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HomeMy WebLinkAbout20080124Comments.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 IDAHO BAR NO. 1895 t"T.., ; ii..t Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 . Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ) BRIAN WATER CORPORATION FOR ) AUTHORITY TO INCREASE ITS RATES. ) ) ) ) ) CASE NO. BRN-W-07-1 COMMENTS OF THE COMMISSION STAFF COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its Attorney of record, Scott Woodbury, Deputy Attorney General, and in response to the Notice of Application and Notice of Modified Procedure issued on September 19,2007, submits the following comments. BACKGROUND On September 10,2007, Brian Water Corporation (Brian Water, Company) fied a one- page Applicatíon with the Idaho Public Utilties Commission (Commission) requesting an increase in its rates. The Company did not request an effective date for its proposed new rates. Brian Water Corporation was issued Certificate No. 260 in August 1965 by Commission Order No. 7884. The Company has 46 residential customers in Brian Park Subdivision located in Ada County, Idaho, a few miles east of Boise along old State Highway 21. The last rate case from the Company was fied in 1998, Case No. BRN-W-98-1. In that case, the Commission STAFF COMMENTS 1 JANUARY 24,2008 authorized a rate increase of 31 %, effective May 1, 1999. The curent rates are $10.50 per month for the first four thousand gallons and $1.08 for each thousand gallons thereafter. The average water use for Brian Water customers for 2006 was about 13,250 gallons per month. At curent rates, this would result in an average monthly water bil of $20.49. Brian Water states that a rate increase is needed to recover repair expenses, meter replacements and power costs. The requested increase would change the monthly rates from $10.50 per month to $15.00 per month with no increase in the commodity rate of$1.08 per thousand-gallon. The proposed rates would result in an increase of$4.50 per month to $24.99. AUDIT Staff examined the records of Brian Water for the calendar years ended 2005, 2006 and 2007. This examination included, but was not limited to, the check register, invoices, accounts receivable, property records and tax retus. The audit included an examination and analysis of the anual reports fied with the Commission, prior rate cases, orders and conversations with Mr. Tony Bowar, the sole stockholder and only employee of Brian Water. The audit of financial records was conducted at the Commission's office. Staff also conducted a meter reading test on October 11, 2007. The purposes of this test were to: (1) observe meter reading procedures; (2) use the test results to verify the accuracy of customer bilings and of accounts receivable; and (3) verify the existence of, and to observe the use of, various items of equipment listed as property in anual regulatory reports. Brian Water does not maintain conventional jourals and ledgers. Property records were not available and were reconstructed by Staff. Moreover, some invoices and other documents were not available or not provided. Mr. Bowar performs administrative and operations duties. His administrative duties include various accounting fuctions, as well as billng and collections. REVENUE REQUIREMENT Staff found that the Company's records were at times incomplete, and, in the case of property records for Plant-in-Service, unavailable. Staff was required to reconstruct property and depreciation records from prior audit results and purchase records. Finding the Company's records for 2006 to be substantially complete, Staff used 2006 as the test year for the Company's STAFF COMMENTS 2 JANUARY 24, 2008 rate case. The recommended revenue requirement using the 2006 test year is $14,277 as discussed below. Revenues Brian Water receives revenues solely from water sales to its residential customers. All customers are in Brian Subdivision. In 2006, fort-six customers were served through individual meters. Brian Water reported