20091030Staff 22-47 to FLS.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
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in09 OCT 30 PM 2: 26
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
)
) SECOND 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 FRIDAY,
NOVEMBER 13, 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
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 1 OCTOBER 30, 2009
holder and if different the witness who can sponsor the answer at hearng 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. 22. In the Company's last general rate case (FLS-W-07-01),
Commission Order No. 30484 issued on January 11, 2008 specifically directed the Company to
address the following issues in its rate design when the Company fied its next general rate case:
a) the 12,000 gallon minimum monthly charge; b) the implementation of seasonal differentials in
the allowance; and c) whether the minimum charge should be different based upon meter size.
The Company did not address these issues in its current Application. Please address these issues
as directed by the Commission.
REQUEST NO. 23. The Company proposes to maintain the single block commodity
rate design for all metered customers for both residential and commercial classes, and maintain
the first 12,000 gallons as the basis for the fixed customer charge. To the extent this is not
addressed in response to Request No. 22 above, please explain the rationale behind this approach
in the proposed rate schedules.
REQUEST NO. 24. The Company claims that it is experiencing revenue a shortfall of
approximately $9,000 per month. Please provide a summary of monthly revenue collections and
expenditures in 2008 and 2007. In addition, please provide a 2007 "Profit & Loss Detail" in
Excel format (like what was provided to the audit Staff during the onsite audit). In addition,
please provide the 2008 "Profit and Loss Detail" previously provided on paper in Excel format.
REQUEST NO. 25. One customer of Falls Water wrote to the Commission asking why
construction companies building houses or developing subdivisions take water from the
Company hydrants without paying for it. Please provide explanation of what the Company is
doing or what it plans to do to protect its asset from abuse and minimize this occurrence. The
Company may note that in Teton Springs Water (Case No. TTS-W-08-01) the Commission
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 OCTOBER 30, 2009
allowed Teton Springs Water to include a non-recurring charge for bulk water service for
contractors (Order No. 30718).
REQUEST NO. 26. Please provide justification for the construction of Well NO.9.
REQUEST NO. 27. Please submit the total cost of developing Well No.9 (excluding
water rights-related costs), broken down into the following categories: a) land purchase (identify
the seller); b) well driling/development; c) pump and motor; d) electrical controls; e) variable
frequency drive; f) appurenances; g) pump facility building; h) back-up generator; i) mainline
tie-in; and j) engineering costs. Please provide copies of invoices and other documents
supporting these costs.
REQUEST NO. 28. In Order No. 30484, Case No. FLS-W-07-01, the Commission
noted the likelihood that the property for Well No.9 was purchased from an affiliate of Falls
Water. For affliate expense to be justified, the utilty needs to provide compellng evidence of
ar's length bargaining when incurring costs between the utilty and the affiiate. In addition, it
appeared that the water rights were acquired from a company affiliated with Falls Water's vice
president. In this case, the Company is asking to include Well NO.9 and its associated water
rights in rate base. Please provide the necessary information to demonstrate the reasonableness
of the costs for the purchase of the lot and water rights for Well No.9, including evidence of
arm's length bargaining.
REQUEST NO. 29. Please provide a copy of the well completion report, driling permit,
and water rights associated with Well NO.9. Please include the well driler's log, specifying the
depth and diameter of the well, and pump test results.
REQUEST NO. 30. Please provide the design capacity (gpm) of the pump and size of
motor (hp) in Well NO.9.
REQUEST NO. 31. Please provide the size of back-up generator (kW) for Well NO.9.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 3 OCTOBER 30, 2009
REQUEST NO. 32. Please provide the as-built plans for the completed Well NO.9
(well, pumping plant, back-up generator, mainline-tie-in, etc.).
REQUEST NO. 33. Staff notes that Well NO.9 was placed into service in May 2009.
Please provide copies of documentation indicating that the Idaho Deparment of Environmental
Quality has given approval of the as-built plans for Well NO.9 to operate it as par of the Falls
Water system.
