20160518Comments.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF DIAMOND BAR
ESTATES WATER COMPANY'S
APPLICATION FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO.
i(TCEIVED
?il16 ileY I I AH ll : 32
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. DIA.W.15.O1
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Daphne Huang, Deputy Attomey General, and submits the following
comments.
BACKGROUND
On December 28, 2015, Diamond Bar Estates Water Company (Diamond Bar) filed a
general rate case Application to increase its rates and charges for water service, effective February
1 , 2016. On January 13 , 2076, the Commission issued a Notice of Application and Notice of
Modified Procedure, and suspended the requested effective date until July 1 ,2016. Order No.
33452.
In its Application, the Company proposes to increase its rates by 79.39%, which if
approved, would produce about $20,910 more in annual revenue than the prior year. Application
at 1. Diamond Bar notes that it has not had a rate increase since October 2007, when the
STAFF COMMENTS MAY 18,20t6
Commission issued Order No. 30455. Id. The Company also proposes to increase its new
customer meter installation fee from $310 to $475. Id. With its Application, the Company
submitted proposed notices to be sent with customer bills, and to be published in local
newspapers. Id. at 3; Exh. 5.
Diamond Bar proposes raising the monthly minimum rate from $29.00 for the first 5,500
gallons of water to $52.02 per month, and raising the commodity rate for usage above 5,500
gallons per month from $0.80 per 1,000 gallons (above the initial 5,500 gallons) to $1.44 per
1,000 gallons. Proposed Amended Tariff. The Company proposes arate base of $40,398,
reflecting accumulated depreciation of 912,669, but also including a working capital allowance
of 54,679 - or 1i8th of the Company's operation and maintenance expenses. Id. at 1-2; Exh. 1.
According to Diamond Bar, the Company has been operating at a loss, and the proposed
increases, if approved, would enable it to recover various expenses. Application at2. The largest
expense that Diamond Bar seeks to recover is for costs incurred from multiple pump failures
during 2015. Id. The Company also asks to recover costs of "bookkeeping and customer-service
related services," and recovery for expenses from "water testing, meter reading, pump service and
on-call duties." Id.;Exh.2. In addition, the Company seeks to recover rate case expenses for this
filing, and the cost of electricity to run its pumps. /d.
STAFF ANALYSIS
System Description
Diamond Bar provides water service to approximately 44 customers in the Diamond Bar
Estate Subdivision and the Boekel Estates Subdivision in Kootenai County, Idaho, near Rathdrum.
Most customers maintain lots of approximately five acres. Average annual water use per customer
typically exceeds 300,000 gallons; however, there is significant variation in usage among
customers. Water is sourced from two wells in the vicinity.
Diamond Bar was granted a Certificate of Public Convenience to serve the Diamond Bar
Estates subdivision on May 30, 2003 (Case No. GNR-W-02-03, Order No.29247). The
authorized service territory was expanded to include the Boekel Estates Subdivision on August 2,
2004 (Case No. DIA-W-04-01, Order No. 29556).
STAFF COMMENTS MAY 18,2016
Staff Audit
Staff s audit found that the Company generally maintains good records. Diamond Bar uses
a hybrid between cash and accrual accounting. Plant in service and accounts payable are reported
on an accrual basis, while the revenues are recorded on a cash basis. Internal controls were
generally adequate with month-end reconciliations available for review. However, Staff found
that several expenses and capital projects were misclassified. Also, there were neither operating
nor capital budgets in use at the time of the audit. The Company's bookkeeper, Mrs. Cristy
Turnipseed, stated that she has little to no training in regulatory accounting standards.
Staff notes that this was not the Company's first Staff audit. In this case, the Company
hired a consultant to assist with the rate case. Generally the consultant's workpapers and process
were not available for review, and questions to the consultant were not answered in a timely
fashion if at all.
The Company requested a test year ending December 31,2014, with pro forma
adjustments. Staff made adjustments and updated the results. Attachment A shows a summary of
the adjustments Staff recommends for this case. The Staff-adjusted results show a net loss of
$6,932 and a rate base of $32,945.
