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Home My WebLink About20080411Staff to MSW 1-33.pdfKRISTINE A. SASSER DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BARNO. 6618 ". t:'...$ vi Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ) IDAHO SPRINGS WATER COMPANY, INC. ) FOR A CERTIFICATE OF PUBLIC ) CONVENIENCE AND NECESSITY ) ) ) ) ) CASE NO. ISW-W-08-1 FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO SPRINGS WATER COMPANY, INC. The Staff of the Idaho Public Utilties Commission, by and though its attorney of record, Kristine A. Sasser, Deputy Attorney General, requests that Idaho Springs Water Company, Inc. (Company; Idaho Springs) provide the following documents and information as soon as possible, but no later than FRIDAY, MAY 2, 2008. 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. Reference IDAPA 31.01.01.228. This Production Request is to be considered as continuing, and Idaho Springs 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. FIRST PRODUCTION REQUEST TO IDAHO SPRIGS 1 APRIL 1 1, 2008 Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearng. REQUEST NO.1: Please provide a schedule of all rate base claimed by the company that is included in the monthly rates calculation. Please provide a copy of all evidence documenting the cost of the rate base. REQUEST NO.2: Please provide the number of employees employed by the water company. Please provide a schedule separately showing by employee and cost category all wages and associated employee costs. REQUEST NO.3: Please provide a schedule of all costs for the water system including the cost of the wells, storage, transmission system, and distribution system. Please provide all documentation evidencing the costs. REQUEST NO.4: Please provide a schedule of all fees collected by the water company or any predecessor or affiiated company of the water company for connection to the water system. REQUEST NO.5: Please provide a schedule of all revenues collected by the water company from its inception to the curent date. REQUEST NO.6: Please provide a schedule of all contribution to plant received by the water company other than the fees collected for connecting to the system. REQUEST NO.7: Please provide a schedule of all anual expenses claimed by the water company as par of its rates. FIRST PRODUCTION REQUEST TO IDAHO SPRINGS 2 APRIL 1 1, 2008 REQUEST NO.8: Please provide a schedule showing the anual or monthly charge for all contractors doing continuing service for the water company, and please provide a copy of all contracts documenting the fee paid to the contractor, the term of the contract, a description of the services provided and any additional charges that could be paid under the terms of the contract. REQUEST NO.9: Please provide a schedule of all services provided to the water company by any affiiate of the water company and state how much is charged for those services and how the price is determined. REQUEST NO. 10: Please provide all information on how the Capital Sinking Fund was determined. REQUEST NO. 11: Please provide a copy of all income tax returs for the water company. REQUEST NO. 12: Please provide a schedule of how the gross up factor was determined. REQUEST NO. 13: Please provide a schedule of the rate case costs and how the water company determined that it should recover those costs. REQUEST NO. 14: Idaho Springs Water indicated that the first occupancy was made sometime in June 2006. When did the Company star delivering water to the first residential customer and start charging fees? REQUEST NO. 15: Staf notes that the general area being served by Idaho Springs Water is about 2 ~ miles from the Kuna City Water system. Please indicate how close United Water Company's water supply and distribution system is to the Idaho Spring's water supply system. REQUEST NO. 16: Who is the curent certified operator ofIdaho Springs Water? Staff notes that Valley Hydro, Inc. was the listed operator in the October 2005 Report to Idaho Deparment of Environmental Quality (IDEQ). Please provide current contact information, if different. FIRST PRODUCTION REQUEST TO IDAHO SPRINGS 3 APRIL 1 1, 2008 REQUEST NO. 17: Please provide documentation showing that the Company fully complied with the IDEQ's Regulations for Public Drinking Water Systems prior to providing water service to customers in Arrowrock Ranch Subdivision. REQUEST NO. 18: Please cite the specific legal description of the following areas: (1) areas to be covered by the existing domestic water system, and (2) areas being requested for the issuance of a Certificate of Public Convenience and Necessity if different from (1). These areas are not clearly defined in Item V. of the Application and Exhibit B. REQUEST NO. 19: The Company indicated during the intervenors' informal meeting on April 8, 2008 that the curent wells and water pumping system could serve 2000 residential customers. The Engineering Report shows that there are curently two pumps with a total capacity of 750 gpm and a third pump with a capacity of 1,000 gpm that is solely