200403122nd Request of Staff to Spirit Lake.pdf

JOHN R. HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5470
~"r'Ii
'-! ,- ', .
\ L 'J
, !LED
Hm, V : IvU'III,," L!.
;L1C
Ur!L!Tir~S COI"lr"i!SSION
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 APPLICATION
OF SPIRIT LAKE EAST WATER COMPANY
TO INCREASE ITS CONNECTION FEE.
CASE NO. SPL-04-
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
SPIRIT LAKE EAST WATER
COMPANY
The Staff of the Idaho Public Utilities Commission (IPUC), by and through its
attorney of record, John R. Hammond, Deputy Attorney General, requests that Spirit Lake East
Water Company (Spirit Lake; Company) provide the following documents and information on or
before FRIDAY, APRIL 9, 2004. IDAPA 31.01.01.225 and .229.
The Company is reminded that responses to production requests must include the name
and phone number of the person preparing the document, and the name, location and phone
number of the record holder. IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Spirit Lake 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.
SECOND PRODUCTION REQUEST TO
SPIRIT LAKE EAST WATER COMPANY MARCH 12, 2004
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 employee who can sponsor the answer at a public
meeting. For all responses to the following requests, please provide all workpapers and include
an electronic version on diskettes (3.5 in.) and all underlying formulas intact in Excel 2000
compatible language.
Request No. 18: According to page 11 of the Company s October 31 2002 Annual
Report submitted to the IPUC, 147 additional customers could be served with no system
improvements except a service line and meter. Because 16 hook-up connections were made in
2003 , the current number of additional customers that could be served is 131 (147 minus 16)
based upon that information. The Company s response to First Production Request No.
indicates that there are 90 potential customers that have not paid the connection fee and two lots
not connected but for which connection fees have been paid. Please explain in detail the
difference between these two representations (approximately 40 potential customers).
Request No. 19: For the customers yet to be connected to the system, please identify
how many connections will require:
Only a water meter set;
Only a water meter box set and water meter set; or
A line installed from the water main to the meter and a water meter and water
meter box.
Request No. 20: Staff has received the 24 invoices the Company provided in response to
First Production Request No. 16. Please also provide the invoices for the hook-ups to lots/tracts
254, TP-3/16, 225, 293 and TP 3/9 listed in Company Exhibit "A."
Request No. 21: The Company, in response to First Production Request No. 5b
explained that the Company "selected Mr. Davis due to his 'hands on' experience and
knowledge with the water system and installation requirements.
I As identified by the Company in its response to the First Production Request No. 14.
SECOND PRODUCTION REQUEST TO
SPIRIT LAKE EAST WATER COMPANY MARCH 12 2004
Except for the field work described in the Company s response to First Production
Request No., did/does Mr. Davis perform work for Hanson Industries or any of
its related companies including Spirit Lake East Water and in what capacity
(independent contractor, employee, etcetera). If so, when?
Please describe, to your knowledge, how and when Mr. Davis obtained this
hands on" experience and knowledge. Please state the company/companies for
which he worked (including water companies) while obtaining this experience.
Request No. 22: The Company in response to First Production Request No. 5c stated
Frank Davis has quoted the Applicant fixed prices based on the actual costs." Please provide
the price quotes provided by Mr. Davis.
Request No. 23: Please provide a detailed description of the procedures and work
performed by Mr. Kruger in connection with hook-ups by year during 2001 2002 and 2003.
Request No. 24: As requested in First Production Request No. 10, please provide copies
ofMr. Kruger s timecards for 2001 2002 and 2003.
Request No. 25: The Company in response to First Production Request No. 11 identified
2003 as a year where "labor allocation is slightly higher (due to field problems) based on 38
hours per month." Please provide a detailed description ofthe field problems referenced in the
response including the related work tasks and vehicle use required due to those problems.
Request No. 26: The Company in response to First Production Request Nos. 10 and 12
responded that annual labor, vehicle and administrative expenses are an allocation of Hanson
Industries ' overall costs. Please provide the journal entries for 2002 and 2003 such as journal
entry dated October 31 , 2001 (JE# 0/31B) that charges the water company for maintenance
supervisor and accounting services.