a steady decrease in metered water sales between 2000 and 2006. In 2000, metered sales of 9, 150,000 gallons were biled to forty-seven customers. This is an average anual use of 194,681 gallons. In 2006, metered sales were reported as 7,311,860 gallons to 46 customers; an average use of 158,953 gallons per customer. This is an 18.3% decrease in average use from 2000 to 2006. Additionally, reported sales for July, the peak month of use, decreased 44.3% during the same period. F or the test year 2006, reported sales of 7,311,860 gallons resulted in total reported revenues of $11 ,558. Reported revenues were based upon meter reading calculations. The timing of readings resulted in two errors: (1) including December 2005 sales and (2) excluding December 2006 sales. Staff adjustments for these two items totaled $95, increasing 2006 revenues to $11,653 as shown on Attachments C and C.1. Revenues and accounts receivable figures begin with meter readings. Curently calculations are done using vintage software. The calculations, format and aging of accounts receivable balances are insufficient in several aspects: (1) Customer payments are often detailed on a list cited on deposit slips. These lists are not retained. Consequently, individual account balances canot be verified. (2) Bils are not calculated on a one month intervaL. (3) Balances are not aged based on the fifteen day interval in Commission rules for curent balances. (Tariff Biling 6.3) Expenses Brian Water is currently facing a trio of adverse financial circumstaces: (1) declining metered sales; (2) a rate schedule based upon nearly decade old costs; and (3) the expenses of maintaining an aging water system. STAFF COMMENTS 3 JANUARY 24,2008 The Company reported total expenses of$12,388 for the test year 2006. Attchment C lists the reported expenses and Staffs adjustments. Staff recommends anual expenses of $11 ,442 for this rate case. Adjustments to Annual Expenses The records of Brian Water are maintained by Mr. Tony Bowar. In Order No. 22880 dated December 12, 1989, the Commission commented on the condition of records and Mr. Bowar's lack of accounting knowledge, particularly with respect to depreciation. Mr. Bowar freely admits this lack of knowledge. However, Mr. Bowar stated that he feels unable to afford professional accounting assistace. Staff recommends the following adjustments based on its audit and review. The following adjustments, including known and measurable changes, are recommended by Staff, decreasing total expenses by $946 from $12,388 to $11,442 as shown on Attachment C. Purchased Power: Water Testing: Contracted Services - Other: Depreciation: Property Taxes: DEQ Fees: Income Taxes: Interest Expense Increase $95 Increase $228 Increase $33 Decrease $357 Decrease $7 Increase $230 Decrease $30 Decrease $1,138 Purchased Power Reported expenses for purchased power were reported in the test year 2006 as they were paid. This resulted În an understatement of power costs for the test year. Staff examined power bils and constructed an allocation of power use to determine actual power use for the test year as shown on Attachment Co2. This resulted in an increase of $95 in Purchased Power Expense. STAFF COMMENTS 4 JANUARY 24, 2008 Water Testing Water testing expenses were adjusted to reflect the anualized expense of the required testing protocol as shown on Attachment C.3. Under this protocol, various water tests are performed at scheduled intervals ranging from monthly to once every nine years. In the test year 2006, Brian Water did not pay expenses equal to the anualized portions of some tests which occur in years other than the test year. Accordingly, test year expenses were adjusted to reflect this portion of expenses. In addition, during Januar 2008, two water tests for nitrates were accelerated from anually to quarerly. This more frequent testing and the related expense will be required for at least one year. Water testing expenses were increased by $228 per year to reflect all changes. Contracted