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Home My WebLink About960319v1.docxSUSAN HAMLIN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0300 Street Address for Express Mail: 472 W WASHINGTON BOISE ID 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE INVESTIGATION) INTO WHETHER PACKSADDLE)CASE NO. GNR-W-95-1 DEVELOPMENT CORPORATION IS A ) PUBLIC UTILITY SUBJECT TO )COMMISSION STAFF'S COMMISSION REGULATION.)RESPONSE TO FIRST SET )OF INTERROGATORIES )AND THIRD PRODUCTION )REQUEST OF THE )PETITIONERS SUSAN PATLA )AND DON LINGLE ____________________________________) The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Susan Hamlin, Deputy Attorney General, provides the following documents and information, pursuant to Commission Rules of Procedure 225-229, IDAPA 31.01.01225-229. INTERROGATORY NO. 1: Provide the date and the name of the IPUC staff member who inspected the Packsaddle water system 80,000 gallon storage tank. Was the tank in service on that date? Describe evidence used in determining this. RESPONSE TO INTERROGATORY NO. 1: Robert E. Smith inspected the 80,000 storage tank on May 7, 1995. The storage tank was in operation as evidenced by an observed water level in the sight glass and he observed the open condition of control valves. Response prepared by Robert E. Smith. INTERROGATORY NO. 2: Did a staff engineer do an engineering analysis of the Packsaddle water system? Did a staff engineer do a field evaluation of the system? Provide dates of any such evaluation. RESPONSE TO INTERROGATORY NO. 2: A Staff engineer did an evaluation of the water source in relation to its capability to provide adequate quantities of water to Packsaddle customers. A Staff engineer did not do a field inspection since 90% of the water system is underground. Response prepared by Don Oliason. INTERROGATORY NO. 3: Provide a list of the date, time and locations of each water pressure measurement made at Packsaddle referenced in the staff report dated May 25, 1995. RESPONSE TO INTERROGATORY NO. 3: The following pressure observations were taken by Robert E. Smith between 10:00 A.M. and 2:00 P.M. on May 4, 1995: Block 1, lot 48 (Cantu) pressure 80 psi. Block 1, lot 8 (Higdem) pressure 68 psi. Block 3, lot 7A (Colquette) pressure 62 psi. Block 1, lot 63 (Pump house) Pressure switch (tested by releasing water from lines) turned on at 33 psi off at 46 psi. Advised switch setting should be adjusted to provide a wider range between on and off settings to reduce pressure pump cycling (20 psi range). Response prepared by Robert E. Smith. INTERROGATORY NO. 4: If no engineering report was available for your review of the Packsaddle water system, please describe the methodology used in evaluating the adequacy of the system. RESPONSE TO INTERROGATORY NO. 4: The methodology used to determine the capability of the Packsaddle system is explained on page 3 of the Direct Testimony of Don Oliason. (See Attachment A for additional description of methodology.) Response prepared by Don Oliason. INTERROGATORY NO. 5: Did the staff establish that the replacement of the pressure pump, pressure tank and well No. 1 pump was the result of normal use and not the result of improper operation during periods of low water? Describe how this was determined. RESPONSE TO INTERROGATORY NO. 5: Staff had no information available regarding the actual cause of the failure of this equipment other than its age, and the Company's verbal description regarding the problems encountered during the drought period. Staff accepted that replacement of this equipment was not abnormal given its age. Response prepared by Robert E. Smith. INTERROGATORY NO. 6: Referring to the staff report (May 25, 1995) attachment #1, provide the following information: (a) What data was used for determining electricity expenses during the period August 1994 to Feb. 1995. (b) Were the expenses for materials and supplies based on “Packsaddle Creek Estate General Water Expenses” dated July 1992 through June 1993 and July 1993 through June 1994 as provided in their response to the IPUC's first production request? (c) Provide the methodology used in estimating labor costs to monitor and perform routine maintenance. (d) Provide the methodology used in determining that three round trips per week from Tetonia to the service area would be needed. RESPONSE TO INTERROGATORY NO. 6 (a): Staff used actual electric bills. See response to Lingle/Patla's First Production Request No. 4 dated February 28, 1996. Response prepared by Robert E. Smith. RESPONSE TO INTERROGATORY NO. 6 (b): No. Staff analyzed expenses detailed in the accountants' work papers for preparation of the 1992-3 and 1993-4 income tax returns of Packsaddle Development Corporation for the development of this number and verified the expenditures by check number. Expenses related to maintenance materials for the water system for those two tax years were $528 and $454 respectively. Response prepared by Robert E. Smith. RESPONSE TO INTERROGATORY NO. 6 (c): See Staff response to Interrogatory No. 2, First Set of Interrogatories of Intervenor Robert Young, Sr., dated March 19, 1996. Response prepared by Robert E. Smith. RESPONSE TO INTERROGATORY NO. 6 (d): See Staff response to First Production Request of Intervenors Don Lingle and Susan Patla dated February 28, 1996. Response prepared by Robert E. Smith. INTERROGATORY NO. 7: Identify any dates when Public Utility Commissioners visited the Packsaddle Estates between January 17, 1995 and March, 1996. For each visit, identify purpose of the visit and list persons contacted, visited, interviewed or consulted. RESPONSE TO INTERROGATORY NO. 7: Staff has no knowledge regarding visits to the Packsaddle Estate subdivision by the Commissioners of the Idaho Public Utilities Commission. Response prepared by Robert E. Smith. INTERROGATORY NO. 8: Was the drawing in possession of the IPUC staff engineer, Donald Oliason, titled “Water System As-Built, Proposed Extension” submitted as a response to a IPUC staff request or was it an unsolicited submittal by the Packsaddle Corporation? Provide the date or approximate date it was received by the IPUC and the specific reason for submittal. Is this the current drawing of record for this water system or is the drawing titled “Water System As-Built” on file with District Seven Health and used as Exhibit #2 the current drawing of record? RESPONSE TO INTERROGATORY NO. 8: The drawing Staff Engineer Oliason has is entitled “Water System As-Built, Proposed Extensions,” and it was provided by Consulting Engineer Dale L. Handy of Benton Engineering at Staff's request. Staff did not record the date on which the drawing was received. Staff has no knowledge of what drawings exist in District Seven Health files. Response prepared by Don Oliason. INTERROGATORY NO. 9: Donald Oliason's testimony dated August 23, 1995, at page 3, line 21, indicated a design flow of 2.0 gpm as normal and at page 4, line 8 and 9, indicated the peak demand would be 2.0 gpm. Please define the terms “this design flow” (p. 3) and “peak demand” (p. 4) as used by Mr. Oliason in terms of IDAPA 16.01.08 “Public Drinking Water Systems”: Definitions, section 003. RESPONSE TO INTERROGATORY NO. 9: In Mr. Oliason's Direct Testimony, the words “this design flow” and “peak demand” relate to definition No. 31 in IDAPA 16.01.08, Section 003. Response prepared by Don Oliason. REQUEST FOR PRODUCTION NO. 1: Provide copies of any additional requests for information made by the IPUC staff and any responses by Packsaddle to such requests besides the initial request and the response dated March 20, 1995. RESPONSE TOPRODUCTION REQUEST NO. 1: Staff issued only the one request for production of information. Any other information available to the Staff was acquired by on site review of records and interviews of principals. Response prepared by Robert E. Smith. REQUEST FOR PRODUCTION NO. 2: In Packsaddle's response of March 20, 1995 to the IPUC production request numbers 2, 22, 23, and 24, it refers to Exhibit No. 2 called the Benton Engineering Report. Does the drawing entitled “Water System As-Built” consist of the entire report? If not, provide the engineering report you used to conclude that the system “is well engineered; it has good sources of water, and the ability to deliver water to the customers.” (Order #26296, p. 4). RESPONSE TO PRODUCTION REQUEST NO. 2: A Benton Engineering Report was not used to draw conclusions. Staff only has in its possession the engineering drawings of the system. Staff Engineer Don Oliason has interviewed (via telephone) Mr. Dale L. Handy of Benton Engineering and discussed the information presented by the drawings. Staff is not aware of any written narrative or explanatory letters. Response prepared by Don Oliason and Robert E. Smith. REQUEST FOR PRODUCTION NO. 3: Provide all work products, calculations and analysis used in evaluating the adequacy of the Packsaddle water system. RESPONSE TO PRODUCTION REQUEST NO. 3: See response to Interrogatory No. 4 above on page 3. Response prepared by Don Oliason. REQUEST FOR PRODUCTION NO. 4: Provide a copy of any and all staff work products or other evidence used to determine causes of failure of pressure pump, pressure tank and well No. 1 pump referred to in Interrogatory No. 5 above. RESPONSE TO PRODUCTION REQUEST NO. 4: No calculations or work products exist. See response to Interrogatory No. 5 above on page 3. Response prepared by Robert E. Smith. REQUEST FOR PRODUCTION NO. 5: Provide a copy of any and all work products and calculations used in estimating labor cost referred to in Interrogatory #6 above. RESPONSE TO PRODUCTION REQUEST NO. 5: See Staff responses to Interrogatory Nos. 6 (c) and 6 (d) above on page 4. No other work products or calculations exist. Response prepared by Robert E. Smith. REQUEST FOR PRODUCTION NO. 6: Provide a copy of any and all notes made by Public Utility Commissioners in connection with any and all visits made to Packsaddle Estate identified in Response to Interrogatory Number 7. RESPONSE TO PRODUCTION REQUEST NO. 6: See response to Interrogatory No. 7 above on page 4. Staff does not have access to any personal notes of the Idaho Public Utilities Commissioners. Response prepared by Robert E. Smith. DATED at Boise, Idaho, this day of March 1996. _____________________________________ Susan Hamlin Deputy Attorney General res/rsgdk/gnrw951r.3sh/umisc\pr