20160727Reply Comments.pdf

RE,OEIVED
?'x16 JuL ?1 Pl{ 2: 05
2626 Eldorado Boise,ldaho 93704
Telephone 375{931
Jnly 26,2016
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83702-0074
RE: CASE NO. CAP-W-I6-01
IN THE MAITER OF THE APPLICATION
OF CAPITOL WATER CORP. TO
CHANGE IT'S SCHEDULE NO. 3
PURCHASED POWER COST ADJUSTMENT RATE
Dear Ms. Jewell:
Enclosed are an original and seven copies of applicants reply to the Commission Staff
comments in this case.
Robert Price, President
Capitol Water Corporation
\
Robert Price, President
Capitol Water Corp.
2626Eldorado
Boise, Idaho 83704
Ph: [phone]
Fax: [phone]
E-mail: [e-mail]
Representative for Capitol Water Corp.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF THE APPLTCATION ) CASE NO. CAP-W-16-01
oF CAPTTOL WATER CORP. TO )
CHANGE ITS SCHEDULE NO.3 ) REPLY COMMENTS
PURCHASED POWER ADJUSTMENT RATE) TO PUC STAFF COMMENTS
COMES NOW Capitol Water Corporation ("Capitol",'oApplicant" or
"Company"), holder of Certificate of Convenience and Necessity Number 239, and files
these comments in response to the Commission Staff (Staff) Comments in this case.
PPCA CALCULATION
Staff in this case argues that the Company's annual electricity use has declined since the
Purchased Power Adjustment Rate was first approved by the Commission in 2009.
Initially, by Order No. 30881 in Case No. CAP-W-08-02, the Commission adopted
Staff s recommended use of a three year average of 1,454,401 KWh per year rather than
a single years' actual use. In this case, Staffnow proposes the use ofa single years'
actual use as more appropriate. Staff is reversing its earlier recommendations to the
Commission.
Staff at page 4 of its comments acknowledges "...that the lower energy
consumption is due to efficiency improvements related to well maintenance and cleaning
completed in early 2015 and recent equipment upgrades." Staff does not, in its
comments, acknowledge the additional costs the Company has incurred to realize these
efficiency improvements. Staff is proposing to change one component of the
Commissions approved purchased power cost adjustment methodology ignoring any
REPLY COMMENTS
CAP-W-16-01
other effect on the Company's costs that would affect other components of the
Company's rate structure.
Capitol Water is currently working on, and intends to file before year-end, a
general rate case application to update the Company's overall rate structure. Applicant
proposes the Commission maintain the status quo of the previously approved "Purchased
Power Adjustment" methodology and approve the Company's application as filed in this
case. The Company will cooperate with Staff to refine and update that methodology
during the course of the rate case investigation.
CUSTOMER RELATIONS
Staff in its Comments pointed out what it considers to be inadequate language in
the Company's Tariff Sheet, Billing Statements, Customer Notice and News Release.
The language in these documents are consistent with similar documents in prior cases
that have been modified on occasion to meet the Staff s recommendations. Applicant
assumed the documents were prepared in compliance with those prior recommendations.
Applicant will, in the future, submit such proposed documents to the Staff prior to
filing an application.
CONTACT INFORMATION:
Questions regarding these Comments should be addressed to:
Robert Price, President
Capitol Water Corp.
2626Eldorado
Boise,Idaho 83704
Ph: [phone]
e-mail [e-mail]
Robert E. Smith
2209 N. Bryson Rd.
Boise,Idaho 83713
Ph: (208) 761-9s01
e-mail uti [e-mail]
Please provide copies of all correspondence, notices and orders to the above individuals.
Robert Price, President
Capitol Water Corporation
REPLY COMMENTS
CAP-W-16-01