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Home My WebLink About200512221st staff request to Falls Water.pdf;:_~:' /LD SCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BAR NO. 1895 cr" ? ' t' '1 j (J : tj ~ . ,- . . 1. I, t.. , ,j ;' ij;3LiC ; :l:'::; COii;':JSSIOiJ 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 THE APPLICATION OF FALLS WATER COMPANY, INc. FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES CASE NO. FLS-05- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO FALLS WATER COMPANY The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Scott Woodbury, Deputy Attorney General, requests that Falls Water Company (Falls Water; Company) provide the following documents and information on or before THURSDAY, JANUARY 5, 2006. 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 IDAP A 31.01.01.228. This Production Request is to be considered as continuing, and Falls 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 FALLS WATER DECEMBER 22, 2005 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. Request No.1: Please provide a copy of water conservation information that was provided to the customers in 2004 and 2005.A. How often was this information provided to the customers?B. Was this information provided to both metered and flat rate customers? Request No.2: When were the meters in the Henderson Trailer Park replaced? If they have not been replaced, please explain why not. Request No.3: How many customers who were in the process of having service turned off for non-payment during 2004, paid the serviceman who had come to turn off the service? How many paid at the door during 2005? Request No.4: Please provide monthly water usage data for each customer for the 2004 test year in an electronic copy using Excel or similar format. Please separate the data by customer class and include the total water pumped by Falls Water for the period. Request No.5: Please identify each residential customer listed in response to Request No.4 as a metered mobile home or trailer park service if that definition applies. Request No.6: Please identify each residential customer listed in response to Request No.4 that is presently served by a secondary irrigation system. Request No.7: Please provide a copy of specifications, purchase orders and work orders for all system improvements made since the last rate case. This is to include meter replacement new meter installation, pump replacement, new mains, new services and any special expense or capital items that have been added to the Falls Water system. FIRST PRODUCTION REQUEST TO FALLS WATER DECEMBER 22, 2005 Request No.8: Please provide copies of water utility electric bills for the years 2003 and 2004. Request No.9: Please provide a copy of the latest maps and/or drawings showing the location and sizes of all pumping facilities, storage facilities, mains, fire hydrants, isolation valves, purge valves, sampling locations and service stubs. Request No. 10: Please provide a copy of the letter, settlement agreement, or other documents granting the water rights obtained recently by the Company that are conditioned upon establishing a secondary irrigation system. Include any supporting documents necessary for Commission Staff to understand the terms of the water rights (restrictions, etc.) and the settlement agreement with intervenors. Also, please provide a timetable for and written copy of the ordinance the Company will propose to the county in accordance with the requirements of that settlement. Request No. 11: The Company proposed tariff includes both summer and winter rates for those customers not living in areas required to use secondary irrigation. The Company proposes a higher rate for a seven month summer period. Given that summer periods are normally set for a period of no more than five months, please provide justification for the proposed seven-month period. Additionally, please confirm if this tariff structure is intended to apply to all customers regardless of availability of secondary irrigation sources. Respectfully submitted this ex;j day of December 2005. Technical Staff: Carol Cooper Harry Hall Kathy Stockton Scott Woodbury Deputy Attorney General i:urnisc:prodreq/flswO5. 1 swcchhkls prl FIRST PRODUCTION REQUEST TO FALLS WATER DECEMBER 22, 2005 CER TIFI CA TE OF SER VI CE I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF DECEMBER 2005 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO FALLS WATER COMPANY, IN CASE NO. FLS-05- , BY MAILING A COpy THEREOF, POSTAGE PREPAID , TO THE FOLLOWING: K SCOTT BRUCE FALLS WATER COMPANY INC 1770 SABIN DR IDAHO FALLS ID 83406 SECRETARY CERTIFICATE OF SERVICE