20151120Staff 1-20 to Eagle Water.pdf

DONALD L. HOWELL, II
BRANDON KARPEN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03121334-03 s7
IDAHO BAR NO. 336617956
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
IN THE MATTER OF EAGLE WATER
COMPANY'S APPLICATION FOR
AUTHORITY TO IMPLEMENT A
TEMPORARY CUSTOMER SURCHARGE.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. EAG-W.15.01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
EAGLE WATER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Eagle Water Company
(Eagle Water; Company) provide the following documents and information as soon as possible,
but no later than FRIDAY, DECEMBER 11,2015.
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 supplementary responses, additional documents that it or any person acting on
its behalf may later obtain that will augment the documents produced.
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY NOVEMBER 20, 2015
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. l: The Surcharge Application, beginning on page2,lists system
improvements in item numbers 3 and 4. Please provide all invoices and all source documents for
each and every item listed.
REQUEST NO.2: Please provide a detailed explanation of how the costs listed in items 3
and 4 of the Application are currently accounted for and reflected on the books of Eagle Water
Company.
REQUEST NO.3: Please provide a schedule identifying each item and showing the in-
service dates for each plant item listed in items 3 and 4 of the Application.
REQUEST NO. 4: Please provide copies of any and all bids received by Eagle Water
Company for each line item listed in numbers 3 and 4 of the Application.
REQUEST NO. 5: Please provide the location of the Main Booster Station listed in item
number 3 of the Application. Is this booster station part of the infrastructure of Well #8? If not,
please provide justification for its installation.
REQUEST NO. 6: Please provide the directives requiring the line relocations for the
State Street Bridge, Horseshoe Bend Road Bridge, and Hill Road items listed in number 4 of the
Application. If any payments were received by Eagle Water Company from the entity requesting
the line relocations, please identiff the payment amounts and provide the source documents
substantiating the payments.
REQUEST NO. 7: Please provide the rationale for upsizing the line from 8 inches to 12
inches for Well #7. Please provide an explanation of why this was not done during the
construction and design of Well #7.
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY 2 NOVEMBER 2O,2OI5
REQUEST NO. 8: Please provide a description of the repairs to Well #4 and Well #6.
Include in your description the reason for the repairs.
REQUEST NO. 9: Please provide a detailed accounting showing receipts, payments and
the balance in the existing Surcharge Account authorized in the previous surcharge case (IPUC
Order No. 30734).
REQUEST NO. l0: The Company indicates that the capital projects listed in item
numbers 3 and 4 have already been paid for and constructed. Please provide a list of the source of
the funding provided to finance these projects, and provide source documents such as paid
invoices, billings, and cancelled checks, showing payment for these projects,
REQUEST NO. ll: Please provide a description of how the proceeds of the proposed
loan will be dispersed. Include the dollar amount to be paid and the name of the person or entity to
receive the payment.
REQUEST NO. 12: For Tariff Schedules 2 and 6, please provide the following
information for the year 2014:
a. The number of customers billed under each schedule.
b. The total volume of water billed under each schedule.
c. The volume subject to the 48.075% surcharge (IPUC Order No. 30734) under each
schedule.
REQUEST NO. 13: For any Tariff Schedule I customers classified as Master Metered
Mobile Home Parks. Please provide the number of customers, the total billed water volume, and
the billed volume subject to the 48.075% surcharge (IPUC Order No. 30734) in20l4.
REQUEST NO. 14: Please provide the total quantity of water provided to United Water
Idaho, Inc. under Tariff Schedule 7 in20l4.
REQUEST NO. 15: Please provide the number of new customers who were charged
hook-up fees under Tariff Schedule 5 in20l4.
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY 3 NOVEMBER 2O,2OI5
REQUEST NO. 16: Recently, Eagle Water Company amended some of its annual reports.
There appear to be some discrepancies related to the customer statistics reported on page l2 of
these reports (Items 2A,2P., and2C). For the years2012,2013, and2014, please provide the
following information :
a. The numbers of metered residential, commercial, and industrial customers.
b. The volume of water sold to each of these customer classihcations.
c. The numbers of flat rate residential, commercial, and industrial customers.
REQUEST NO. 17: Please provide an estimate of the amount of water pumped during the
system peak hour.
REQUEST NO. 18: Please describe the system used to deliver water from the 90,000
gallon storage tank at Wellhouse No. 2 into the system. Include horse power, rated capacity, and
discharge pressure for each pump.
REQUEST NO. 19: Please provide a current system map, with the locations and sizes of
all distribution pipes, pumps, wells, pressure reducing/sustaining valves, boosters and storage
facilities. Please provide the power (horsepower) and capacity (gpm) for each pump and booster.
REQUEST NO. 20: Please provide pump curves for all pumps and boosters associated
with Wells 7 and 8.
DATED at Boise, Idaho, this dLday of November 2015.
-'-) Ia
'Rrandon l(arpen, I
Deputy Attorney General
Technical Staff: Kathy Stockton/l-l 1
Mike Monrson/12-20
i :umisc:prodreq/eagw I 5. I dhbkklsmm prod req I
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY 4 NOVEMBER 20, 2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF NOVEMBER 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSTON STAFF TO EAGLE WATER COMPANy, N CASE NO.
EAG-W.Is-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BOISE TD 83702 P.O. BOX 455
E-MAIL: molly(Zl)bizcounseloratlaw.com EAGLEID835l5
MOLLY O'LEARY
BIZCOUNSELOR AT LAW
1775 W STATE ST #I5O
ROBERT V DESHAZO, JR.
PRESIDENT
EAGLE WATER COMPANY, INC.
CERTIFICATE OF SERVICE