20130603Staff 34-44 to SPL.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 14
ISB NO. 6864
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
sPIRrr LAKE EAST WATER COMPANY FOR ) CASE NO. SPL-W-13-01
AUTHORITY TO INCREASE ITS RATES AND )
CHARGES FOR WATER SERVICE IN THE ) THIRD PRODUCTION
STATE OF IDAHO. ) REQUEST OF THE
) COMMISSION STAFF
) TO SPrRrr LAKE EAST
) WATER COMPANY
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Spirit Lake East Water Company (Company;
Spirit Lake) provide the following documents and information on or before MONDAY,
JUNE 24,2013.
This Production Request is to be considered as continuing, and Spirit Lake East Water
Company 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.
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 hearing.
THIRD PRODUCTION REQUEST 1
TO SPIRIT LAKE EAST
JUNE 3,2013
REQUEST NO. 34: In reference to your response to Staff Production Request
(SPR) No. 5, please provide the following:
a) Copy of price quotations from vendors concerning reservoir cleaning.
b) Copy of the completed O & M Manual for the Spirit Lake Water System.
REQUEST NO. 35: In reference to your response to SPR No. 6 you stated that
there have been no water system issues or violations identified by IDEQ since the
completion of the Sanitary Survey in August 2011. Have you recently conducted any
pressure measurement at critical location(s) of your distribution system? If the answer is
yes, please provide us any pressure data collected.
REQUEST NO. 36: In reference to your response to SPR No. 7, the complaint list
did not show any complaint on low water pressure in 2010, 201I and 2012 with the
exception of a customer complaint logged by the Company on 5126112. Were there
additional customer complaints brought to the Company about low system pressure during
the period from January 1,2013 to date? If there are any, please list these complaints and
provide explanation on how they were resolved.
REQUEST NO. 37: In reference to your responses to SPR Nos. 9 and 10, please
provide the following:
a)
b)
THIRD PRODUCTION REQUEST
TO SPIzuT LAKE EAST
An electronic copy of all Excel files in executable format used in calculating
customer usage and excess usage for the years 2010 , 20lI and 2012.
In the same tables accompanying your response, please explain the meaning
of various notations in Status Column (i.e. Gal/needs Replaced, Needs
Replaced-Remo, etc.).
REQUEST NO.38: Preliminary review of the data submitted in your response to
SPR Nos. 9 and l0 show that there appears to be an increasing trend in customer water
usage and excess usage (gallons per customer) using annual data points in 2010, 2011 and
2012. Please provide similar customer usage and excess usage data for 2009.
JUNE 3,2013
REQUEST NO. 39: If the Company has completed meter readings in April 2013,
please provide the customer usage and excess usage data during the winter period from
October 2012to March 2013 (6-month period).
REQUEST NO. 40: In reference to your response to SPR No. 11, please provide
an estimate of the volume (or percent) of water "wasted" during annual flushing activities
in 2010, 201I and 2012.
REQUEST NO. 41: In reference to your response to SPR No. 14, please explain
why testing for Nitrite was not included in your water quality testing list. Staff understands
that DEQ requires Spirit Lake to test also for this contaminant (one test every nine years -
see Sanitary Survey completed by DEQ in 2011).
REQUEST NO. 42: In reference to your response to SPR No. 18, please provide
the following:
a) An electronic copy of Excel file (spreadsheet) in performing the
calculations.
b) Please confirm if the customer usage data in Column I of the table is the
total volume used during the 9-month period for a specific customer.
c) If your response to Request No. 42b above is yes, please provide similar
data during the same 9-month period from a prior year (2011) for each of
the same customers.
d) Please confirm if Column 2 of the table is what you consider as the total
volume of leaks being experienced by the specific customer. Column 2
appears to be the excess usage data. Please explain.
e) Please state if the leaks occurring on the customers' side of the meter as
reported have been fixed to date.
REQUEST NO. 43: Please provide the annual purchased power cost and the
corresponding annual volume of water pumped for approximately the same time frame (i.e.
October to September of the following year) for 2012,2011,2010,2009 and 2008.
THIRD PRODUCTION REQUEST
TO SPIRIT LAKE EAST
JUNE 3,2013
REQUEST NO. 44: In reference to the Billing Worksheets for Test Year and
Future Cost of Monthly Billings, please respond to the following:
a)Explain the discrepancies between the cost of meter reading of $3.00 per
meter for the Test Year (Attachment to Application) and the $4.00 per meter
cost as specified in the contract between the Company and Water Works,
Inc. (Estimate No. 141, Company Response to SPR No. 2l).
Explain why the cost of meter reading decreases from $3.00 per meter for
the Test Year to $2.00 per meter reading for the proposed monthly billing.
Please attach any supporting calculations.
Explain what the cost item - Bill Creation Administration entails.
In reference to the Bill Creation Administration labor, please explain why
there is more time (6 hours) spent per billing for the Test Year (quarterly
billing) compared to lesser time (4 hours) spent per billing for the proposed
monthly billing. Please attach any supporting calculations.
In reference to the cost item - Forms, please explain why the cost per Form
per customer is considerably higher for the Test Year ($0.51 per form)
compared to $0.09 per form for the proposed monthly billing. Please attach
any supporting calculations.
b)
c)
d)
e)
DATED at Boise, Idaho, thkVd, day of June 2013.
Technical Staff: Gerry Galinato
umisc:prodreq/splwl3. lnpgdg prod req3
THIRD PRODUCTION REQUEST
TO SPIRIT LAKE EAST
Deputy Attorney General
JUNE 3,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RO DAY oF JUNE 2013, SERVED
THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION
STAFF TO SPIRIT LAKE EAST WATER COMPANY, IN CASE NO. SPL-W-13-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LESLIE ABRAMS
OWNER/OPERATOR
SPIRIT LAKE EAST WATER
PO BOX 3388
COEUR D'ALENE ID 83816
CERTIFICATE OF SERVICE