20090409Staff 39-47 to EAG.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
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Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF EAGLE WATER )
COMPANY'S APPLICATION FOR )
AUTHORITY TO IMPLEMENT A CUSTOMER )SURCHARGE. )
)
)
)
)
CASE NO. EAG-W-09-1
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
EAGLE WATER COMPANY
The Staff of the Idaho Public Utilties 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 as soon as possible, but no
later than THURSDAY, APRIL 23, 2009.
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. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Eagle Water is requested
to provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
SECOND PRODUCTION REQUEST
TO EAGLE WATER COMPANY 1 APRIL 9, 2009
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. 39: Please provide a schedule(s), for all the surcharge related cases,
showing the amount charged for legal fees, the date charged for legal fees, and to which case the
legal fees apply.
REQUEST NO. 40: Please provide the back-up documentation for all legal fees for
surcharges and related cases for Eagle Water Company. This includes, but is not limited to, all
legal bilings pertaining to the Eagle Water surcharge cases, including Case No. EAG-W-05-2,
EAG-W-07-1 and EAG-W-09-1.
REQUEST NO. 41: What is the anual amount oflegal service expense embedded in
the base rates of the Company?
REQUEST NO. 42: On page 5 of the Application and in Footnote No.2, the Company
seeks recovery of an additional $6,047.94 in legal fees for Case No. EAG-W-05-2. Footnote No.
2 indicates that Exhibit A to the present Application shows the correct total biling for legal
services is $16,993.16.
a.) Please verify the total amount oflegal fees biled in Exhibit A minus the biled
finance charges is $15,962.58.
b.) Please verify the total amount of finance charges shown in Exhibit A is $269.26.
c.) Please explain any discrepancy between the sum of the above biled legal services
and finance charges in Exhibit A of $16,231.84, and the requested amount of
$16,993.16.
d.) Is there stil an ongoing error?
e.) Please explain the difference and why it differs from the original $10,945 authorized
for recovery.
SECOND PRODUCTION REQUEST
TO EAGLE WATER COMPANY 2 APRIL 9, 2009
REQUEST NO. 43: Does the Company propose to recover the finance charges shown
in the Application's Exhibit A? What are the reason(s) for the finance charges? Why should
ratepayers be responsible for paying finance charges denoted in Exhibit A?
REQUEST NO. 44: On page 5 of the Application, the Company shows that the TOTAL
Biled (August 2005 to curent) for the Engineering Report legal fees for the EAG-W-05-2 case
is $32,786.02.
a.) Does that amount include the biling "clerical error" of $6,047.94?
b.) Does the amount of$32,786.02 shown on page 5 of the Application also include the
previously authorized surcharge amount of$IO,945.22?
c.) Please provide a detailed explanation of the difference (balance) requested of
$16,554.18 above the $16,232 previously authorized for recovery.
REQUEST NO. 45: Please provide a schedule showing the hours biled for legal
services and the hourly rate for legal services that support the Company's request for $14,905.72
for "EAG- W -07 -1" shown on page 5 of the Application.
REQUEST NO. 46: Please provide a schedule showing the biled legal services thus far
(including the hourly rate and the number of biled hours) which are included in the $15,000
estimate for legal fees for this case shown on page 5 of the Application in Paragraph NO.7.
REQUEST NO. 47: Requests No. 20 to 28 contained in the First Production Request
were related to Booster Pump Modification for Well No.2. It is Staffs understanding that
modification work is currently being done on Well NO.2 booster pump as cited in the
Company's Application (p.2, Item C.ii., System Improvements). However, in page 3 of the
Application, the project listed as curently being completed, with an estimated cost of $175,000,
is occurrng in the Main Booster station. Is the main booster station the same as Well NO.2
booster pump? Please explain this discrepancy.
SECOND PRODUCTION REQUEST
TO EAGLE WATER COMPANY 3 APRIL 9, 2009
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DATED at Boise, Idaho, this day of April 2009.
Technical Staff: Gerr D. Galinato
Kathy Stockton
i:umisc:prodreq/eagwaJ. I dhgdgkls prod req 2.doc
SECOND PRODUCTION REQUEST
TO EAGLE WATER COMPANY 4 APRIL 9, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF APRIL 2009,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO EAGLE WATER COMPANY, IN CASE NO. EAG-W-09-1,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
ROBERT DESHAZO
PRESIDENT
EAGLE WATER COMPANY INC
172 W. STATE STREET
EAGLE ID 83616
MOLLY O'LEARY
RICHARDSON & O'LEARY
515 N. 27TH STREET
BOISE ID 83707
E-MAIL: molly(ßrichardsonandoleary.com
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SECRETARY
CERTIFICATE OF SERVICE