20120510Staff 67-80 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
REC.E..VEQ
2012 MAY 10 AMIO:37
IDAHO -PUBLIC 2TILITIlS OMMk3
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
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
THIRD 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 31, 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.
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 1 MAY 10, 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. 67: Please provide a copy of the "bid specifications" sent to vendors in
April 2011 concerning the meter project.
REQUEST NO. 68: In reference to responses of the two bidders (Company Response to
Staff Production Request No. 15), both vendors indicate that they must cut 3,300 holes in the
meter lid (cover) to install 3300 MXU units. Staff understands that most of these holes were
already cut (drilled) on lids of existing touch-read meters previously installed in the systems.
Please explain why the vendors must drill 3,300 holes when no more than 604 new meters will
be installed.
REQUEST NO. 69: Did the Company install all 604 Sensus iPERL meters obtained in
May 2011 (per winning bid by Wise Excavation) in Falls Water's system? If yes, please explain
the discrepancy of total meter installation of 535 meters (530 in 2011 + 5 in 2012) as shown in
the Company's worksheet entitled "Installed Meter Schedule through 1-31-12." If no, please
state how many meters were not installed.
REQUEST NO. 70: For the total 604 iPERL meters purchased by the Company (per
winning bid by Wise Excavation), please provide a schedule showing how many meters the
Company actually replaced with the newly acquired iPERL meters, including without limitation:
a) old manual-read meters replaced (fully and partially depreciated units separately identified); b)
old touch-read meters replaced (fully and partially depreciated units separately identified). In the
schedule, please also show how many new iPERL meters the Company installed for unmetered
customers.
REQUEST NO. 71: The Company responded to Staff Production Request No. 3 by
explaining why the Company converted its manual-read meters to automated meter-reading
systems. With regard to the Company's response, please provide additional information
described below:
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 MAY 10, 2012
a)Estimated annual labor savings (manpower and amount) in meter-reading as a result
of converting from manual or touch-read to radio-read system.
b)Estimated vehicle/transportation costs savings in meter-reading as a result of
converting from manual or touch-read to radio-read system.
c)Other cost savings identified by the Company as a result of converting from manual
or touch-read to radio-read system.
REQUEST NO. 72: The Company responded to Staff Production Request No. 3 by
noting that its customers suffered potential water losses due to leakage in supply lines not
previously identified until the Company took meter readings in April. In regard to the
Company's response:
a)Please explain how the Company billed the customers with these losses/leakages (i.e.,
apply the existing tariff for actual volume recorded by meter, etc.)
b)Did the Company incur financial losses from these leakages that occurred in the
customers' service lines? If yes, please document the financial losses.
c)The Company claims 118 customers used over 100,000 gallons ending in April 2010,
and that the total usage was 20,345,000 gallons with a corresponding excess usage
(above the 12,000 gallon volume allowance) of 11,849,000 gallons for these 118
customers. Please provide documentation that actual leaks occurred in these
customers' service lines. Please provide an estimate of extra costs billed by the
Company (or extra cost paid by the 118 customers) as a result of these "leaks" over
their normal winter usage.
d)The Company claims 106 customers used over 100,000 gallons ending in April 2011,
and that the total usage was 16,729,000 gallons with a corresponding excess usage
(above the 12,000 gallon volume allowance) of 9,169,000 gallons for these 106
customers. Please provide documentation that actual leaks occurred in their service
lines. Please provide an estimate of extra costs billed by the Company (or extra cost
paid by the 106 customers) as a result of these "leaks" over their normal winter usage.
e)The Company claims one customer had a bad leak during the October 2007 to April
2008 reading and had a total usage of 2.2 million gallons. Please provide an estimate
of extra costs billed by the Company (or extra cost paid by the customer) as a result
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 3 MAY 10, 2012
of this "leak" over the customer's normal winter usage. Similarly, the Company
claims that another customer had a bad leak over winter months a few years earlier
that showed usage of over 2.2 million gallons. Please provide an estimate of extra
costs billed by the Company (or extra cost paid by the customer) as a result of this
"leak" over the customer's normal winter usage.
REQUEST NO. 73: Please provide all written records of customer complaints and
requests for conferences about customer winter billings related to leaks within the customers'
service lines during the calendar year 2009, 2010 and 2011.
REQUEST NO. 74: Please explain the Company's general understanding of why
residential customers used less water in July 2009 than they did in July 2010 and 2011 (see
Company's Excel spreadsheet "Unaccounted Water Loss" table as part of Company Response
No. 28).
REQUEST NO. 75: The Company responded to Staff Production Request No. 34 by
indicating that the Company is withdrawing its proposal to create a new schedule for Private Fire
Sprinkler and Service. Does Falls Water serve private fire sprinkler systems? If yes, please state
how many private fire sprinkler systems are served, and explain why the Company does not
charge private fire sprinkler users for the Company's water services.
REQUEST NO. 76: Please provide a schedule showing the Company's calendar year
2011 payments to, for or on behalf of Kelley Howell. This schedule should include date of
check, check number, payee, dollar amount and purpose. Are any of these payments included in
the Pro forma results of operation, Exhibit 2, in this case FLS-W-12-01 2? If yes, please provide
the associated amount per account number.
REQUEST NO. 77: Please reconcile the Company's CYE 2010 and CYE 2011
Contribution in Aid of Construction (CIAC) accounts.
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 4 MAY 10, 2012
REQUEST NO. 78: Application Exhibit 2, line 34, Account 642, Rental of Equipment,
reports $31,474.28 for the CYE 2011. This amount includes payments for rental of equipment
owned by Brent Johnson. Please provide the following:
a)Please provide an explanation and documentation demonstrating the need for this
equipment. Your response should include, without limitation, job schedules, equipment needs,
etc., coinciding with the beginning and ending of the rental periods.
b)Please provide quotes from an unrelated party showing that the amounts paid are the
same or less than the amounts for the same or similar equipment available in your area.
REQUEST NO. 79: Please explain why the Company needed to hire a temporary office
worker to handle extra meter project-related paperwork. Please also provide a schedule showing
the detailed components for the $12,852 for the temporary office worker including amounts
capitalized, total wages, related payroll taxes, etc. Please also state if this temporary worker was
related to the owner and, if so, explain the relationship.
REQUEST NO. 80: Please explain how the Company determined the $26,666 in
financing for the meter project. Also please provide a schedule showing the loan number,
payments including the amounts of principal and interest, check number, amounts, payee, etc.,
related to this financing.
DATED at Boise, Idaho, this IO day of May 2012.
V ;~ 4~~ -
Karl T. Klein
Deputy Attorney General
Technical Staff: Gerry Galinato/67-75
John Nobbs/76-80
i:umisc:prodreq/flsw 12.1 kkgdgjn prod req 3
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 5 MAY 10, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF MAY 2012,
SERVED THE FOREGOING THIRD 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]
SECRETAR'
CERTIFICATE OF SERVICE