REQUEST NO. 34. Please provide an explanation and documentation (competitive bid
documents, selection process, work contracts, etc.) showing cost control efforts have been
applied in paying for any of the work elements for Well NO.9 (i.e., well development,
installation of pumps and motors, back-up generators, etc.) to be sure that the project was built as
economically as possible.
REQUEST NO. 35. Please provide a list of all Company water rights that are licensed,
under permits, under protests, specifying the License No. or Permit No., priority date, authorized
diversion rate (cfs) and authorized anual volume (acre-feet), if applicable, issued by the Idaho
Deparment of Water Resources.
REQUEST NO. 36. Please provide a list of all water rights purchases made through
private transactions specifying the date of purchase, seller, flow rate and/or volume of water
purchased, and total cost of acquisition for each transaction. Please provide a copy of the sales
agreement for each transaction.
REQUEST NO. 37. Please provide the curent peak flow requirements (PHD-peak hour
demand) of the Falls Water system (i.e., cfs, gpm, gpd).
REQUEST NO. 38. Please provide a list of all well source pumps and their
corresponding design capacity (gpm).
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 4 OCTOBER 30, 2009
REQUEST NO. 39. Please provide monthly water production data and appropriate
yearly total for calendar years 2006, 2007 and 2008.
REQUEST NO. 40. Please provide monthly water consumption data for each class of
customers served (commercial, residential and multi-family residential) and the appropriate total
for calendar years 2006,2007 and 2008. For unmetered customers during any period, make an
appropriate estimate.
REQUEST NO. 41. Please provide the year-end number of customers for each customer
class for calendar years 2006, 2007 and 2008.
REQUEST NO. 42. Please provide an estimate of total unaccounted water losses due to
leaks, wasted water, etc., by month for calendar years 2006, 2007 and 2008. Please explain how
these losses are calculated.
REQUEST NO. 43. The Company plans to install 300 new meters and 300 MXU
transmitters with a total cost of $85,536 in 2009. Application at 2. Please provide a construction
bid, detailed cost estimate(s) or actual invoice(s) if project is already completed. Please indicate
what size(s) of service meters are being replaced. If the project is not complete, please provide
the estimated completion date.
REQUEST NO. 44. After completing the project described in Request No. 42, Staff
assumes that the Company's meter replacement program is complete; that means all customers
wil be metered. Please provide the total breakdown of meters installed by size for each
customer class. Please provide also the breakdown of the meters installed by type, such as: a)
touch read meters; and b) manual read meters.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 5 OCTOBER 30, 2009
REQUEST NO. 45. Please provide a detailed estimate or copy of actual invoice(s) of a
fire hydrant replacement shown in Exhibit 1, colum E, line 9. Please explain if this fire hydrant
is going to be reimbursed by the City of Ammon or the local fire district. If not, why not.
REQUEST NO. 46. The Company states that at the beginning of the summer irrigation
period, many customers question their usage being biled. The Company indicates that it has
conducted tests for the accuracy of the service meters. Please provide the total number of meter
accuracy tests performed by the Company in 2007 and 2008. Please indicate how many of the
total meters tested did not meet the manufactuer's accuracy specification of plus/minus 1.5%.
REQUEST NO. 47. In Commission Order No. 30027, the Commission ordered the
Company to "enhance its SCADA software capabilties, to identify and better control its water
loss and to improve its delivery effciency." Please explain the status of the Company's SCADA
system and address the efforts instituted by the Company to control water losses and improve its
delivery system.
'2I\TlIDated at Boise, Idaho, this -..day of October 2009.
~O;a.~A,istine A. Sasser
Deputy Attorney General
Technical Staff: Gerry Galinato/22-47
i:umisc:prodreq/fsw09.1 ksgg prod req 2.doc
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 6 OCTOBER 30, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30TH DAY OF OCTOBER 2009,
SERVED THE FOREGOING SECOND 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.
2180N. DEBORAH DR.
IDAHO FALLS, ID 83401
E-MAIL: scott1Ø)fallswater.com
ROBERT E SMITH
2209 N BRYSON RD
BOISE ID 83713
E-MAIL: utilitygroupØ)yahoo.com
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SECRETA
CERTIFICATE OF SERVICE