20120625Staff 21-49 to CCH.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
RECEtVED
1017 JUN 25 pj
OAHO UBL
1'TI
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION)
OF COUNTRY CLUB HILLS UTILITIES )
FOR AUTHORITY TO INCREASE ITS )
RATES AND CHARGES FOR WATER )
SERVICE )
)
)
)
)
CASE NO. CCH-W-12-01
SECOND PRODUCTION
REQUEST OF THE COMMISSION
STAFF TO COUNTRY CLUB
HILLS UTILITIES
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Country Club Hills Utilities (Company;
Country Club Hills) provide the following documents and information as soon as possible, but
no later than MONDAY, JULY 16, 2012.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number 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.
This Production Request is to be considered as continuing, and Country Club Hills 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.
SECOND PRODUCTION REQUEST
TO COUNTRY CLUB HILLS 1 JUNE 25, 2012
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
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 21: The 2011 Annual Report of Country Club Hills Utilities Inc.
reports insurance expense of $315. Please provide copies of all premium notices for your
liability insurance for 2011 and 2012 to date. Also, please provide copies of premium notices for
any other insurance reported as a utility expense in 2011.
REQUEST NO. 22: The list of Aged Accounts Receivables for the Calendar Year
ended 2011, shows an uncollected balance of $812 for Holiday Hills Condominiums. This
account also shows uncollected amounts of $302 for 2007, $302 for 2008, $302 for 2009 and
$604 for 2010. Please list the uncollected amounts for each year which are only for drinking
water. Please explain the collection problems at these condominiums. Also, please describe the
deposit, billing and collection policies and arrangements for these condominiums.
REQUEST NO. 23: Please provide an estimate of the average number of weekly hours
worked by Mr. Groth in the drinking water operations at Country Club Hills Utilities during
2011.
REQUEST NO. 24: Please provide a schedule showing detailed amounts and totals by
year for annual repair expenses on abandoned service lines during 2009 to date. Also, please
provide copies of invoices and all other documentation, supporting the expense items listed.
REQUEST NO. 25: The 2011 Annual Report for Country Club Hills Utilities on page
7, line 19 lists Account No. 141, Accounts and Notes Receivable—Customers with a balance of
$3,826. However, the schedule of Aged Accounts Receivable for the same period, the Calendar
Year ending 2011, shows a total balance of $9,192. In addition, the amount due from December
SECOND PRODUCTION REQUEST
TO COUNTRY CLUB HILLS 2 JUNE 25, 2012
2011 is listed as $7,906. These are differences of $5,366 and $4,080, respectively. Please
provide a reconciliation for each of these differences.
REQUEST NO. 26: Please provide a detailed schedule of customer deposits being held
by Country Club Hills Utilities as of December 31, 2011. Please include the name of the
customer, amount, date of deposit, and the purpose of the deposit. Please differentiate between
those for sewer services and those for drinking water.
REQUEST NO. 27: Please state if the Financial Statements in the 2011 Annual Report
for Country Club Hills Utilities are presented on an accrual basis or on a cash basis.
REQUEST NO. 28: The 2011 Annual Report of Country Club Hills Utilities, reports
$8,400 for Rental Expense of Plant and Equipment. Please provide the following:
(a)description of items rented;
(b)invoices and any other documentation necessary to support this amount of reported
rental expense;
(c)copies of all contracts supporting this rental expense if any;
(d)please state if this rental is with a related party or entity, and
(e)if so, please provide evidence of arms length equivalents, such as quotes from local
sources for the same or similar item.
REQUEST NO. 29: The 2011 Annual Report of Country Club Hills Utilities reports
$4,800 for Transportation Expenses. Please provide copies of invoices and any other documents
necessary to support this amount of transportation expense.
REQUEST NO. 30: Country Club Hills Utilities reports $4,808 of Miscellaneous
Expenses in its 2011 Annual Report. Please provide a schedule showing the amount and
description of all expenditures in the total. Also, for items equal to or exceeding $100, please
provide copies of invoices and any other documents needed to support the amount.
SECOND PRODUCTION REQUEST
TO COUNTRY CLUB HILLS 3 JUNE 25, 2012
REQUEST NO. 31: Please provide detailed monthly billing information for each of the
148 customers showing volume of water sold (gallons), actual overage (gallons) used for
commodity charge and total amount billed for the calendar years 2009, 2010 and 2011. Please
provide the requested information in executable Excel format.
REQUEST NO. 32: In response to Staff Production Request No. 6, the Company
indicated that it has not received any written complaints from its customers related to water
system operations and water quality since the Company's last general rate case. However, on
May 4, 2012 the Commission received comment from a Country Club Hills customer claiming
that water delivered has "high silt concentrations and sometimes sand." Please provide any test
results conducted by the Company showing that such water quality problems exist or do not exist
in the Company's distribution system as claimed by the customer. Is the Company aware of this
problem? If yes, please explain how the Company is planning to resolve this problem. Has this
problem been identified by IDEQ in violation of current Rules for Public Drinking Water
Systems?
REQUEST NO. 33: During the Company's last rate case (CCH-W-05-1, Order No.
29794), $1,500 per year was included in its rates for the purpose of repairing broken lines
(duplicate service drops installed by previous developer). Please provide a list of all the broken
lines previously repaired and the cost of such repairs during each year from 2005 to 2012.
