20160624Staff 21-40 to MVW.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W, WASHINGTON
BOISE, IDAHO 83702.5983
Attorney for the Commission Staff
RECE IVED
Iill6 Jl.li,l 2t+ Pll 12: l6
:]: :i r i,tjijLlC' , "',,::' :l':ii.{F,{lSSl0N
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
MORNING VIEW WATER COMPANY INC.
FOR AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO
CASE NO. MNV.W.16.O1
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
MORNING VIEW WATER
COMPANY,INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Morning View Water Company, Inc.
("Moming View" or "Company") provide the following documents and information as soon as
possible, but no later than FRIDAY, JULY 15,2016.
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 holder and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Morning View 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 produced.
THIRD PRODUCTION REQUEST
TO MORNING VIEW WATER
JUNE 24,2016
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 identifu the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 21: Please list the debt items that total $19,151.69 for short-term debt,
and $550,653.69 of long-term debt, as stated in Exhibit No. 3 to the Company's Application.
Please also include the documents supporting the interest rates and terms of repayment.
REQUEST NO. 22: Please list the Company's owners and describe the Company's
succession plans, if any. If the Company has a written succession plan, please provide it.
REQUEST NO. 23: In the Company's response to Staff Production Request No. 12, the
Company indicated that a meter costs $401. Please provide the invoice, supplier price list, and
other documents showing the meter cost is $401.
REQUEST NO. 24: On average, how much time is required to install a meter for a new
customer, including driving time? Is the installation work performed by just one person? If not,
please state how many persons are required to install a meter, and describe their respective roles
in the installation process.
REQUEST NO.25: On average, how many miles are driven to connect a new
customer?
REQUEST NO.26: How many new customers does the Company expect to connect
over the next two years? What is the basis for the Company's expectation?
REQUEST NO.27: Does the Company expect any problems in serving new demand?
If so, please explain the expected problems and the Company's proposed solutions to those
problems.
THIRD PRODUCTION REQUEST
TO MORNING VIEW WATER
JUNE 24,2016
REQUEST NO. 28: Please provide monthly water production data from January l,
2013 to present.
REQUEST NO. 29: Please estimate the Company's total unaccounted water losses due
to leaks, wasted water, etc. by month from January 1,2013 to present. Please explain how these
losses are estimated. If loss data is not available for any period within the 2013 to present
timeframe (for example, because of lack of customer metering), please state the time period for
which the data is not available, and explain why the data is unavailable.
REQUEST NO.30: Please provide a schedule showing each of the Company's wells,
the size of the motor, pumping capacity in gallons per minute, and depth of well.
REQUEST NO. 3l: Please provide a schedule for each of the Company's reservoirs
showing the type of construction and means of system pressurization and capacity.
REQUEST NO. 32: Are all customers served with the same size meter?
REQUEST NO.33: Please provide the name and license number for all licensed
operators employed or contracted by the Company since January 1,2013.
REQUEST NO.34: The Company's Annual Reports for 2013 through 2015 show sales
(in 1000 gallons) at71,469; 67,266; and72,4l9 for 2013,20t4 and20l5, respectively, and
customer count at 106 over the period. Are these results based on metered data? Please explain.
REQUEST NO. 35: The Company's Annual Reports for 2009 through 2011 show sales
(in 1000 gallons) at 64,508 for all three years. Is this an estimated value? If so, what is the basis
for the estimate?
REQUEST NO.36: The Company's Annual Report for2012 show sales (in 1000
gallons) at 62,135. Is this an estimate or a reliable metered result?
THIRD PRODUCTION REQUEST
TO MORNING VIEW WATER
JI-INE 24,2016
REQUEST NO. 37: Following up on Production Request No. 2, please produce a copy
of the Note Payable to Dawn Gneiting.
REQUEST NO. 38: Following up on Production Request No. 2, please produce a copy
of the Note Payable to Nolan Gneiting.
REQUEST NO. 39: Following up on Production Request No. 4, explain, and provide a
copy of, your preparation and deposit procedures for cash deposits.
REQUEST NO. 40: Following up on Production Request No. 2, please produce a copy
of the bank transaction record for the cash transfer or payment to Landco on March 11,2015,
totaling $572.95.
DATED at Boise, Idaho, this Ztlryday of June 2016.
lU / /L-
Frr: Neil Price
Deputy Attorney General
Technical Staff: Joe TerrylZl-22
Bentley Erdwurm/23-36
John Nobbsl3T-40
i:umisc:prod req/mnvwl6.lnpjtjnbe prod req 3
THIRD PRODUCTION REQUEST 4
TO MORNING VIEW WATER
JUNE 24,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF JUNE 2016,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO MORNING VIEW WATER COMPAI\TY, INC., IN
CASE NO. MNV.W.16-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWNG:
NOLAN GNEITING OWNER
MORNING VIEW WATER CO
PO BOX s98
RIGBY ID 83442
E-MAIL: mornin gviewater:@gmai l.com
CERTIFICATE OF SERVICE