20080925Staff to ROC 20-24.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEIVED
lOUS SEP25 PH 3: 09
IDAHO PUBLIC
UTiliTIES COMMISSiON
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN UTILITY
COMPANY, INC. FOR A CERTIFICATE OF
PUBLIC CONVENIENCE AND NECESSITY.
)
) CASE NO. ROC-W-08-1
)
)
) SECOND PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO ROCKY MOUNTAIN
) UTILITY COMPANY, INC.
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Rocky Mountain Utility Company,
Inc. (Company; Rocky Mountain) provide the following documents and information on or before
FRIDAY, OCTOBER 10,2008.
This Production Request is to be considered as continuing, and Rocky Mountain 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.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN UTILITY
COMPANY
1 SEPTEMBER 25, 2008
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 IDAP A
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
Following the Idaho Public Utilties Commission public hearing held on September 23,
2008 in Rigby, several questions were raised that required attention prior to final deliberation of
the Company's Application.
REQUEST NO. 20: How many residential and commercial customers are currently
connected to the water system and curently being biled?
REQUEST NO. 21: How many residential and commercial sites/lots are curently
connected to the water system where the shut-off valves are tured on, but the lots are not
curently being biled (i.e. ESSA homes)? Please explain why they are not biled.
REQUEST NO. 22: How many residential and commercial sites/lots are currently
connected to the water system where the shut-off valves are closed and not curently being
biled? Please explain why they are not biled.
REQUEST NO. 23: How many water connections are serving common areas (i.e.
parks) and the well lot? What is the approximate size of each common area?
REQUEST NO. 24: Please provide a list of customers charged a $1,500 hook-up fee
and the date the fee was paid.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN UTILITY
COMPANY
2 SEPTEMBER 25, 2008
Dated at Boise, Idaho, this ;t1J day of September 2008.
~.fL.~mKrilne ASser
Deputy Attorney General
Technical Staff; Gerr D. Galinato
i:umisc:prodreq/rocw08.ksgg prod req2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN UTILITY
COMPANY
3 SEPTEMBER 25, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF SEPTEMBER 2008,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN UTILITY COMPANY, INC., IN
CASE NO. ROC-W-08-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
SHERI POULSEN
JENSEN POULSEN & COMPANY PLLC
PO BOX 50225
IDAHO FALLS ID 83405
JIM BERNARD
OWNER! MANAGER
ROCKY MOUNTAIN UTILITY CO. INC.
3894 EAST 200 NORTH
RIGBY ID 83442
JotherSECRETA ~
CERTIFICATE OF SERVICE