Services - Other Casual record keeping practices and lack of accounting controls resulted in uneported or misreported items in regulatory filings. Staff identified two expense transactions that were not accounted for properly. These two transactions totaling $33 as shown on Attchment C.4 should have been recorded in this category of expense. Staff made this adjustment. Depreciation Expense Reported depreciation expense is overstated because of a combination of factors. Mr. Bowar acknowledges his lack of expertise in depreciation methodology, as stated above. This overstatement resulted from a combination of several factors including: (1) depreciating equipment over longer than the depreciable life; (2) lack of property records; and (3) failure to amortize Contributions-In-Aid-of-Construction. Total adjustments to depreciation expense for the test year included parial year depreciation on 2006 additions. Attchment C.5 shows the anualized depreciation of $1 ,256, a reduction of $357, recommended for rate setting. Property Taxes Staff contacted the Ada County Assessors Offce to verify reported property taes for 2006. Propert taxes as shown on Attchment C.6 were found to be overstated by $7. Staff made a $7 reduction to reflect actual expense for the 2006 test year. STAFF COMMENTS 5 JANUARY 24, 2008 DEQ Fees Brian Water reported no expenses for Department of Environmental Quality (DEQ) fees for the test year 2006. Staff contacted DEQ to determine the correct fees. DEQ fees for Brian Water Corporation are $5 per connection. Brian Water serves forty-six metered customers. This would result in fees of$230 as shown on Attachment C.7. Staff made an adjustment of$230 to increase reported expenses. Income Taxes Income taxes are reflected in the gross up on Attachment A rather than as an operating expense. Staff removed reported income tax expense of $30. Interest Expense Brian Water reported interest expense of $988 plus additional interest of $150, totaling $1,138. The loans were made to Mr. Bowar, the stockholder, and are available for mixed business and personal use. As discussed below, Staff has treated these fuds as capital contributions, increasing equity. Consequently, the interest is not reflected as an expense of the corporation. Staff reduced interest expense by $1,138. Rate Base In its rate case request, Brian Water did not provide specific rate base details. In the BRN- W-98-1 rate case, a rate base of $7,863 was used. In this rate case, Staff recommends a rate base of$18,558 as shown on Attachment B. This amount consists of$59,358 for plant in service (Attachment B.1), which includes additions for 2005 and 2006, Accumulated Depreciation of ($24,288), and Unamortized CIAC of ($16,512). Capital Structure and Rate of Return Until 2005, the capital structure of Brian Water consisted of common stock and retained earings. In 2005, the stockholder began using a personal loan to provide capital infusions. These capital infusions were used to pay for additional plant-in-service, repairs and some expenses. The capital infusion is a personal line of credit that will be treated as a capital contribution in this case since there are mixed uses possible for the line of credit. Interest STAFF COMMENTS 6 JANUARY 24,2008 expense on the line of credit will be paid by Mr. Bowar from the equity retur granted in this case. Brian Water did not specify a requested rate of retur. Staff recommends a retu on equity of 12.0%. In several recent water company rate cases, the Commission has used this rate of retur (Falls Water Co. in Case Nos. FLS-W-05-01 and FLS-W-07-01, Order Nos. 30027 and 30484; Capitol Water Co. in Case No. CAP-W-06-01, Order No. 30198; and Mornng View Water Co. in Case No. MNV-W-06-01, Order No. 30420). RATE DESIGN The rate design analysis was based on an anual revenue requirement for the Company of $14,277 and forty-six (46) customers on the water system with an average usage of about 15,000 gallons per month. The Company proposes to raise its current minimum charge of$1O.50 