20230612Staff 2-11 to KHW.pdf

MICHAEL DUVAL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF KOOTENAI HEIGHTS )WATER SYSTEM'S APPLICATION FOR )CASE NO.KHW-W-23-01
AUTHORITY TO INCREASE ITS RATES )AND CHARGES FOR WATER SERVICE IN )THE STATE OF IDAHO )SECOND PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO KOOTENAI HEIGHTS
)WATER SYSTEM
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Kootenai Heights Water System
("Company"or "Kootenai Heights")provide the followingdocuments and information as soon
as possible,but no later than WEDNESDAY,JUNE 28,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 also identify the name,job title,location,and
telephonenumber of the record holder.
SECOND PRODUCTION REQUEST
TO KOOTENAI HEIGHTS 1 JUNE 12,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.2.Please provide a copy of the Company's QuickBooks file.Please
ensure that this file has data from January 1,2020,through March 31,2023.Please also note
which edition of QuickBooks is currentlyused,and provide sufficient credentials,such as
username and password,to access the file.An external accountant login for the QuickBooks file
should be sufficient.
REQUESTNO.3:Please provide a printed copy of PDF file of the Company's income
statement and balance sheet from QuickBooks used by the Company for the Calendar Years
Ended ("CYE")2020,2021,and 2022.
REQUESTNO.4:Please provide all supporting documentation for revenues posted in
the 2019,2020,2021,and 2022 annual report,includingthe amount billed and the amount
collected.
REQUESTNO.5:Please provide the make and model of each pump that is connected
to the system.Include pump curves for each pump.
REQUESTNO.6:Please provide the Electrical Rate Schedule that Kootenai Heights
Water Company,Inc is charged under for electricity to operate the water system.
REQUESTNO.7:Please provide documentation supporting all expenses included in
Exhibit 2,Schedule B provided with the Application.In addition,please provide any
calculations used to derive the expense totals included in Exhibit 2,Schedule B provided with
the Application.Please provide any workpapers used to determine the expenses in electronic
format with links and formulae enabled.
REQUESTNO.8:For the Company's water system,please provide the following:
SECOND PRODUCTION REQUEST
TO KOOTENAI HEIGHTS 2 JUNE 12,2023
a.A geo-spatialmap of each system showing each well,the distribution piping,storage
tanks,booster pumps,and major valves (includingfire hydrants).
b.The Idaho Department of Water Resources (IDWR)water rights associated with each
system.
c.The name of each well,and its IDWR well identification number.
d.The year,make,model,and capacity for backup generation supporting the well
pumps.Indicate if the generationhas an Automatic Transfer Switch (ATS)or if it
must be manuallystarted.
e.The year each storage tank was installed.
f.A copy of the most recent IDEQ sanitary survey for each water system.If one does
not exist,provide information about the type of water treatment (if any)and treatment
capacity for that system.
g.The dates,causes,and durations of unplanned outages for each system for the last 2
years.
h.The Company's narrative assessment of the system's condition and the need for near-
term (next 5 years)future investment.If a recent master plan exists,please provide a
copy.
REQUESTNO.9:Please provide the monthlypower invoices for the Company's
system from January 2020 through December 2022.If a system has multipleelectric accounts,
please clarify which accounts correlate to which pump.
REQUESTNO.10:Please provide the Company's monthlyconsumption data in
gallons for all months in which data is available from January 2020 throughDecember 2022.
REQUESTNO.11:Please provide a list of all improvements made to the Company's
system since 2007 after the Company's last rate case.Please include the cost of the
improvements,a description of the improvements,how the Company ensured they were
completed at least cost,and written justification for the need for the improvements.
SECOND PRODUCTION REQUEST
TO KOOTENAI HEIGHTS 3 JUNE 12,2023
DATED at Boise,Idaho,this 12 day of June 2023.
Michael Duval
Deputy AttorneyGeneral
Technical Staff:Ty Johnson
i:umise:prodreq/khww23.1mdtj prod req 2
SECOND PRODUCTION REQUEST
TO KOOTENAI HEIGHTS 4 JUNE 12,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18th DAY OF APRIL 2023,SERVED
THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION STAFF
TO KOOTENAI HEIGHTS WATER SYSTEM,IN CASE NO.KHW-W-23-01,BY
MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE FOLLOWING:
BOB HANSEN JEFF COWLEY
KOOTENAI HEIGHTS WATER SYSTEM E-MAIL:
67 WILD HOURSE TRAIL ieff.cowley usa.com
SANDPOINT ID 83864
E-MAIL:wsmibob aol.com
'SEWETARY
CERTIFICATE OF SERVICE