Adjustment I - Plant in Service
The Application stated that plant in service at fiscal year ending December 31, 2014 was
$48,388 with accumulated depreciation totaling $72,669, resulting in a net plant in service of
$35,719 with a depreciation expense of $1,881. These number are based on the 2074 anrrual
report submitted on November 5,2014. The Company stated this was created by their consultant.
Staff requested backup documentation, but was unable to reconcile the plant in service with any of
the backup documentation. Staff asked the consultant to reconcile the annual report plant in
service with the backup documentation provided, but has not received a response. Staff therefore
created a new plant in service listing from the previous rate case and the results of this audit.
Staff recommends using the plant in service at December 31, 2015. The items are known
and measurable, as well as used and useful. This also results in a more accurate rate base and
revenue requirement.
In Case No. DIA-W-07-01, Order No. 30455, the Commission set plant in service at
$ 15,449. The plant in service consisted of a well pump and software program placed in service in
2002, fencing around the well house and reservoir, flow meters, and hydrant locks placed in
STAFF COMMENTS MAY t8,2016
service in 2006. Of the plant items in the last case, the only remaining items still in the plant in
service rate base are the fencing and the flow meters. The hydrant locks are also in service, but
have been fully depreciated.
Since the last rate case, the Company made significant investments in this water system.
[n2007, the Company installed new gate valves. In 2010, the Company installed a new delay
timer, as well as new water check valves. In 201 1, the Company replaced one of the booster
pumps. In20I2, the Company replaced another booster pump. In20l4, the Company installed a
sub monitor and lightning arrestor for the well pump, plus additional grounding wire. In 2015, the
Company replaced the well pump and installed a transformer pad with improved wiring to the
pump house, as well as an additional lightning arrestor and emergency bypass. The Company has
replaced the main well pump repeatedly - in 2010, 2012,2014, and twice in 2015 - which will be
discussed in more detail under the deferral and amortization of pump replacement costs. Staff
reviewed the invoices and conducted an onsite inspection to verify that these items are all
currently in place. Staff recommends plant in service totals of $39,670. See Attachment B.
In Attachment B, Staff set depreciation lives for all the new assets. These depreciation
lives are within the bounds set by the NARUC guidelines. Staff used the half year convention for
the first year of operation for each asset to calculate accumulated depreciation of $ 10,177 and
depreciation expense of $ I ,891 . Depreciation for the flow meters reflects only half a year of the
remaining life and depreciation. As shown in Column 1 of Attachment A, Staff recommends a
decrease of $2,492 for accumulated depreciation, a decrease of $8,718 in plant in service, and an
increase of$10 in depreciation expense.
Revenue
Staff reviewed the procedure for producing bills, receiving payments and posting the
payments to the proper account. Staff found no material deficiencies in controls. The Company
reported that there are almost no uncollectable accounts, and the audit confirmed this.
Adjustment 2 - Remove Bar Circle S Water Revenue
In the test year, the Company posted a rebate from Kootenai Electric Coop totaling $642 to
other revenue. This was improper for two reasons. First, the rebate should be posted as a
reduction to power expense rather than revenue. Second, the rebate was made to Bar Circle S
STAFF COMMENTS MAY 18,2076
Water, and thus should not have been included in the results for Diamond Bar. Staff recommends
removing this from revenues. With this adjustment, Staff recommends revenue of $25,696.
Expenses
Staff reviewed the Company's process for receiving and paying invoices. Staff found that
controls were adequate to prevent any material errors in payment. At times, the Company lacked
adequate knowledge to post expenses to the proper account leading to some misclassifications.
Adjustment No. 3 - Reclassify Expenses
Staff found three misclassifications of expenses, only one of which impacts the revenue
requirement. First, the Company misclassihed expenses totaling $9,431, related to the water
system operator, as Contract Services - Water Testing. Staff recommends this be reclassified as
Labor Operations & Maintenance. This results in no change to revenue requirement.