per month to $15.00 per month, or an increase of 43%. The Company is not requesting an increase in the commodity charge of $1.08 per 1000 gallons. Nor is the Company requesting any change in the 4,000-gallon allowance included in the minimum charge. Company's Current and Proposed Rates and the Impact on a Customer's Average Monthly Bil Average Usage is 14,613 Gallons per month Current Rates $10.50 Minimum + $1.08/1000 over 4000 = Average Monthly Bil of$21.96 Company Proposed Rates $15.00 Minimum + $1.08/1000 over 4000 = Average Monthly Bil of $26.44 Staff believes the Company's proposal to increase the minimum charge without increasing the commodity charge is not in keeping with the Commission's historical approach to designing rates for small water companies. First, it sends no conservation signal to customers and secondly, it does not allow customers who consistently practice good water conservation the opportity to impact their monthly bilL. Consumption data over the past six years shows a gradual decline of approximately 25% from 2002 through 2006. Staff canot explain the reason for the decline; however, in 2007 STAFF COMMENTS 7 JANUARY 24, 2008 consumption increased 10% over that in 2006. In 2007, consumption was 8,066,320 gallons and more closely approximated the seven-year average anual usage of 8,338,881 gallons. Therefore, Staff recommends using the 2007 consumption rate in the calculation of the revenue requirement because it is more representative of normal usage. Curently, the minimum charge accounts for 48% of the revenue for the Company and the commodity charge accounts for 52% of the total revenue generated. Staff sees no reason to change the relationship of the customer charge and the commodity charge. Therefore, Staff proposes that the minimum charge be increased to $12.75 per month with no change to the 4,000-gallon allowance and increase the commodity rate to $1.29 per 1000 gallons of usage over the allowance. This relationship is maintained with the Staff proposed rates: Ratio Between Minimum Charge and Commodity Charge Current Rates Usage Commodity Charge Minimum Charge Number of Customers 5,858,320 Gallons Per Year $1.08 Per 1000 Gallons $10.50 Per Month 46 Staff Proposed Rates Usage Commodity Charge Minimum Charge Number of Customers 5,858,320 Gallons Per Year $1.26 Per 1000 Gallons $12.50 Per Month 46 Current Rates Usage x Rate 1 1000 = Minimum x # Customers x 12 months Total $6,326.99 $5,796.00 $12,122.99 52% 48% 100% Staff Proposed Rates Usage x Rate 1 1000 = Minimum x # Customers x 12 months Total $7,377.00 $6,900.00 $14,277.00 52% 48% 100% STAFF COMMENTS 8 JANUARY 24, 2008 METER READING AND BILLING The Company curently reads its meters and bils its customers every other month. The bil is comprised of the minimum charge for two months added to the accumulated consumption over the two months less the 8000 gallons allowed and computed at the rate of$1.08 per 1000 gallons. If monthly cash flow is a problem, and it has been suggested that may be the case, then Staff recommends that the Company read the meters and bil its customer every month. It has been reported that the time necessary to read meters and bil customers requires less than three hours. UNACCOUNTED FOR WATER The Company has two wells, the large well produces approximately 160 gpm and the smaller well produces approximately 110 gpm. The pumps are not equipped with a flow meter and consequently the exact amount of water pumped into the system is not being measured, therefore the amount of unaccounted for water canot be calculated. Knowing this would allow the Company to determine if there are any major leaks in the system, or if the old meters are not recording all the usage. Based on an analysis of energy use and the pump cures, Staff estimates lost and unaccounted for water for the system is high. Possible reasons for this include defective meters and water leaks. Master Meter As noted during our on site visit, well output is not curently metered. Staff recommends placing a master