20070926Staff to FLS 19-24.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-
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
FALLS WATER CO MP ANY
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
WEDNESDAY, OCTOBER 17, 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.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY SEPTEMBER 26, 2007
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 ofthe 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. 19: In the Company s response to Staff Production Request No., it
indicated that there has been a 59.6% increase in new connections over the last four years. It also
indicted that there were fourteen active developments currently building new homes in its service
territory and three more developments in the planning stages or installing infrastructure. The
Company is claiming that because it didn t have sufficient resources it could not properly inspect
new construction by developers, causing many problems down the road. As a result, the Company
indicated that the field operations manager had to work overtime on numerous occasions. Please
provide the paid overtime hours by position and by month for the past three years (2004, 2005, 2006
and to-date) and if known, describe any abnormal periods of time when overtime hours are
excessive. In addition, please describe how the Company is addressing the problem of inspecting
new construction other than hiring a new maintenance worker.
REQUEST NO. 20: In the Company s response to Staff Production Request No., it
indicated that hiring additional manpower has allowed the Company to reevaluate how its system is
being operated. Describe how the Company plans to increase routine maintenance by specifically
identifying individual maintenance items by what is currently performed versus what are the future
performance expectations. In addition, identify any savings the company hopes to achieve by
increasing routine maintenance.
REQUEST NO. 21: Describe the situation regarding unmetered customers including age
of their system, water loss versus consumption (if known), and size oflots compared to metered
customers. Did the Company consider charging the flat rate customers an interim increased rate
until such time as each is metered? Please explain the rational for and against.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY SEPTEMBER 26, 2007
REQUEST NO. 22: Please provide a description ofthe Company s meter reading program
including the number of meter readers employed and how many man-hours are required each month
to read the meters. Explain what meter readers do during the months that meters aren t read.
Explain how meters are read on accounts that are closed during the months that meters are not
normally read, and explain why the Company chooses not to read meters during the winter months.
REQUEST NO. 23: In reference to the Company s response to Staff Production Request
No. 13 , please explain the fluctuations in unaccounted for water for the three years reported (2004
2005, and 2006) on the spreadsheet. Describe and identify current and future procedures and
programs to assist the Company in the discovery, tracking and limiting the amount of lost and
unaccounted for water.
REQUEST NO. 24: Please provide copies of all the electricity bills for the test year period.
DATED at Boise, Idaho thi~~ay of September 2007.
onald L. Howell, II
Deputy Attorney General
Technical Staff: Dan Graves
Kathy Stockton
i:umisc:prodreg/flswO7.ldhdgch prod reg 2.doc
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY SEPTEMBER 26, 2007
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF SEPTEMBER 2007
SERVED THE FOREGOING SECOND 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
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SECRETARY
CERTIFICATE OF SERVICE