200509191st staff production request to Eagle.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
C:Ei\!EO
. ;"
;; U
r;;.
"-:.:
inf\r, C'-r-J:4 2: ti 4
"-.uuu ,j!..~
. .
, ,! i, i
:) 1
":(.
~Y'
if S iON
JIlL_IIIC,) Lt liili.,J
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF EAGLE WATER
COMPANY'S REQUEST FOR A TEMPORARYSURCHARGE CASE NO. EAG-05-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
EAGLE WATER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Donald L. Howell II, Deputy Attorney General, requests that Eagle Water Company (Eagle
Water; Company) provide the following documents and information on or before MONDAY,
OCTOBER 3, 2005.
This Production Request is to be considered as continuing, and Eagle Water 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.
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.
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.
FIRST PRODUCTION REQUEST TO
EAGLE WATER SEPTEMBER 19, 2005
Reference IDAPA 31.01.01.228. For documents provided please include the name and phone
number of the person preparing the document, and the name, location and phone number of the
record holder.
For all responses to the following requests, please provide all workpapers, diskettes
(3.5 in.) and all underlying formulas in Excel (version 5) language.
REQUEST NO.1: Please provide a detailed explanation of what events/actions caused
the failure of the 12-inch water main that fed the booster pump serving Eagle Springs. In the
Company s Application, Exhibit No., Mr. Reese states that the operator of the gravel
pit.. . removed the 12-inch C-900 water main.
a) Was this 12-inch water main in an established utility easement? If so, please provide
a copy of that easement.
b) If not in an established utility easement, why not?
c) If the 12-inch water main was in an established utility easement, why is the gravel
company not liable for their actions, which caused the failure of the water main?
REQUEST NO.2: Please provide a written explanation of why Well No.5 was never
fully developed. Please include a schedule of all expenses incurred and copies of all invoices
pertaining to the development of Well No.
REQUEST NO.3: Please provide explanation and documentation related to the interest
rate calculation on estimated borrowed funds.
a) Why is the quoted interest rate set at PRIME + 2?
b) Is this interest rate fixed or floating?
c) How is the credit worthiness of the borrower factored in the quoted interest rate?
d) Have you received quotes from other banks or financial institutions? If so, please
identify the institutions.
e) Does Eagle Water believe that this is the lowest interest rate achievable?
REQUEST NO.4: In Order No. 24474 (Case Nos. EAG-91-1; EAG-92-1) and
Order No. 24890 (Case No. EAG-93-1) the Commission granted approval for a hook-up fee
FIRST PRODUCTION REQUEST TO
EAGLE WATER SEPTEMBER 19 2005
surcharge to be used only for the development of a new well and a variable speed pump for that
well. Please provide schedules showing the accounting for this hook-up fee surcharge account
including, but not limited to:
a) list of developer payments showing date, amount and developer;
b) name of bank or financial institutions where funds were deposited;
c) all deposits and withdrawals;
d) copies of all bank statements; and
e) copies of all invoices showing how the monies were spent; and
f) a reconciliation of this account showing all debits and credits in this account as well as
a current account balance.
DATED at Boise, Idaho, this 1971tday of September 2005.
.-bfl Donald L. owell, II
- Deputy Attorney General
Technical Staff: Dave Schunke
Eric Johnson
Kathy Stockton
i :umisc:prodreq/eagwO5 .2dhdesej
FIRST PRODUCTION REQUEST TO
EAGLE WATER SEPTEMBER 19 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF SEPTEMBER 2005
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO EAGLE WATER COMPANY IN CASE NO. EAG-05-, BY MAILING
A COpy THEREOF POSTAGE PREPAID , TO THE FOLLOWING:
ROBERT DESHAZO
PRESIDENT
EAGLE WATER COMPANY INC
PO BOX 455
EAGLE ID 83616-0455
MOLLY O'LEARY
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83707
SECRET AR
CERTIFICATE OF SERVICE