20160106Staff 7-15 to DIA.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83120
BOISE, IDAHO 83120.0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702.5983
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF )
DIAMOND BAR ESTATES WATER COMPANY )
FOR AN INCRE,ASE IN RATES AND CHARGES )
FOR WATER SERVICE IN THE STATE OF )IDAHO )
)
)
)
ldehCI Pul iie Utilitier ,1..,: " r,ll*sierrr
Office ol the Sesreti"x/RECEIVED
JAN 0 6 20t6
Boise,ldaho
CASE NO. DIA-W.l5-OI
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STABF TO
DIAMOND BAR ESTATES
WATER COMPANY
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, requests that Diamond Bar Water Company
(Diamond Bar; Company) provide the following documents and information as soon as possible,
but no later than WEDNESDAY, JANUARY 27,2016.
This Production Request is to be considered as continuing, and Diamond Bar Water
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 produced.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
SECOND PRODUCTION REQUEST
TO DIAMOND BAR WATER JANUARY 6,2016
REQUEST NO. 7: Has the Idaho Department of Environmental Quality (IDEQ)
conducted any Sanitary Survey(s) on the Company's water system since the last general rate case
in2007? If so, please provide a copy. In addition, please provide copies of any communication
with IDEQ indicating any deficiencies identified or recommendations made as a result of the
sanitary survey and the Company's response concerning status of compliance of such
defi ciencies and./or recommendations, if defi ciencies and/or recommendations exist.
REQUEST NO. 8: Please provide monthly water production data from 2011 to present.
REQUEST NO. 9: Please provide monthly consumption data (total system) from 2011
to present.
REQUEST NO. l0: Please provide monthly consumption data - by customer - for all
months in which data is available (e.g., April through October) from 2011 to present.
REQUEST NO. 11: Please provide an estimate of total unaccounted water losses due to
leaks, wasted water, etc. by month from 2011 to present. Please explain how these losses are
estimated.
REQUEST NO. 12: Please provide cost support for the proposal to increase from
$3 10.00 to $475.00 the fee for first time installation of a meter to serve new customers.
REQUEST NO. 13: Referencing prior Audit Request No. 8, please provide
documentation for, and an explanation of, the source of funds for the following deposits:
A. The deposit on8l5l20l4 for $1,750.00.
B. The deposit on9l4l20l4 for $5,000.00.
C. The deposit onl0l24l2014 for $16,500.00.
D. The deposit on 121512014 for $4,170.91.
REQUEST NO. 14: Please provide bank statements for each month in the year ending
December 31,2015.
SECOND PRODUCTION REQUEST
TO DIAMOND BAR WATER JANUARY 6,2016
REQUEST NO. 15: Please provide a listing of available funds that the Company may
be able to call upon if necessary, the source of those funds, and any costs associated to those
funds (i.e. interest rates, withdrawal costs, etc.).
DATED at Boise,Idaho, this bh U^rof January zlrc.
Technical Staff: Bentley Erdwurm/7-|2
Joe Terry/I3-15
i:umisc:prodreq/diawl 5. ldjhbejt prod req 2
SECOND PRODUCTION REQUEST
TO DIAMOND BAR WATER JANUARY 6,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF JANUARY 2016,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO DIAMOND BAR ESTATES WATER COMPANY, N
CASE NO. DIA.W-15.01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
ROBERT TURNIPSEED
DIAMOND BAR ESTATES
WATER CO
PO BOX 1870
HAYDEN ID 83835
E-MAIL : [e-mail]
ALDEN HOLM
9446W FAIRVIEW AVE
BOISE ID 83704
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE