20070820Staff to FLS 1-18.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
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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 FORAN ORDER
AUTHORIZING INCREASES IN THE
COMPANY'S RATES AND CHARGES FORWATER SERVICE
CASE NO. FLS-07-
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
Donald L. Howell, II, Deputy Attorney General, requests that Falls Water Company (Falls Water;
Company) provide the following documents and information as soon as possible, but no later than
MONDAY, SEPTEMBER 10, 2007
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 COMPANY AUGUST 20, 2007
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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: The Company is proposing four new projects to improve system
reliability (Line-Looping Projects). Are these a DEQ requirement? Please describe in detail the
projects and benefits that will result.
REQUEST NO.2: The Application indicates that the Company plans to convert those
remaining customers, not yet metered, from flat rates to metered rates by mid-2008. How many
customers are still on flat rates? Please describe the Company s plan and timeline for converting
the remaining unmetered customers to metered customers.
REQUEST NO.3: The Company plans to hire another full-time administrative employee.
Please define and identify the additional workload the Company is experiencing to justify hiring
this employee.
REQUEST NO.4: Please provide any salary surveys performed by the Company or any
other information justifying the recent increases in its employee salaries?
REQUEST NO.5: Please identify the decision process and supporting reasons used by the
Company to justify the need for new office space.
REQUEST NO.6: Please explain the Company s statement in the Application, at the
bottom of page 3
, "
Well head protection regulations require the Company to move these programs
to another location.
REQUEST NO.7: The Company currently uses a trailer and shed for storage and
maintenance purposes. Please provide justification for plans now in place to replace these facilities.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY AUGUST 20, 2007
REQUEST NO.8: Please describe how the Company s water testing process changed
resulting in increased expenses? Has DEQ changed the frequency oftesting, or added additional
tests? Or, have the costs of the same tests increased?
REQUEST NO.9: The Company hired one additional maintenance person. What salary
for the new position was included in the reported labor costs for wages and salaries? Please provide
justification for the Company s decision to hire an additional maintenance person.
REQUEST NO. 10: How many full-time maintenance persons are needed to perform
service calls? Please describe the most recurring reasons for service calls. What is the normal
frequency of service calls? Is the Company experiencing a current service call backlog? Please
provide the monthly service call orders received and worked for the past two years, by month.
REQUEST NO. 11: The Company reported that it reads meters seven times per year for
the metered residential customers. Please describe the process used by the Company to true up the
readings and provide the customer with the appropriate billing for the period of time when the
meters are not read.
REQUEST NO. 12: Please provide a table (in excel format if available) depicting the
following monthly information for the past three (3) years, 2004, 2005, and 2006, and separate
residential from commercial:
Year and month
# Customers metered
# Customers on flat rate
Total gallons (metered well) pumped
Total gallons metered to customer
REQUEST NO. 13: Please provide an estimate of the annual systems lost and unaccounted
for water, i., what is your estimate of the amount of water pumped that does not get billed to your
customers. Provide the information for the last three (3) years, 2004, 2005 , and 2006.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY AUGUST 20, 2007
REQUEST NO. 14: Please provide the number of customer complaints received by the
Company for calendar year 2006 and 2007 to date, broken into categories by topics: credit and
collections; line extensions service outages; billing, rates and policies, etc.
REQUEST NO. 15: Please provide an example of a customer billing statement sent out by
the Company.
REQUEST NO. 16: Please provide a copy of the Company Initial Notice of Past Due
document.
REQUEST NO. 17: Please provide a copy of the Company Final Notice of Past Due
document.
REQUEST NO. 18: Please provide a copy of the Company s annual Summary of Rules
and Customer Regulations.
DATED at Boise, Idaho, this r;);J'day of August 2007.
Donal L. Howell, II
1/ Deputy Attorney General
Technical Staff: Dan Graves
Chris Hecht
i:umisc:prodreq/flswO7. 1 dhdgch prod req l.doc
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY AUGUST 20, 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF AUGUST 2007
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO FALLS WATER COMPANY, IN CASE NO.
FLS-07-, 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
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CERTIFICATE OF SERVICE