20220330Staff 1-30 to Teton Water.pdf

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RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
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Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
TETON WATER & SEWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES AIID
CHARGES FOR WATER SERVICE IN THE
STATE OF IDAIIO.
CASE NO. TTS-W-22-02
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO TETON WATER AND
SEWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its affomey of record,
Riley Newton, Deputy Attorney General, requests that Teton Water and Sewer Company
("Company") provide the following documents and information as soon as possible, but no later
than WEDNESDAY, APRIL 20,2022.
This Production Request is to be considered as 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO TETON WATER AND SEWER
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I MARCH 30,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide a copy of the Company's most recent property tax
bill
REQUEST NO. 2: Please provide a copy of all power bills for the years 2019 through
2021
REQUEST NO.3: Please provide a schedule showing the number of customers that pay
their bills on-line. Please break out those customers by rate class. Please provide a list of fees
and charges related to those online payments.
REQUEST NO. 4: Please provide a copy of the Merchant Account contract
REQUEST NO. 5: Please provide a list of the inventory the Company had on hand on
December 31,2021. Please include the cost of each inventory item.
REQUEST NO. 6: Please provide the Company's most recent Sanitary Survey. Please
list the costs and frequency for each water test.
REQUEST NO. 7: Please provide a copy of the contract with Teton Management
Services. Please ensure that this response includes the services provided to the Company and the
charges for those services.
REQUEST NO.8: Please provide a copy of the invoice from H20 Pro Diagnostics
posted on February 4,2021, and explain the services provided for Teton Water and Sewer
Company.
REQUEST NO. 9: Please provide a copy of the Company's most recent insurance
contract and bill.
FIRST PRODUCTION REQUEST
TO TETON WATER AND SEWER 2 MARCH 30,2022
REQUEST NO. 10: Please explain what is posted in the Merchant Deposit Fees account
and the 720.610 Unallocated - Bank Fees account. Please explain how they are different.
REQUEST NO. 11: Please provide copies of invoices for April, July, and October of
2021for AT&T.
REQUEST NO. 12: Please explain the services that Silverstar Communications
provides the Company. Please provide copies of invoices for April, July, and October of 2021
REQUEST NO. 13: Please provide a schedule showing each new connection for 2019
through 2022to date. Please include the amount charged for each connection and the costs
associated for each connection.
REQUEST NO. 14: Please provide the method the Company uses to allocate expenses
between the water and the sewer companies.
REQUEST NO. 15: After Well No. 3 and No. 4 are built, please describe the
Company's access extemal financial resources needed to fund investment in the system (e.g. for
potential emergencies or leaks).
REQUEST NO. 16: Please provide the documents for the loan used to finance the
construction of the well showing all terms including interest rates and payback period.
REQUEST NO. 17: Please provide explanations and supporting documentation for the
following known changes included in Exhibit No. 2, Schedule B:
a. Purchased Power & Fuel for Power: an increase of $1,000
b. Materials & Supplies-Operations and Maintenance: a decrease of $69,074
c. Contract Services-Other: an increase of $9,068
REQUEST NO. 18: Please provide a schedule showing all the expenses the Company
has incurred for this rate case and an estimate of the expenses the Company will incur.
FIRST PRODUCTION REQUEST
TO TETON WATER AND SEWER aJ MARCH 30,2022
REQUEST NO. 19: Please provide the number of commercial customers connected to
the system, and provide the following for each:
a. Currently billed meter size;
b. Number of billings per calendar year; and
c. Location of the customer within the water system.
REQUEST NO. 20: Please provide a list of all property that the Company leases to
others and all property that the Company leases from others. Please provide copies of all lease
contracts.
REQUEST NO. 21: For each month from January 2019 to December 2021, please
provide the number of billed customers for each meter size.
REQUEST NO. 22: Please provide monthly consumption data for each metered
customer from January 2020 through the most recent billing period. Please speciff the unit of
measure (e.g., gallons, CCF) and meter read logs (if available).
REQUEST NO. 23: Please explain why the Company offers pro-rated water fees. How
did the Company calculate the rate(s)?
REQUEST NO. 24: Please explain why the Company offers a monthly billing option?
REQUEST NO. 25: Please provide a list of customers that use water on a seasonal basis
or only have usage during three billing cycles or less in a calendar year.
REQUEST NO.26: Please provide the following information about irrigation
customers
a. How was the water rate determined?
b. What is being inigated?
c. Where are the inigation customers located?
FIRST PRODUCTION REQUEST
TO TETON WATER AND SEWER 4 MARCH 30,2022
d. What is the connection size?
e. Do the customers have other water service connections? If so, please identiff.
REQUEST NO. 27: Does the Company still provide water to Quick Water Ranch? If
so, please provide the owners rutmes and monthly consumption for the years 2019,2020, and
2021.
REQUEST NO. 28: Does the Company expect to continue providing water services to
Quick Water Ranch in2022 and beyond? If so, please provide the expected water consumption
of Quick WaterRanch for2022.
REQUEST NO. 29: With Quick Water Ranch not within the Company's Certificate of
Public Convenience and Necessity ("CPCN") No. 510, why does the Company provide water
services to Quick Water Ranch?
REQUEST NO.30: Please provide the legal property description of Quick Water
Ranch.
DATED at Boise,Idaho, this 30rH day of March2022.
Riley N
Deputy Attorney General
i:umisc:prodreqlttstw22.2rnjt prod req I
FIRST PRODUCTION REQUEST
TO TETON WATER AND SEWER 5 MARCH 30,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 3OTH DAY OF MARCH 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIM
COMMISSION STAFF TO TETON WATER AND SEWER COMPAI\IY, IN CASE
NO. TTS.W.22-02, BY E- MAILING A COPY THEREOF, TO THE FOLLOWING:
JON PINARDI
TETON WATER & SEWER CO
PO BOX 786
DRIGGS TD 83422
E-MAIL: [e-mail]
Tetonws@silverstar. com
CERTIFICATE OF SERVICE