20130816Staff 1-26 to Fox CreekWater.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
FOX CREEK WATER AND SEWER LLC FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. FCW-W-13-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO FOX
CREEK WATER & SEWER LLC
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Fox Creek Water and Sewer LLC (Company,
Fox Creek) provide the following documents and information as soon as possible, but no later
than THURSDAY, SEPTEMBER 5, 2013.
This Production Request is to be considered as continuing, and the 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO FOX CREEK WATER & SEWER AUGUST 15,2OI3
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: In reference to the Company's response to Question No. 6 as part of
the Application (legal description of the certificated area to be served), the Company appears to
propose serving two subdivisions, namely: a) Fox Creek Village, and b) Fox Creek Country Club
Estates. Please respond to the following:
Fox Creek Village:
1) Does the Company propose to include the entire Fox Creek Village (i.e., as described by
the legal description) in the certificated area?
2) If the answer to Item I ) above is yes, please explain your rationale for including Lots M I ,
M2 and M3. Staff understands that the existing water right may not currently apply to
these areas (see Company response to Question No. 11 as part of the Application, page
2).
3) If your answer to Item 2 above is no, please identiff the excluded areas and explain your
rationale for such exclusion.
Fox Creek Country Club Estates:
1) The Company did not provide a map or legal description for the proposed certificated
area within Fox Creek Country Club Estates located in the adjacent north, east and south
of Fox Creek Village. Staff understands that Fox Creek Country Club Estates is located
in a portion of SE% of Section 23, T4N R45E. Please provide a map or legal description
of Fox Creek Country Club Estates and identify the area proposed for certification.
2) The Company provided another plat labeled Fox Creek Estates Subdivision that is
composed of eight lots located in Nl/2 NWI/4SWL14 of Section 26, T4N R48E. This
area is non-contiguous with the water system serving Fox Creek Village and Fox Creek
Country Club Estates subdivisions and is approximately amile southwest of the
Company's system. Please provide an explanation as to why the Fox Creek Estates
Subdivision is included in the Company's CPCN request.
FIRST PRODUCTION REQUEST
TO FOX CREEK WATER & SEWER AUGUST 15,2OI3
REQUEST NO. 2: Please provide a copy of the following engineering reports:
1) Demonstration of Financial, Technical, and Managerial Capacity for a New
Public Water System for Fox Creek Country Club Estates and Fox Creek Village.
2) Operations Manual
3) As-built drawings as approved by IDEQ.
REQUEST NO. 3: If the as-built drawing of facilities as requested in Request No. 2,
Item 3 is not available, please provide an additional map for Fox Creek Village and Fox Creek
Country Club Estates with the two wells and other facility locations (wells, pumps, reservoirs,
mainline and distribution lines indicating pipe size, etc.) clearly labeled (see Company's
response to Question No. 7 as part of the Application providing a copy of plat for Fox Creek
Village and Fox Creek Country Club Estates).
REQUEST NO. 4: If the as-built drawing of facilities as requested in Request No. 2,
Item 3 is not available, please state the sizes (diameter in inches) of service lines for residential
customers.
REQUEST NO. 5: Please explain which organization owns the various physical
components of the water system (i.e. wells, well house, pumps and motors, electrical controls,
appurtenances, pressure tanks, reservoir storage, mainline and distribution system, etc.).
REQUEST NO. 6: Please identify the specific location(s) of the two wells providing
source(s) of water supply for the system (i.e. Lot No. at a specific subdivision).
REQUEST NO. 7: In reference to the Company's response to Question No. I I as part
of the Application (water right license), the Company provided a copy of document from the
Idaho Department of Water Resources indicating the present water right owners are authorized to
use groundwater for domestic use in the Fox Creek Village Subdivision and Fox Creek Country
Club Estates Subdivision, namely: a) Fox Creek Country Club Estates POA, Inc., and b) Fox
Creek Village HOA. Does the Company plan to secure an agreement with the current owners of
FIRST PRODUCTION REQUEST
TO FOX CREEK WATER & SEWER AUGUST 15,2013
the water right to use this right? Or, will the water right be transferred from the current owners
to the Company? Please explain.
REQUEST NO. 8: In reference to the Company's response to Question No. 23 as part
of the Application (attach samples: i.e. Annual Rules Summary), the Company provided a copy
of document entitled "Shared Well Agreement." The agreement describes, among other things,
the sharing of costs in maintaining and operating the water system by the Fox Development,
LLC, Fox Creek Village HOA, and Fox Creek Country Club POA. Does the Company propose
to maintain this agreement? If the answer is yes, please explain the Company's rationale in
maintaining this agreement.
REQUEST NO. 9: In reference to the Company's response to Question Nos. 15 and2l
as part of the Application (number of customers connected to the system), please respond to the
following:
1 ) The Company' s response to Question No. I 5 as part of the Application indicates a
total of 49 residential customers and no commercial customers. However, the
Company's response to Question No. 21 as part of the Application included a list of
current customers served by the Company which indicates a total of 54 customers (32
from page I plus 22 frompage2). Please explain the discrepancies between the two
totals.
2) Provide the total number of residential customers within the Fox Creek Village served
by the water system as of July 31,2013.
