20091022Staff 1-21 to FLS.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEIVED
in09 OCT 22 PM 2: 30
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF FALLS WATER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES.
)
) CASE NO. FLS-W-09-1
)
) FIRST PRODUCTION REQUEST
) OF THE COMMISSION STAFF
) TO FALLS WATER COMPANY
)
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Falls Water Company (Company;
Falls Water) provide the following documents and information on or before THURSDAY,
NOVEMBER 12, 2009.
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 wil augment the documents produced.
Please provide answers to each question and any supporting workpapers that provide
detail or are the source of information used in calculations. 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
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 1 OCTOBER 22, 2009
holder and if different the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: Please provide copies of both state and federal income tax returns
for Falls Water Company for 2007 and 2008.
REQUEST NO.2: Please provide a schedule showing all water testing for the years
2000 through 2009, by location, including the cost and frequency of each test.
REQUEST NO.3: Please provide a spreadsheet with the revised Rate Base due to
change in plant in service discussed during the onsite audit.
REQUEST NO.4: Please provide a schedule of Plant in Service as of September 30,
2009.
REQUEST NO.5: Please provide the amount of rental income from water company
property during 2007, 2008 and to date 2009.
REQUEST NO.6: Please provide a description of the source of Other Income, such as
work done for other water companies and municipal water organizations. Please provide a
breakdown of the income received by month and category for 2007, 2008 and to date 2009.
REQUEST NO.7: Please provide the cost benefit analysis completed by the Company
showing that the current Rental Agreement with an affiiate is reasonable.
REQUEST NO.8: Please provide copies of all rental agreements and other leases held
by the affliates between the lessor and other parties with similar terms.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 OCTOBER 22, 2009
REQUEST NO.9: Please provide a market analysis for the current office and
warehouse rental, including rental details for other offces in the area, rental details for other
warehouse space, etc.
REQUEST NO. 10: Please provide a copy of the contract between Falls Water
Company and DJ Park Well. If no contract exists, please provide the terms under which Falls
Water Company provides services to DJ Park Well, and the contact information for DJ Park
WelL.
REQUEST NO. 11: Please provide a copy of the explanation of rate schedules sent to
existing customers anually and to new customers when they take service. Please provide an
explanation as to when it is sent. (UCIR - Rule 101).
REQUEST NO. 12: Please provide a sample copy of a written denial of service letter.
(UCRR - Rule 104).
REQUEST NO. 13: Please provide a sample copy of a bil sent to a customer with no
past due balance. (UCRR - Rule 201).
REQUEST NO. 14: Please provide a sample copy of a bil sent to a customer with a
past due balance. (UCRR - Rule 202).
REQUEST NO. 15: Please provide a sample copy of a bil sent to a customer when the
Company did not read the meter and the biling is minimum charge only. (UCRR - Rule 204).
REQUEST NO. 16: Please provide a sample copy of a bil sent to a customer when the
Company had not been able to read the meter and the Company is biling based on more than one
month's commodity charges. (UCRR - Rule 204).
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 3 OCTOBER 22, 2009
REQUEST NO. 17: Please provide a sample copy of the written transfer notice used
when transferring amounts between customers when the lapse in service exceeds 60 days.
(UCRR - Rule 206).
REQUEST NO. 18: Does the Company offer customers a pre-printed form for a
medical emergency certificate? Ifso, please provide a copy of the form. (UCRR - Rule 308).
REQUEST NO. 19: Please provide the written records of customer complaints and
requests for conferences for calendar years 2006 through 2009 to date. (UCRR - Rule 403).
REQUEST NO. 20: Please provide a sample copy of the Rules Summary required by
Rule 701 (UCRR) sent to customers. How and when are customers given the sumary?
REQUEST NO. 21: For each rate schedule or class of customers, please provide a copy
of the following Company documents: Initial Notice to Terminate, Final Notice ofIntent to
Terminate Service (if sent), and the Notice of Procedure for Reconnecting Service (door tag or
notice if used). Please provide an explanation of how the Company conducts its termination
process. (UCRR - Rule, 304, 305, 310, 311).
.;'i/lÁ
Dated at Boise, Idaho, this ~ day of October 2009.
~d)a,~ÚIKri1~ Sasser
Deputy Attorney General
Technical Staff: Kathy Stockton/l-l 0
Chris Hecht/II-21
i:umisc:prodreq/tlsw09.1kskls prod req I.doc
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 4 OCTOBER 22, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF OCTOBER 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO FALLS WATER COMPANY, IN CASE NO.
FLS-W-09-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
K. SCOTT BRUCE
FALLS WATER COMPANY, INC.
2180 N. DEBORAH DR.
IDAHO FALLS, ID 83401
E-MAIL: scottl(ifallswater.com
ROBERT E SMITH
2209 N BRYSON RD
BOISE ID 83713
E-MAIL: utilitygroup(iyahoo.com
,b~
SECRETAR
CERTIFICATE OF SERVICE