SECOND PRODUCTION REQUEST TO
SPIRIT LAKE EAST WATER COMPANY MARCH 12 2004
Request No. 27: Please provide the supporting calculations for the journal entries
requested above in Request No. 26 including labor rates and hours.
Request No. 28: To the extent not previously provided in response to Request Nos. 26
and 27, please provide the hourly rate of the personnel who perform the administrative functions
described by the Company in response to First Production Request No. 13. If more than one
individual performs those functions, please identify each individual, their hourly rate, hours
performing administrative tasks, and the specific tasks performed.
Request No. 29: Based upon invoices provided to Staff during its review of2001
Company operations, there were 7 hook-ups in 2001 that averaged a cost of approximately
000 (see attachment).
Please describe in detail why the cost of hook-ups have increased substantially in
2002 when compared to 2001. Specifically:1. Please explain why 2002 invoices2 bill $2 500 for tapping the water main
in the road and setting the water meter and boxes when Company
personnel stated a hot tap into the main line, piping, installation of meter
box and meter cost approximately $1 500 in a March 27 2002 response to
an audit request (an increase of almost 70% in 2002).
11.Please explain why invoice #41 dated April 23 , 2002 charges $500 to
install a water meter when invoice #92 dated August 17 2001 charges
$320 to put a water meter in an existing box set (an increase of over 50%
in 2002).
111.Please describe the actions taken by the Company in response to these
increases such as inquiry of contractor(s) regarding services and prices and
the information obtained as a result of those actions. Please include the
name of any contractors contacted and provide any documentation related
to this process.
2 These invoices were provided in response to First Production Request No. 16.
SECOND PRODUCTION REQUEST TO
SPIRIT LAKE EAST WATER COMPANY MARCH 12, 2004
Please explain in detail the reason for the difference between the 12 connections
identified for 2001 in Company s response to First Production Request No. 14
and the 7 connections for which Staff has been provided 2001 invoices by the
Company (see attachment for listing of invoices).
Please provide the invoices for the 2001 connections to the extent not already
provided to Staff (see attachment for listing of invoices).
Dated at Boise, Idaho, this ;".r day of March 2004.
Technical Staff: Michael Fuss
Patricia Harms
~:::t.
Hammond(yJY Attorney General
umisc/prod req/splwO4. I 2nd prod req
SECOND PRODUCTION REQUEST TO
SPIRIT LAKE EAST WATER COMPANY MARCH 12 2004
Case No. SPL-04-
2001 Water Hook Ups
Installations:
Invoice #Date Lot #
440 6/6/2001 SLE 275
423 1/29/2001 SLE 285
412 12/11/2000 TP 1-
105 9/4/2001 TP 3-
108 9/4/2001 SLE 134
107 9/4/2001 SLE 223
8/17/2001 SLE 221
Total Installation Costs for 2001 per Invoices
Total Number of Installs per Invoices::::-
Amount
578
280
190 invoice dated 2000 although paid in 2001
320
685
685
320
058
"';ftpawtffi;_'f-.~\~~'lli1ir~O/"i!S'!!1i1:1'.1 1tI:;"';;t 111 ffl "W""Ck,, ci1!WA1J;I
~ .
&~."~~\~~i11i6'J~~~ill,~E~ " 1"
~~"'"
Plus Non-Installation Costs:
Cost of Locates:
Invoice #Date Amount
125 0/2/2001
124 1 0/2/2001
102 9/4/2001
103 9/4/2001
104 9/4/2001 275
Cost of Main Valve Replacement (Invoice #109 Dated 9/4/2001)624
Cost to Repair Damage to Meter (Invoice #110 Dated 9/4/2001)
Customer Payment to Repair Damage to Meter
500
500
Cost to Repair Roadway - Amount was Deducted from Prior Contractor
(Invoice #93 dated 8/17/2001)
Total of Contractor Invoices
Supplies: Pump
Wrench
Company Annual Report Amount for
Materials & Supplies - Operation and Maintenance
370
327
370
730
Attachment
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF MARCH 2004
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO SPIRIT LAKE EAST WATER COMPANY, IN CASE
NO. SPL-04-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
ROBERT 1. BOYLE
SPIRIT LAKE EAST WATER CO.
15807 E INDIANA AVE
SPOKANE VALLEY W A 99216
\C~
CERTIFICATE OF SERVICE