20120503Staff 45-66 to FLS.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
RECEVED
'z12t1M3 iU:53
¶T Ji 3 cot
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 AN ORDER )
AUTHORIZING INCREASES IN THE )
COMPANY'S RATES AND CHARGES FOR )
WATER SERVICE )
)
)
CASE NO. FLS-W-12-01
SECOND 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,
Karl T. Klein, Deputy Attorney General, requests that Falls Water Company (Company; Falls
Water) provide the following documents and information as soon as possible, but no later than
THURSDAY, MAY 24, 2012.
This Production Request is to be considered as continuing, and the Company 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 1 MAY 3, 2012
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 45: Please identify the number of field collections on a monthly basis
for each year from 2009 forward to date. Please identify the separate classes of customers and
include whether those collections were completed during normal business hours or outside of
normal business hours.
REQUEST NO. 46: Please identify the number of disconnections for non-payment on a
monthly basis for each year from 2009 forward to date. Please identify the separate classes of
customers and include whether those disconnections were completed during normal business
hours or outside of normal business hours.
REQUEST NO. 47: Please describe the Company's current online bill pay program,
Xpress Bill Pay. Please provide the cost-benefit analysis, if any, that the Company performed
prior to implementing the program.
REQUEST NO. 48: Please justify the Company's decision to initiate the Xpress Bill
Pay program at no direct cost to those customers who use the service, rather than charging a
separate user fee per transaction.
REQUEST NO. 49: Please provide enrollment and usage information of the Xpress Bill
Pay program by month since implementation.
REQUEST NO. 50: Please provide additional detail on any ongoing cost for the Xpress
Bill Pay program as implemented by the Company, including any planned or necessary costs for
upgrades or improvements. Please provide details of any known costs for necessary changes or
upgrades to Company computer systems or software or additional programming necessary to
monitor accounts.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 MAY 3, 2012
REQUEST NO. 51: Please provide a schedule of the charges comprising the amounts
for a line extension quote as of December 31, 2011. Also, please include the specific charges for
water rights, and the formula or other method of calculating the total estimate or quote.
REQUEST NO. 52: Please provide a schedule listing all individuals, businesses and
developers requesting a quote for line extensions during the last three years. Please provide the
following for each:
1)Identify the requesting party and state if it is a residence, business or developer;
2)Itemize the specific charges included in calculating each line extension total;
3)Specify if the line extension was installed;
4)Identify dollar amounts collected for each.
REQUEST NO. 53: For the list provided in the above response, please provide all
workpapers and a schedule calculating the itemized charges, all formulas and the method of
computing the total of each connection charge or quote. Please provide the calculations in Excel
format with formulas included and activated.
REQUEST NO. 54: Exhibit 2, page 2, Column U, line 52 includes an adjustment for
depreciation expense totaling $84,210.10. Please provide the details for this depreciation
adjustment and state if it is only for items included in the 2012 meter project.
REQUEST NO. 55: In your response to the Production Request No. 15, copies of two
estimates were provided. Wise Excavation was selected. The estimated total cost for the Wise
bid was $815,625. The adjustment to Account No. 334 for the 2012 meter project totaled
$839,878.35 as shown on Exhibit 1. Please provide a schedule itemizing the $839,878.35
adjustment and identifying the $24,253.35 difference between the Wise Excavation estimate and
the adjustment. If any part of the differences resulted from change orders, please provide copies
of those change orders.
REQUEST NO. 56: If not provided in the above response, please provide a list of the
categories of items in the 2012 audit adjustment to Account No. 334-meters, totaling
$839,878.35, shown on Exhibit 1, line 8. Each category should include a description of the
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 3 MAY 3, 2012
category contents (such as meters, meter box extensions, etc) dollar total for the category, and
supporting invoices.
