  CAP-W-96-2
FOR A TEMPORARY RATE INCREASE TO)
IMPLEMENT WATER QUALITY )    
IMPROVEMENTS. )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, Scott Woodbury, Deputy Attorney General, requests Capitol Water Corporation provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before OCTOBER 11, 1996.
This production request is to be considered as continuing, and Capitol Water Corporation (Capitol; Company) is requested to provide by way of supplementary responses, additional documents that you or any person acting on your 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; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder.
Request No. 1: Please identify the consultant(s) retained by the Company.  Please provide copies of all supporting documentation and/or correspondence regarding consultant recommendations.
Request No. 2:  Please provide a copy of DEQ documentation and/or correspondence wherein DEQ concludes “that the current levels of iron and manganese in Capitol Water's water supply does not constitute a health risk and does not constitute a basis for additional water treatment or the use of a different source of supply.”  reference Application paragraph 3
Request No. 3:  Please provide copy of DEQ documentation and/or correspondence wherein DEQ advises Capitol Water “that DEQ does not consider these secondary contaminants of iron and manganese to be a health hazard.”  Does the Company have any supporting documentation or study reports regarding the health effects of iron and manganese?  If so, please provide copies of same.  What are the cumulative effects of drinking water with the levels of iron and manganese present in the Company's source waters?  Has the Company inquired?  
Request No. 4:  What are the health effects, if any, of the sequestering chemicals (phosphate) recommended by your consultant?  Has the Company inquired?
Request No. 5:  Capitol Water's consultant “recommends that eventually phosphate be injected into five of the Company's six wells.”  When will this occur?  Will there be additional costs for sequestering chemicals, metering and injection equipment?  If so, please provide estimated costs?
Request No. 6:  Does the Company propose to recover any phosphate chemical costs incurred prior to the date of its Application?  If so, please provide actual expense amounts and supporting documentation?
Request No. 7:  Please provide supporting documentation for estimated costs of rebuilding Well No. 2 ($70,000) and drilling a new well at site of current Well No. 6 ($170,000).
Request No. 8:  What is the Company's present amount of retained earnings, if any?
Request No. 9:  Re:  metering cost ($6,000).  Please break out estimated cost of metering by well.
Request No. 10:  Please provide supporting workpapers for rate increase calculations.      
DATED  at Boise, Idaho, this              day of September 1996.
______________________________________
Scott Woodbury
Deputy Attorney General
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