20160216DIA to Staff 7-15.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX $72A
BOISE, IDAHO 83720-0074
[phone]
IL}AHU TTAK NU. UJ-IU
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 INCREASE IN RATES AI\ID CHARGES
FOR WATER SERVICE IN TIIE STATE OF
IDAHO
RLCEIVED
:li[ ri8 I G f,H t0: 25
i'.i ,i,il8s,ou
BEFORE TIIE IDAHO PI]BLIC UTILITIES COMMISSION
CASE NO. DIA-W.15.0I
REPLY TO SECOND
PRODUCTION REQUEST
OF COMMISSION STAFF
COMES NOW Diamond Bar Estates Water Co ("Diamond Bar Water", "Applicant" or
o'Company") and files this response to the second production request of the Commission Staff.
Questions regarding these responses should be directed to:
Robert N Turnipseed Alden Holm
Diamond Bar Estates Water Company 9446W Fairview Ave.
PO Box 1870
Hayden tD 83E35
P: 208.665.9200
Boise ID 83704
P: ZUE.3'2'2.U7'ZU
Please provide copies of all correspondence, notices and orders to the above individuals.
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. ln 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
deficiencies andlor recommendations, if deficiencies and/or recommendations exist.
RESPONSE: Aprit 9 20l2ldaho Department of Environmental Quality (IDEQ) Saniary
Survey is enclosed as Exhibit 12- March 27 20I5IDEQ Sanitary Survey is enclosed as Exhibit l2a-
Response prepared by Cristy Turnipseed, Admin Witness, Robert N Turnipseed
REQUEST NO. 8: Please provide monthly water production data from 2011 to present.
RESPONSE: Diamond Bar Estates Water's Pump house flow meter reads the flow of
water into the reservoir only. At this time there are no readings for water flow to the distribution
lines. Enclosed is Exhibit 13 providing pump house readings for the flowmeter of water going
mto the reservor. lhrs does not deprct the productron data you requested to be used rn
comparison to the billings of the years 201l-2015
Response prepared by Cristy Turnipseed, Admin Witness, Robert N Turnipseed
REQUEST NO.9: Please provide monthly consumption data (total system) from 201I
to present.
REPSONSE: Enclosed is Monthly Consumption Data. See Total Usage Column page
3 of Exhibits 14, l4u l4b, l4c, and l4d.
Response prepared by Cristy Turnipseed, Admin Witness, Robert N Turnipseed
REQUEST NO. 10: Please provide monthly consumption data - by customer - for all
months in which data is available (e.g., April through October) from 201I to present.
RESPONSE: Enclosed is Monthly Consumption Data by customer.
See Column "Customer" of Exhibits 14,l44l4b,l4c, and l4d.
Response prepared by Cristy Turnipseed, Admin Witness, Robert N Turnipseed
REQUEST NO. 11: Please provide an estimate of total unaccounted water losses due to
leaks, wasted water, etc. by month from 201I to present. Please explain how these losses are
estimated.
RESPONSE: As stated in Response to RequestNo 8 Diamond Bar Water does not have
Production data atthis time. Enclosed Exhibits 1ld and 1 le which each are a well service record
explaining the Repairs done over the years. From 2002 forward Diamond Bar Estates has been
at the recervmg end of mconsrstent, unbalanced as well as underpowered servrce trom Kootenar
Electric Co-op. During the down times of removing and replacing the well pumps, Diamond Bar
Estates Water was receiving water service for their customers from Robert N Tumipseed's
private well at no charge to Diamond Bar Water, due to lack of funds and extensive repair bills.
While the private well served the Diamond Bar Water, billing proceeded as normal, therefore
water data was unaccounted for on the production end to compare to the billing amounts. We
also serve the Northern Lakes Fire District who uses our hydrants frequently such as the event
occurring over the Thanksgiving Weekend when a home in another subdivision caught fire. In
these cases water is not tracked. Diamond Bar Water is unaware of any waterline leaks, if any.
Response prepared by Cristy Turnipseed, Admin Witness, Robert N Tumipseed
REQUEST NO. 12: Please provide cost support for the proposal to increase from
$310.00 to $475.00 the fee for first time installation of a meter to serve new customers.
RESPONSE: The increase in meter purchases just from 2012to 2015,
See Exhibit 15 and 15a explains the proposed increase. Meter installation involves the
Certified Water Master driving to pick up meter and parts, drive to location of installation and
follow up with customer about meter installation is complete. Diamond Bar Water should be
invoiced monthly a reasonable amount for vehicle wear and tear, due to lack of funds the vehicle
wear and tear is absorb by the Owner.
Response prepared by Cristy Tumipseed, Admin Witness, Robert N Turnipseed
ruiQutjs't' N(). 13: Reterencmg pnor Audrt Request No. U, please proude
documentation for, and an explanation of, the source of firnds for the following deposits:
A. The deposit on8l5l20l4 for $1,750.00.
B. The deposit on9l4l20l4 for $5,000.00.
C. The deposit onl0l24l20l4 for $16,500.00.
D. The deposit onl2l512014 for $4,170.91.
PJSPONSE: Deposit A was an effor of check written from the wrong account
The deposit reflects the return of the funds. Deposit B reflects a loan from Owner, Robert N
Turnipseed. Deposit C reflects a loan from Owner, Robert N Turnipseed. Deposit D reflects a
check received from Travelers, The Boiler Insurance Policy.
Response Prepared by Cristy Turnipseed, Admin Witness, Robert N Turnipseed
REQUEST NO. 14: Please provide bank statements for each month in the year ending
December 31,2015.
RESPONSE: Enclosed are requested Monthly Bank Statement for 2015.
See Exhibit 16.
Response Prepared by Cristy Turnipseed, Admin Witress, Robert N Turnipseed
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.).
RESPONSE: Available funds are through Owner, Robert N Turnipseed, whether
personally or borrowing from one of his entities. If a bank loan,60/o interest, is to be taken it is
done in Robert N Turnipseed name and his personal financial security.
Response by Cristy Turnipseed, Admin Witress, Robert N Turnipseed
Respectfully Submiued
President, Diamond Bar Estat6s Water Company