20191217Staff 1-6 to Teton Water.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BARNO. 10655
Street Address for Express Mail:
1I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI.A
BOISE, ID 83714
Attomey fbr the Commission StaIT
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
TETON WATER & SEWER COMPANY FOR
AUTHORITY TO ACCESS THE COMPANY'S
EMERGENCY RESERVE ACCOUNT
cAsE NO. TTS-W-19-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
TETON WATER AND SEWER
COMPANY
The Staffof the Idaho Public Utilities Commission requests that Teton Water and Sewer
Company (Teton Water; Company) provide the following documents and information as soon as
possible, by TUESDAY, DECEMBER 31,2019.r
This Production Request is continuing, and the 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.
Please provide ans\rr'ers to each question, supporting workpapers that provide detail or are
the source of inlbrmation used in calculations. 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 ofthe record holder
FIRST PRODUCTION REQUEST
1'O TETON WAI'ER AND SEWER
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DECEMBER 17,2019
RECEIVED
0l3DEC i7 pH t:02
l: l r:ii ;a: r r' '-rr i-tlf,,i,1i.$slolJ
I Staff is requesting an expedited response- lfthis is problematic, please contact Staffs attomey at [phone]
or [e-mail]
I
and if diftbrent the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with tbrmulas activated.
REQUEST NO.2: On the bank statement and on the Quick Books printout, therc is a
withdrawal of $ 10,000 from the emergency reserve fund account on July I , 2019 and a payment
of $ 10,000 was made on October 2, 2019. Given the nature of this account, please explain the
reasons for thcse transactions.
REQUEST NO.3: How does the Company plan to frurd the repair olleaks or other
water system emergencies that may arise while the reserve fund is depleted? Please explain.
REQUEST NO. 4: Does the Company anticipate that the pump, motor, transformer and
othe( spare parts will be compatible with proposed Well No. 3?
a. Ilso, would the Company consider using these to equip Well No. 3 when it comes
on-line? Please explain.
b. Ifnot, please explain why not.
REQUEST NO. 5: If Welt No. I were to experience a pump, motor, or transformer
malfunction during Calendar Year 2020, how many hours does the Company believe it would
take to restore water system operation? Please explain.
FIRST PRODUCTION REQTJEST
TO TETON WATER AND SEWER ).DE,CEMBER 17.2019
REQUEST NO. l: Does Teton Water have an affordable and reliable source of funding
for regular investment expenditures?
a. If so, please list the sources and costs for those sources of funding the Company has
for regular investment expenditures.
b. Ifnot, please identify how capital investments are funded.
REQUEST NO. 6: Please provide copies of any correspondence that the Company has
had with the Idaho Department of Environmental Quality regarding its plan to maintain spare
parts for Well No. I .
ilDated at Boise, Idaho, this l7 dav of December 201 9.
Hunter
Deputy Attomey General
i/utility/umisc/production rcquestvtlswl9. I mhjk prod req I
FIRST PRODUCTION REQUES'T
TO TETON WATER AND SEWER 3 DECEMBER 17,2019
CERTIFICATE OF SERVTCE
I HEREBY CERTIFY THAT I HAVE 'I'HIS 17TH DAY O}' DECEMBER 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO TETON WATER AND SEWER COMPANY, IN CASE
NO. TTS-W-Ig-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLI,OWING:
JON PINARDI
TETON WATER & SEWER CO
PO BOX 786
DRIGGS ID 83422
.L,4a^.
SECRETARY '
CERTIFICATE OF SERVICE