meter at the pump outlets on both wells. This is estimated to cost about $1,200 for the primary well. Comparisons of the production volume from the master meter at the well, with metered sales would reveal differences between gallons pumped and gallons biled. This would provide an accurate measure of the Company's lost and unaccounted for water. Individual Meters Curently, replacing individual meters is a decision based on Mr. Bowar's subjective assessment of water use. Staff recommends a program of meter testing and replacement beginning in 2008. This program would involve systematic testing and replacement when STAFF COMMENTS 9 JANUARY 24,2008 necessar of individual meters. The estimated cost of testing replacement meters would be about $2500. In some cases, additional costs might be incurred for specific replacements due to unique circumstaces requiring use of a backhoe, etc. CUSTOMER RELATIONS Rule 101 of the Commission's Utilty Customer Information Rules (UCIR) requires the Company to provide notice to customers of the proposed rate increase and to publish a press release for public information. The documents provided to the Commission do not meet the requirements of the rule. The customer notice did not include information on how to contact the Commission for filing comments. It also did not include the amount of increase expressed as a percentage of current rates as required. Although the Company provided a copy of a letter about the proposed rate increase addressed to the Idaho Statesman, it did not actually send the letter nor has a press release been sent to the local media as required by Rule 101. While there is concern regarding the Company's failure to comply with Commission's requirements, the Commission has since published its own press release and held a workshop to provide information to the public. The Commission has received no written comments from customers regarding this rate case and no customers attended the workshop, which could be due to lack of proper notification from the Company. Rule 101 of the UCIR also requires the Company to provide a written explanation of its rate schedule to each new customer and all existing customers on an anual basis. Curently, the Company does not provide a wrtten explanation to any of its customers. Staff recommends that the Company distribute its Explanation of Rates to all customers on an anual basis and maintain copies to distribute to new customers. Staff is willng to assist the Company in developing the required information. Rule 701 of the Commission's Utilty Customer Relations Rules (UCRR) requires the Company to provide a summar of the Commission's Rules and Regulations when it signs up new customers and provide all customers a copy on an anual basis. Curently, the Company does not provide the Summar of Rules to any of its customers although the Commission's Records indicate that the Company did so at one time. Staf recommends that the Company create and distribute a Summar of Rules as required by Rule 701. Staff is willng to assist the STAFF COMMENTS 10 JANUARY 24, 2008 Company in preparing a Summar of Rules. Staff notes that the Explanation of Rates can be combined with the Sumar of Rules if the Company wishes to do so. Rules 201 and Rule 305 of the UCRR list the information required on bils and past due notices mailed to customers. The Company's bils and notices do not meet the requirements of those Rules. Examples of missing information include the itemization of charges on bils, due date of the bils, and Commission contact information on notices. Staff recommends the Company update all documentation to comply with Commission requirements and is willng to offer its assistance to the Company. The records at the Commission reveal that the section of the Company's tariff addressing the General Rules and Regulations dates back to 1989 and is not in compliance with the Commission's curent Rules and Regulations. Staff recommends that the Company update this section of the taiff and is wiling to offer its