REQUEST NO. 34: The Company indicated that a new variable frequency drive (VFD)
and pressure transducer were installed on Well No. 2 with a total cost of $8,956 to improve the
efficiency of the pump, increase its life span and reduce power consumption. Response to Staff
Production Request No. 18. Please provide the estimated annual reduction in power
consumption (kWh and demand) and cost for Well No. 2 as a result of installing the VFD.
Please also provide the date of installation and copies of all invoices supporting the cost of this
project.
REQUEST NO. 35: Staff notes that the invoice from American Pump Company dated
August 22, 2006, indicates that repair work was done for Well No. I including installation of
SECOND PRODUCTION REQUEST
TO COUNTRY CLUB HILLS 4 JUNE 25, 2012
new pump and a 25-hp motor with a total invoice amount of $11,749.26. Another invoice from
Denning Well drilling Company dated August 8, 2011 indicates that similar repair work was
completed for Well No. I including installation of a 30-hp pump with a total invoice cost of
$7,754.50. Please explain the difference of services performed for this well on these two
occasions. Please state the reason(s) for increasing the capacity of the motor from 25-hp to 30-
hp. In addition, please explain why replacement of the pumping unit in Well No. 1 was made
within the span of only five years (2006 and 2011).
REQUEST NO. 36: Staff review of maintenance records for Well No. 2 indicates that
the 30-hp pump was replaced in February 2005 with a total invoice amount of $7,370.
Application for Rate Increase, Exhibit for Well No. 2, Denning Well Drilling Co. Invoice billed
to the Company dated February 7, 2005. Another invoice from Denning Well Drilling dated
August 5, 2008 shows that a similar repair work was completed for Well No. 2 including
replacing the 30-hp pump with a total invoice cost of $7,264.75. Please explain the difference of
services performed for this well on these two occasions. In addition, please explain why
replacement of the pumping unit in Well No. 2 was made within the span of only three years
(2005 and 2008).
REQUEST NO. 37: Please provide a copy of bids or quotations submitted by various
vendors per request made by the Company prior to performing the work on Well No. 1 in August
2006 and August 2011 and on Well No. 2 on August 2008. If request bids or quotations were
not requested by the Company from other vendors to provide the noted services, please explain
why not.
REQUEST NO. 38: Please provide the Company's written record of complaints and
requests for conference from the years for calendar years 2009, 2010, 2011 and 2012 to date,
kept pursuant to the Commission's IDAPA 31.21.01. Utility Customer Relations Rules (UCRR)
Rule 403.
SECOND PRODUCTION REQUEST
TO COUNTRY CLUB HILLS 5 JUNE 25, 2012
REQUEST NO. 39: Does the Company request deposits from customers? Please
provide a sample copy of a written denial of service letter and deposit request letter, if the
Company takes deposits. (UCRR - Rule 104)
REQUEST NO. 40: Please provide a sample copy of a bill sent to customers with no
past due balance for each customer rate schedule, if the documents vary by rate schedules.
Please provide a sample copy of a bill sent to customers with a past due balance for each
customer rate schedule if the documents vary. (UCRR - Rule 201 and Rule 202)
REQUEST NO. 41: Please explain how bills are calculated when the Company resumes.
meter readings in April. For those customers billed under a metered rate, how are the
commodity charges calculated? (UCRR - Rule 307)
REQUEST NO. 42: The Company's 2011 Annual Report states that it reads meters
seven times a year. Does the Company send all customers a monthly billing statement? For
those customers billed under a metered rate, how are the commodity charges calculated? Please
provide a sample copy of a bill sent to metered customers for those months when the Company
reads the meter, and for those months when there is no meter reading. (UCRR - Rule 204)
REQUEST NO. 43: 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. 44: Please provide a sample copy of the Rules Summary sent to
customers annually. How and when are customers given the summary? (UCRR - Rule 701)
REQUEST NO. 45: Please provide a copy of the explanation of rate schedules sent to
customers annually and to new customers. Please provide an explanation as to when it is sent.
(UCRR - Rule 101)
REQUEST NO. 46: Please provide a copy of the following Company documents: Initial
Notice to Terminate, Final Notice of Intent to Terminate Service (if sent), and the Notice of
Procedure for Reconnecting Service (door tag or notice, if used), for each rate schedule, if the
documents vary by rate schedule. (UCRR - Rule, 304, 305, 310, 311)
SECOND PRODUCTION REQUEST
TO COUNTRY CLUB HILLS 6 JUNE 25, 2012
REQUEST NO. 47: Please provide an explanation of how the Company handles its past
due bills (collection process). (UCRR - Rule, 304, 305, 310, 311)
REQUEST NO. 48: Please provide cost justification for increasing the reconnection fee
to $50. Under what circumstances does the Company collect a reconnection charge?
REQUEST NO. 49: Please provide cost justification for increasing the hook-up fee to
$750. Under what circumstances does the Company collect a hook-up charge?
DATED at Boise, Idaho, this) '1'!ay of June 2012.
OF—
Neil Price
Deputy Attorney General
Technical Staff: John Nobbs/21-30
Gerry Galinato/3 1-37
Chris Hecht/38-49
i:umisc:prodreq/cchw12. Inpjngdg prod req2
SECOND PRODUCTION REQUEST
TO COUNTRY CLUB HILLS 7 JUNE 25, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22 " DAY OF JUNE 2012,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO COUNTRY CLUB HILLS UTILITIES, IN CASE
NO. CCH-W-12-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MIKE GROTH
COUNTRY CLUB HILLS UTILITIES
570 S. YELLOWSTONE AVE.
IDAHO FALLS, ID 83402
/X&
SECRETARY
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CERTIFICATE OF SERVICE