dedicated to fire protection. Please explain how the domestic water supply pumps (750 gpm) can serve 2,000 residential customers. REQUEST NO. 20: Staff notes that there were two letters of drinking water quality violations issued to the Company by IDEQ. An IDEQ letter issued on November 24,2006 indicated that the drinking water system on November 17, 2006 showed the presence of total coliform (TC) bacteria and the letter on Januar 16,2007 also indicated a presence of total TC bacteria. Please explain how the Company addressed these violations. REQUEST NO. 21: One customer recently complained to the Commission about "continuous water quality problems" with the service provided by Idaho Springs Water. Are there any other drinking water quality problems or violations in addition to the ones cited above? If so, please explain the nature of the problems/violations and how they were addressed by the Company. REQUEST NO. 22: Please provide monthly well water production data since Idaho Springs stared delivering water to customers up to the most recent month (ending March 2008, if possible) expressed in gallons. FIRST PRODUCTION REQUEST TO IDAHO SPRINGS 4 APRIL 1 1, 2008 .- REQUEST NO. 23: The table known as Exhibit D of the Application indicates average monthly usage and cost. Please provide units of usage and an itemized breakdown of costs. REQUEST NO. 24: It is Staffs understanding that individual meters were installed for curent customers and were initially read by United Water staing September 2006 and are now being read by Idaho Springs Water. Please provide monthly water consumption data for each customer since United Water stared reading customer meters up to the most recent month (ending March 2008, if possible) expressed in gallons. Please designate customer type (residential construction, residential occupied homes, common areas, commercial, others). REQUEST NO. 25: What costs, in addition to the cost of meter and installation, are incured by the Company when a new customer requests water service? Please provide documentation of previous costs of customer meters and installation. REQUEST NO. 26: Staff notes from water utilty plans that the service line to residential customers is a 1 -inch diameter pipe. Please indicate the size of service lines to other classes of customers (common areas, etc.). REQUEST NO. 27: Please provide detailed monthly operation and maintenance costs for the water system since Idaho Springs Water stared serving customers. REQUEST NO. 28: In accordance with Rule 101, Uniform Customer Information Rules (UCIR), a copy of the explanation of rate schedule is to be given to new customers and sent to existing customers on an anual basis. Please provide a copy of any rate schedule explanation provided or to be provided to new or existing customers. REQUEST NO. 29: In accordance with Rule 102 (UCIR) please provide a copy of any notice sent to customers regarding the Company's revised request for approval of rates. Please provide an explanation as to when it was sent and whether it was sent separately or as a bil stuffer. FIRST PRODUCTION REQUEST TO IDAHO SPRIGS 5 APRIL 1 1, 2008 REQUEST NO. 30: In accordance with Rule 102 (UCIR) please provide a copy of any press release for the Company's revised request for approval of rates and dates of when it was mailed to media. REQUEST NO. 31: If deposits are required by the Company because of bad credit or disconnection, please provide a sample copy of a written denial of service letter and deposit request letter. Deposit Rules are covered in Rules 100 -111 of the Uniform Customer Relations Rules (UCRR). Also regarding deposits, in accordance with Rule 109 (UCRR), please provide a sample copy of the receipts used to record deposits received. REQUEST NO. 32: Please provide a sample copy of a bil for Idaho Springs Water Company that is being sent to customers with no past due balance to verify compliance with Rule .201 (UCRR). REQUEST NO. 33: Please provide a sample copy of a bil for Idaho Springs Water Company that is being sent to customers with a past due balance to verify compliance with Rule 202 (UCRR). . itDATED at Boise, Idaho, this 1I day of April 2008. ~.a.~JIlô'Kris me A. Sasser Deputy Attorney General Technical Staff: Joe Leckie Gerry Galinato Chris Hecht i:umisc:prodreq/isww08. lksjlggcwhprod req l.doc FIRST PRODUCTION REQUEST TO IDAHO SPRINGS 6 APRIL 1 1, 2008 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF APRIL 2008, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO SPRINGS WATER CO., INC., IN CASE NO. ISW-W-08-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: JOHN R. HAMMOND JR. FISHER PUSCH & ALDERMAN SUITE 500 101 S CAPITOL BLVD BOISE, ID 83701 EMAIL: jrh(ifpa-Iaw.com TRENT NIEFFENEGGER IDAHO SPRIGS WATER CO. INC. PO BOX 344 MERIDIAN, ID 83642 EMAIL: trentßYwestparkco.com ALDEN J HOLM CPA WEST VALLEY BUSINESS CENTER 9446 W FAIRVIEW AVE BOISE ID 83704 EMAIL: alden(itreasurevalleycpa.com GERALD J. CORVINO 11865 W TUSTIN LANE KUNA ID 83634-5032 EMAIL: gcorvino(iyahoo.com ~SECRETA. CERTIFICATE OF SERVICE