assistance. Copies of the Company's bils provided to the Commission indicate that the Company is not following its approved tariff specifying that it wil bil customers monthly. Bil copies indicate that the Company often bils for two-month periods or longer. This practice also decreases customers' abilty to properly budget their finances. Staff recommends that the Company begin monthly biling in accordance with its tarff. The Company states that it had no complaints from customers for the past three years, and the Consumer Staff has not received any informal complaints and only one inquiry for this time period. This canot be constred as an indication of customer satisfaction levels because the customers have not been provided with the Summar of Rules, the Company's Explanation of Rates, or Commission contact information in recent years as required under the UCIR and UCRR. STAFF RECOMMENDS: 1. A 2006 test year. 2. A 12% return on equity. 3. Monthly bilings as the Company's tarff requires. 4. A new computer program be obtained or the current program be reprogrammed to calculate monthly bilings and accounts receivable. STAFF COMMENTS 11 JANUARY 24,2008 5 Contributions in Aid of Constrction (CIAC) be reduced by the 2005 and 2006 amortization. CIAC is a reduction to rate base. 6. A rate base of $18,558. 7. An anual revenue requirement of $14,277. This is an increase of $2,624 over test year revenues and results in an average rate increase of 22.5%. 8. A monthly minimum charge of$12.50, which includes 4,000 gallons of water plus a commodity charge of $1.26 per thousand gallons. 9. That tariffs be updated to satisfy the Commission's rules. 10. That bils and notices be revised to comply with the Commission's rules. 11. That an Explanation of Rates and Summary of Rules be distributed to new customers at the time of sign-up and to existing customers on an anual basis as required by Commission rules. 12. Installation of a master meter on the Company's primar and backup wells. 13. A program of testing and replacement of individual meters. Respectfully submitted this c9Lf t:y of Januar 2008. Scott Woodbur Deputy Attorney General Technical Staff: John Nobbs Dan Graves Chrs Hecht i:/umisc/comments/bmw07.lswjncwhdg STAFF COMMENTS 12 JANUARY 24, 2008 Brian Water Co. Revenue Requirement Calculation CYE 2006 Return on Rate base Tax Gross Up multiplier Annual Operating Expenses Incl Depr Total Revenue Required Less: Current Revenue Increase Needed % Increase Tax Calculation Beginning State Taxes at 7.6% = Federal Taxable Federal Taxes at 15.0% = Total Multiplier: Net to Gross Attachment A $2,227 Attachment B 1.273 $2,835 11,442 Attachment C 14,277 11,653 2,624 22.5% 100.00% -7.60% 92.40% -13.86% 78.54% 127.32% Attachment A Case No. BRN-W-07-1 Staff Comments 01/24/08 Brian Water Co. Rate Base and Rate of Return Calculation CYE 2006 Plant in Svc Working Capital Accum Depr Unamortized CIAC Rate Base BRN-W-98-1 Changes 31-Dec-97 $45,432 $1,165 ($15,770) ($16,972) $13,855 $13,926 ($1,165) ($8,518) $460 $5,868 Attachment B BRN-W-07-1 31-Dec-06 $59,358 $0 ($24,288) ($16,512) $18,558 Rate of Return = 12%$2,226.96 Attchment B Case No. BRN-W-07-1 Staff Comments 01124/08 Br i a n W a t e r C o . At t a c h m e n t B . 1 An a l y s i s o f U t i l t y P l a n t i n S e r v i c e CY 1 9 9 7 t h r u 2 0 0 7 46 M e t e r s Or g la n d St r & I m p We l l s Re s e r v Pu m p g Ma i n s Me t e r s Of f c e Sh p E q p t To t a l Ba I 1 2 - 3 1 - 9 7 52 4 . 0 0 1 , 5 0 0 . 0 0 3 , 2 5 1 . 3 4 2 , 7 6 0 . 5 9 9 0 0 . 0 0 11 , 5 8 2 . 4 5 18 , 8 3 6 . 4 4 4, 6 9 8 . 2 1 1, 1 8 6 . 0 0 19 2 . 8 9 45 , 4 3 1 . 9 2 19 9 8 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 19 9 9 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 20 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 16 7 . 9 9 0. 0 0 16 7 . 9 9 20 0 1 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 20 0 2 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 20 0 3 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 20 0 4 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 Ad d i t i o n s 20 0 5 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 4, 1 7 8 . 