3) Provide the total number of residential customers within the Fox Creek Country Club
Estates served by the water system as of July 31,2013.
4) Provide lists for the total number of customers served since the Company started
providing water service for (1) Fox Creek Club Estates and (2) Fox Creek Village
(i.e., for the end of each calendar year from 2004 to 2012).
REQUEST NO. l0: In reference to the Company's response to Question No. 16 as part
of the Application (number of customers ultimately served by the system), the Company
indicates that there are no commercial accounts. However, the Company's response to Question
FIRST PRODUCTION REQUEST
TO FOX CREEK WATER & SEWER 4 AUGUST 15,2OI3
No. l8 as part of the Application indicates that there is a potential for commercial accounts in the
future with addition of well(s). Please identify and provide the total number of lots within Fox
Creek Village and Fox Creek Country Club Hill Estates with potential for commercial hook-ups.
Please explain the type of commercial customers expected to request future water service (i.e.
multi-housing, retail shops, etc.). Please explain the need for additional well(s) to serve the
commercial accounts.
REQUEST NO. 1l: Does the Company currently charge a "hook-up" fee for new
customers requesting service? If yes, please state the amount. Please explain what the hook-up
fee intends to cover.
REQUEST NO. 12: Please state how many new customers the Company anticipates to
connect to the water system for each of the next three years, listed by year.
REQUEST NO. 13: When did the Company start delivering water to the first residential
customer and start charging fees?
REQUEST NO. 14: Please indicate the Company's current rate structure and charges.
REQUEST NO. 15: In reference to the Company's response to Question No. 19 as part
of the Application (proposed rates and charges), the Company proposes to charge a flat rate of
$32.39 per month per customer plus $5.00 monthly management fee. Please provide a copy of
the Company's worksheet showing how the $32.39 per month was calculated. Please provide
justification for proposing to charge a management fee of $5.00 per month per customer and
state the specific services provided with this fee.
REQUEST NO. 16: Staff notes that Rick Nansen is the listed certified operator for the
systems. Please provide a copy of any and all service contracts detailing his responsibilities,
contract amount, and proof that the license is valid and current.
FIRST PRODUCTION REQUEST
TO FOX CREEK WATER & SEWER AUGUST 15,2013
REQUEST NO. 17: Staff notes that'minutes and gallons' data for Pump 1 and Pump 2
have been provided for a six month period from 1 ll30l20l2 to 61512013 (See Company's
response to Question No.l7 in the Application). Please provide monthly production well flow
data since Fox Creek started delivering water to customers up to the most recent month (ending
in July 31,2013), expressed in gallons.
REQUEST NO. 18: Please provide example copies of customer bills for the months of
April and July (2013).
REQUEST NO. 19: Please provide the total annual purchased electric power cost for
the calendar years 2010,2011, and2012, along with a sample bills for May, June, and July of
2013.
REQUEST NO. 20: Staff notes that the IDEQ conducted a Sanitary Survey on the
Company's water system in August 2012 and identified several recommendations for system
improvement. Please provide any communication with IDEQ indicating the status of compliance
of the identified recommendations.
REQUEST NO. 21: Please provide any water quality and water system issues or
violations identified by the IDEQ since the completion of the Sanitary Survey in August 2012
and the compliance status of those issues/violations.
REQUEST NO. 22: Please provide a list for the last three years of all service related
complaints (e.g. low system pressure, pump failure, water system leaks, water quality, high bills,
etc.) and an explanation of how each complaint was resolved.
REQUEST NO. 23: Please provide a list of all water quality tests for all water sources
(wells) and within the distribution system as required by the IDEQ. For each type of test,
indicate the frequency, total cost per test and the prorated yearly (normalized) cost. For example,
Well No.1, arsenic test, every 3 years, $20 per test, $6.67 per year; nitrate test, yearly, $20 per
test, $20 per year, and so on.
FIRST PRODUCTION REQUEST
TO FOX CREEK WATER & SEWER 6 AUGUST I5,2OI3
REQUEST NO. 24: Please provide an estimate of total unaccounted water losses due to
leaks, wasted water, etc. by month for calendar years 2010,2011 and2012. Please explain how
these losses are estimated.
REQUEST NO. 25: Please describe and estimate the cost of any major capital
improvements planned for the next three years.
REQUEST NO. 26: Please provide a list of all capital improvement projects initiated
and completed since the Company started providing water service to Fox Creek Country Club
Estates and Fox Creek Village. Please briefly describe the total cost incurred, completion date
and justification for each project.
DATED at Boise,Idaho, thi, lrbday of August 2013.
Technical Staff: Johanna Bell & Gerry Galinatoll-26
Umisc/prodreq/fcwl3. lnpjbgdg proreql
FIRST PRODUCTION REQUEST
TO FOX CREEK WATER & SEWER
eil Price
Deputy Attorney General
AUGUST 15,2OI3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15,H DAY OF AUGUST
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO FOX CREEK WATER & SEWER LLC, IN CASE
NO. FCW-W-I3-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
ROBERT KINCAID
OWNER
FOX CREEK WATER & SEWER
PO BOX 251
DRIGGS ID 83422
SECRETARY
CERTIFICATE OF SERVICE