20091125Staff 48-54 to FLS.pdf

KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
gECE n
1~~~ NQ~ 25 llM 9: 4 \
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 COMPAN FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES.
)
) CASE NO. FLS-W-09-1
)
) THIRD 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,
Krstine A. Sasser, Deputy Attorney General, requests that Falls Water Company (Company;
Falls Water) provide the following documents and information on or before FRIDAY,
DECEMBER 11, 2009.
This production request is to be considered as continuing, and Falls Water is requested to
provide, by way of supplementar 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
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 1 NOVEMBER 25, 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. 48. In reference to the Company's response to Request No.2, the table
of water testing cost shows tests are conducted for Well Nos. 1,5,8,9 and well field. Staff notes
that the Company also owns and operates Well Nos. 2, 3, 4 and 6. Please explain why these
wells do not have costs for water source testing.
REQUEST NO. 49. The Company is proposing to use the 2008 excess water usage data
for varous classes of customers in estimating the expected test case revenue (presented in
Exhibit 5 of the Application and Estimated Revenue tab of the Company's Worksheet). Please
provide justification why the 2008 excess water usage data was used in the calculation rather
than normalized excess usage values.
REQUEST NO. 50. Please explain who prepared the bid documents and project
specification for the construction of the major components of the Well NO.9 such as: (a) well
construction and development; and (b) construction of well house, mainline tie-in, pumps, etc.
REQUEST NO. 51. The Schiess & Associates 2004 Engineering Study recommended
that the Company develop the Iona Road Well and the Crowley Road Well to improve system
pressures and keep supply in pace with demand; (References: July 19, 2004 and June 25, 2004
letters to Falls Water Co., Attachment 13, Company response to Request No. 26). However, the
Company developed Well NO.9 which is located in Deborah Road. Please explain why the well
was sited at a different location than that recommended in the study.
REQUEST NO. 52. The engineer's estimate for the construction and development of
Well NO.9 was $223,050 (Attachment 24, Company Response to Request No. 34). Staff notes
that the lowest bid to construct and develop the well was $114,285 and was awarded to Andrew
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 NOVEMBER 25, 2009
Well Driling Services, Inc. for a total contract price of$114,285 based on the original project
specification. However, the final cost in completing the construction and development of Well
NO.9 was $282,843.63, a cost overr of approximately 147%. Please explain these
discrepancies.
REQUEST NO. 53. Please provide the data (tables) presented in response to Production
Request No. 39,40,42 and 44 in executable electronic Excel format (tables in CD).
REQUEST NO. 54. Exhibit 5 of the Company's Application uses 3,593 total number of
customers (residential=3,460, multi-family residential=71, commercial=62) in estimating
expected revenues using the Company's proposed rates. However, in response to Request No.
41, the Company indicated a total number of customers at the end of the 2008 test year was
3,585 (residential=3,426, multi-family residential=83, commercial=76). Please explain the
discrepancies and why the Company proposes to use 3,593 total number of customers.
/)~ø
Dated at Boise, Idaho, this ¿L-J day of November 2009.
~jl~Kr tine A. Sasser
Deputy Attorney General
Technical Staff: Gerr Galinato/48-54
i:umisc:prodreq/flsw09.\ ksgg prod req 3.doc
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 3 NOVEMBER 25, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF NOVEMBER 2009,
SERVED THE FOREGOING THIRD 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: utiltygroup(iyahoo.com
Jo rfkSECRETAR
CERTIFICATE OF SERVICE