6 2 6, 3 7 9 . 5 4 0. 0 0 0. 0 0 0. 0 0 10 , 5 5 8 . 1 6 Re m o v e d 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 (1 , 0 2 6 . 0 0 ) 0. 0 0 0. 0 0 0. 0 0 0. 0 0 (1 , 0 2 6 . 0 0 ) Ad d i t i o n s 20 0 6 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 4, 3 8 3 . 9 9 0. 0 0 11 8 . 2 3 0. 0 0 0. 0 0 4, 5 0 2 . 2 2 Re m o v e d 0. 0 0 0. 0 0 0. 0 0 0. 0 0 0. 0 0 (2 7 5 . 8 5 ) 0. 0 0 0. 0 0 0. 0 0 0. 0 0 (2 7 5 . 8 5 ) Ba l a t 1 2 - 3 1 - 2 0 0 6 52 4 . 0 0 1 , 5 0 0 . 0 0 3 , 2 5 1 . 3 4 2 , 7 6 0 . 5 9 9 0 0 . 0 0 18 , 8 4 3 . 2 1 25 , 2 1 5 . 9 8 4, 8 1 6 . 4 4 1 , 3 5 3 . 9 9 19 2 . 8 9 59 , 3 5 8 . 4 4 oc : n ; ¡ ~ S - ~ ~ ~: : ( 1 ~ -- n z i : ~ 0 0 S 3' ( 1 3 o : a (1 : : o : :: z . li ~ ; - ,o-.,- Brian Water Co. Schedule of Audit Adjustments CYE 2006 CY Ended Revenues Unmetered Metered Sales-Res. Total Revenues Operating Expenses Labor-O&M Labor- A&G Pensions & Benefits Purchased Power Mat & Suppl - O&M Mat & Suppl - A&G Contr Svs-Profess Contr Svs-Watr Testg Contr Svs-Other Bad Debts Expense Miscellaneous Depreciation Regulatory Fees Propert Taxes DEQ fees Other Fees Income Taxes Interest Expense Total Expenses Net Income 2006 Reported Audit Adjs o 11,558 11,558 3,100 2,920 o 1,173 114 948 183 324 414 o 214 1,613 50 167 o o 30 $1,138 $12,388 ($830) o o o 95 o o o 228 33 o o (357) o ($7) 230 o (30) ($1,138) ($946) $1,041 Attachment C Total o 95 95 o 11,653 Attachment C.1 11,653 o o 3,100 2,920 o 1,268 Attachment C.2 114 948 183 552 Attachment C.3 447 Attachment C.4 o 214 1,256 Attachment C.5 50 160 Attachment C.6 230 Attachment C.7 o o Reflected in Gross-up o Reflected in Equity as contributed capital $11,442 $211 Attachment C Case No. BRN-W-07-1 Staff Comments 01124/08 BRIAN WATER CORPORATION Analysis of Revenue adjustments CYE 2006 Reported Revenues - 2006 Sales - Dec 05 to Feb 06 Reading Dec 05 Sales Sales - Feb to Apr 2006 Reading Sales - Apr Jun 2006 Reading Sales - Jun to Jul 2006 Reading Sales - Jul to Sep 2006 Reading Sales - Sep to Dec 2006 Reading Sales - Dec 06 to Feb 07 Reading Jan 2007 sales Total 2006 Sales Difference 1,219.00 (609.00) 1,133.00 1,979.00 2,203.00 2,967.00 2,056.00 1,410.00 (705.00) Attachment C.1 $11,558 $11,653 / $95 Attachment C.1 Case No. BRN-W-07-1 Staff Comments 01/24/08 At t a c h m e n t C . 2 Br i a n W a t e r C o . An a l y s i s o f A n n u a l P o w e r C o s t CY E 2 0 0 6 20 0 6 Ch a r g e s 0. 0 0 31 . 2 5 36 . 9 2 36 . 3 5 50 . 7 5 14 5 . 4 0 15 9 . 2 6 18 2 . 8 4 18 6 . 9 6 14 7 . 9 5 12 8 . 9 0 71 . 4 8 83 . 4 9 6. 1 5 $1 , 2 6 7 . 7 0 20 0 6 2 0 0 6 Da y s S v c K w H o 26 32 30 29 32 29 30 31 30 30 33 30 3 36 5 To t a l Ch a r g e s 39 . 0 9 36 . 0 6 36 . 9 2 36 . 3 5 50 . 7 5 14 5 . 4 0 15 9 . 2 6 18 2 . 8 4 18 6 . 9 6 14 7 . 9 5 12 8 . 9 0 71 . 4 8 83 . 4 9 65 . 6 2 . $1 , 3 7 1 To t a l T o t a l Be g D a t e E n d D a t e D u e D a t e D a y s S v c K w H 28 - N o v - 0 5 2 8 - D e c - 0 5 1 8 - J a n - 0 6 3 0 4 9 4 28 - D e c - 0 8 2 7 - J a n - 0 6 1 5 - F e b - 0 6 3 0 4 5 2 27 - J a n - 0 6 2 8 - F e b - 0 6 1 7 - M a r - 0 6 3 2 4 6 4 28 - F e b - 0 6 3 0 - M a r - 0 6 1 8 - A p r - 0 6 3 0 4 5 6 30 - M a r - 0 6 2 8 ~ A p r - 0 6 1 7 - M a y - 0 6 2 9 6 5 5 28 - A p r ~ 0 6 3 0 - M a y - 0 6 1 6 - J u n - 0 6 3 2 1 9 6 3 30 - M a y - 0 6 2 8 - J u n - 0 6 1 8 - J u l - 0 6 2 9 2 6 4 8 28 - J u n - 0 6 2 8 - J u l - 0 6 1 6 - A u g - 0 6 3 0 3 5 2 9 28 - J u l - 0 6 2 8 - A u g - 0 6 1 5 - S e p - 0 6 3 1 3 6 8 8 28 - A u g - 0 6 2 7 - S e p ~ 0 6 1 6 - 0 c t - 0 6 3 0 2 7 9 0 27 - S e p - 0 6 2 7 - O c t - 0 6 1 6 - N o v - 0 6 3 0 2 0 2 9 27 - O c t - 0 6 2 9 - N o v - 0 6 1 8 - D e c - 0 6 3 3 1 0 2 2 29 - N o v - 0 6 2 9 - D e c - 0 6 1 9 - J a n - 0 7 3 0 1 2 2 9 29 - D e c - 0 6 3 0 - J a n - 0 7 1 6 - F e b - 0 7 3 2 9 2 1 To t a l s 4 2 8 2 2 , 3 4 0 o 39 2 46 4 45 6 65 5 19 6 3 26 4 8 35 2 9 36 8 8 27 9 0 20 2 9 10 2 2 12 2 9 86 20 , 9 5 1 No t e 1 : e x c l u d e s l a t e c h a r g e o f $ 0 . 