REQUEST NO. 57: The Falls Water 2011 Annual Report Page 1, Item 12, lists
Company contacts. This list shows Tony Wise for engineering and engineering service. Please
state if Tony Wise is an employee of Falls Water. Also, please state if he is an owner in Wise
Excavation. If Tony Wise is an employee and not an owner of Wise Excavation, please explain
the relationship of the owner(s) of Wise Excavation to Tony Wise.
REQUEST NO. 58: If Tony Wise is an employee and an owner of Wise Construction,
please state if Tony Wise, as the contractor, used machinery or equipment from Falls Water on
the 2012 meter project. If machinery or equipment belonging to, rented by, or leased to Falls
Water was used, please provide a schedule identifying the equipment and cost of using this
equipment. The cost should be based on rental or lease prices, if not owned by Falls Water, or
on operating costs, depreciation and interest, if owned.
REQUEST NO. 59: For Account No, 334-Meters, the property records identify an entry
described as "Meters and MXUs purchased" dated 4/3/09 for a total of $13,317.84. Please
provide copies of supporting documentation for this entry and amount. The documentation
should include all bids, purchase contracts, invoices and adjustments or allocations used to
calculate this total.
REQUEST NO. 60: The property records for Account No. 334-Meters show retirements
totaling $36,014.36. Dates in service are listed, but no date of retirement. Please provide a
schedule of the retirement dates for each item in the property records.
REQUEST NO. 61: The recent application includes property records for Account No.
334-Meters. This record shows replacements during 2011, totaling $17,962.17. In the Falls
Water Annual Report, page 5, no additions to this account are listed for 2011. Please explain this
difference of $17,962.17.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 4 MAY 3, 2012
REQUEST NO. 62: The lease dated September 10, 2008, between Falls Water and
Rockwell Development of Ammon, Idaho, describes the leased property as 2180 Deborah Dr.,
Idaho Falls, Idaho, 83401. The property is further described as having 1600 square feet of office
space and 2400 square feet of shop space for a total of 4000 square feet of space. This lease
commenced on September 1, 2008 and expires in 2012. The base rent is listed as $2,700 per
month during the first year. In addition the base rent increases $100.00 per month in each year
thereafter. Please demonstrate why the base rent and the escalators in this lease are justified in
the current market environment for commercial property in your area. Please include estimates
or quotes for similar properties in your area. Each quote should have categories for shop space
and for office space.
REQUEST NO. 63: The lease dated September 1, 2011 between Brent Johnson and
Falls Water identifies property at 2180 N. Deborah Dr. having 9,000 square feet of space. This
is 5,000 square feet more than the September 2008 lease. Please explain the need for the
additional 5,000 square feet. Also, please include any economic analysis including values, cost-
benefit analyses, etc., justifying the decision to lease an additional 5,000 square feet of space.
REQUEST NO. 64: Account No. 303-Land and Land Rights reflects an entry described
as "Water Right final payment to Idaho Water Company" dated 2/24/11 for the amount of
$209,505. Please provide documentation including copies of sales contracts and all other
documentation necessary to support the listed total amount.
REQUEST NO. 65: Please provide a schedule of Contributions in Aid of Construction
for each account in your property records, beginning in calendar year ended (CYE) 2009. Also,
please include additions to each account by year for Contributions in Aid of Construction for the
CYE 2010, CYE 2011 and 2012 to date.
REQUEST NO. 66: Please provide a monthly schedule of revenues for 2011 and 2012
identified by meter size and customer type (i.e. residential, commercial, fire, etc).
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 5 MAY 3, 2012
DATED at Boise, Idaho, this 3' day of May 2012.
Karl T. Klein
Deputy Attorney General
Technical Staff: Chris Hecht/44-50
John Nobbs/5 1-66
i:umisc:prodreq/flsw12.1kkewhjn prod req 2
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 6 MAY 3, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3" DAY OF MAY 2012, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO FALLS WATER COMPANY, IN CASE NO. FLS-W-12-01, 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: [e-mail]
A~qy/~-
SECRETARY
CERTIFICATE OF SERVICE