3 9 f o r p r e v i o u s b i l l . OC / n ~ ~ S " ~ ~ N: : ( l ~ :! n z e - ~ 0 0 S ~ ~ g (l : i ñ :: z . .. , N '" ~ io-.,- Brian Water Corp. Analysis of Minimum WaterTesting Expenses Attachment C.3 2008 PWS # 104010017 Test Type Frequency Testslyr Costlest Annual Cost Well #1 - Primary Nitrate Quarterly 4.00 16.00 $64.00 Arsenic & Sodium Every 3 yrs 0.33 31.00 $10.23 Cyanide Every 3 yrs 0.33 29.00 $9.57 Flouride Every 3 yrs 0.33 18.50 $6.11 IOCs Every 3 yrs 0.33 147.00 $48.51 Radium 226 & 228 Every 3 yrs 0.33 150.00 $49.50 SOCs Group Every 3 yrs 0.33 181.50 $59.90 VOC Every 3 yrs 0.33 187.00 $61.71 Gross Alpha Every 6 yrs 0.17 50.00 $8.50 Uranium Every 6 yrs 0.17 10.00 $1.70 Nitrite 9 yrs 0.12 14.50 $1.74 Well #2 - Backup Nitrate Quarterly 4.00 16.00 $64.00 Nitrite Every 9 yrs 0.12 14.50 $1.74 VOCS Group Every 9 yrs 0.12 187.00 $22.44 Distribution System Coliform Bacteria Monthly 12.00 11.00 $132.00 Lead and Copper Every 3 yrs 0.33 31.00 $10.23 .Average Annual Cost 551.87 Reported Testing Costs 324.00 Difference $227.87 Brian Water Corp. was moved from annual to quarterly testing for nitrates in Jan 2008; this testing protocol will continue for at least one year. Sources Brandon Lowder at DEQ Wally Baker at Bur of Labs Attachment C.3 Case No. BRN-W-07-1 Staff Comments 01/24/08 BRIAN WATER CORPORATION Analysis of Contracted Services-Other CYE 2006 Attachment C.4 Reported Expense 2006 Ck# 1978 1999 Cash $414 $ 28 414 5 $447 $33 2006 Payee 6-Jun Visa 12-Nov Mr. Rooter 11-Dec Air Valve Total Difference Attchment C.4 Case No. BRN-W-07-1 Staff Comments 01/24/08 BRIAN WATER CORPORATION Attachment C.5 Schedule of Depreciation Adjustments as of December 31, 2006 Reported Deprection Expense: Sub#Name 2000 2001 2002 2003 2004 2005 2006 Total 304 Str& Imp 48.77 48.77 48.77 48.77 48.77 48.77 48.77 341.39 305 Resvr 0 0 0 0 0 0 0 0 307 Wells 41.41 41.41 41.41 41.41 41.41 41.41 41.41 289.87 311 PwrPump 555.94 555.94 555.94 555.94 555.94 773.15 983.58 4,536.43 331 Mains 188.36 188.36 188.36 188.36 188.36 258.75 258.75 1,459.30 334 Meters 140.94 140.94 140.94 140.94 140.94 140.94 144.49 990.13 340 Off F&E 132.42 132.42 132.42 132.42 132.42 132.42 132.42 926.94 343 Shop 3.86 3.86 3.86 3.86 3.86 3.86 3.86 27.02 Totals 1,111.70 1,111.70 1,111.70 1,111.70 1,111.70 1,399.30 1,613.28 8,571.08 Actual Depreciation Expense Sub#Name 304 Str& Imp 48.77 48.77 48.77 48.77 48.77 48.77 48.77 341.39 305 Resvr 0 0 0 0 0 0 0 0 307 Wells 41.41 41.41 41.41 41.41 41.41 41.41 41.41 289.87 311 PwrPump 555.94 555.94 555.94 555.94 555.94 612.31 601.79 4,036.47 331 Mains 188.36 188.36 188.36 188.36 188.36 274.71 322.55 1,539.06 334 Meters 140.94 140.94 140.94 140.94 140.94 140.94 142.72 986.58 340 Off F&E 132.42 132.42 132.42 132.42 132.42 132.42 132.42 937.24 343 Shop 3.86 3.86 3.86 3.86 3.86 3.86 1.77 27.02 Totals 1,111.70 1,111.70 1,111.70 1,111.70 1,111.70 1,254.42 1,291.43 8,157.63 2006 depreciation from schedule above $1,291.43 Add: to Annualize 2006 Pumping additions - 11 months $192.94 Add to Annualize 2006 Meter Additions - 6 months $1.77 2006 CIAC Amortization (229.93) Total annualized Depreciation Expense $1,256.21 Difference $357.07 Attachment C.5 Case No. BRN-W-07-1 Staff Comments 01/24/08 Brian Water Co. Analysis of Property Tax Expenses CYE 2006 Attachment C.6 2006 Ada propTx - 3" equivalent pipeline miles 1sthalfYr 80.21 2nd haW Yr 8021 Annual Total 160.42 Reported Difference 167.00 (6,58) Attachment C.6 Case No. BRN-W-07-1 Staff Comments 01/24/08 BRIAN WATER CORPORATION Schedule of DEQ Fees ,CYE 2006 Attachment C.7 DEQ Fees - Per connection Number meters Total annual Fees $5.00 46 $230.00 Attachment C.7 Case No. BRN-W-07-1 Staff Comments 01/24/08 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF JANUARY 2008, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. BRN-W-07-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: TONY BOWAR BRIAN WATER CORPORATION 5120 OVERLAND RD, SUITE C #228 BOISE ID 83705 ~~- SECRETA CERTIFICATE OF SERVICE