Second, the Company misclassified the natural gas expense for heating the well house,
totaling $405, as Purchased Power & Fuel for Power. Staff recommends reclassifying this as
Miscellaneous Expenses. This also does not change revenue requirement.
Finally, the Company misclassified the pro forma adjustment for the pump repairs, totaling
$5,750, as Materials & Supplies - Operations & Maintenance. The Company is requesting a
deferral and recovery of the costs. It therefore should be removed from operating expenses and
booked as a separate regulatory asset to be amortized. This reclassification removes the pump
repair costs from working capital, thus lowering working capital by $719, and revenue
requirement by $110.
Adjustment No. 4 - Deferral and Amortization of Pump Replacement Costs
The Company has experienced a series of pump failures starting in20l2. The pump
replacement in 2010 appeared to be a normal failure. However, the pump failed and had to be
replaced againin20l2,20l4, and twice in20l5. Initially the Company believed the pump failure
was caused by a lightning strike, and insurance covered a significant portion of the replacement
cost ($9,500 of $12,089). When the pump failed in2014, the Company installed additional
grounding wire and a lightning arrestor in an effort to prevent additional failures. Insurance again
covered part ofthese expenses ($4,171 of$14,171).
STAFF COMMENTS MAY 18,2016
When the pump failed in June 2015, the Company did not file an insurance claim. The
Company retained AEI Engineering Incorporated to find the cause of the failures. AEI prepared a
report indicating that the primary cause appeared to be erratic power from the electric company,
and made five recommendations to prevent future failures.
First, AEI recommended improving the grounding wires. The Company improved the
grounding wires h2014. Second, AEI recommended installing an additional surge protection
device, which Diamond Bar also did. Third, AEI recommended upgrading the transformer.
Kootenai Electric Coop provided a transformer for which Diamond Bar built a pad. The
transformer's pad and wire, which the Company provided, was included in rate base, but the cost
of the transformer, provided by Kootenai Electric, was not. AEI's fourth recommendation was, if
the transformer could not be upgraded, to replace the fuse disconnect. Because the transformer
was upgraded, this was not necessary. Finally, AEI recommended installing a solid state soft
starter. This has not been completed, but Staff recommends the Company do so as soon as it is
feasible. See Attachment C (AEI Engineering Report). The improvements appear to have
resolved the problem, as there have been no pump failures since the recommended improvements
were made.
Pump replacements have been a drain on the Company's resources. The Company claimed
it spent $23,000 in 2015 to keep the system running, and asks to recover those expenses over four
years. Staff investigation found that these expenses were associated with replacing the pump
twice in 2015. Staff does not believe the requested amortization and recovery reflect proper
accounting. Staff recommends instead that the unrecovered investment of the previous pumps be
placed in a deferral account to be amortized and recovered over the average remaining life of those
pumps.
Under normal accounting treatment upon the early retirement of an asset, the remaining
book value would be written off as'an extraordinary loss and would not be recoverable in rates.
Staffls proposed treatment recognizes the unique circumstances that required multiple replacement
and books the undepreciated book balance in a regulatory account to be amortized over the
remainder of the depreciable life of the asset. The Commission has allowed similar treatment in
some instances. See Case No. PAC-I2-08.
The initial cost of the four replaced pumps was $51,444, with $13,671 paid by the
insurance company, thus reducing the deferral amount. In addition, Staff found no evidence that it
was prudent for the Company to avoid filing an insurance claim after the first 2015 pump failure.
STAFF COMMENTS MAY t8,2016
Therefore, Staff recommends an additional reduction of $3,764 for the amount Diamond Bar's
insurance policy would have covered had the Company filed a claim. In addition the accumulated
depreciation of $2,751 for those pumps should be a reduction to the deferral amount. This results
in a total remaining deferral amount of $31,258.
The average remaining life of the pumps is 18 years as shown on Attachment D. Staff
therefore recommends an amortization period of 18 years. This results in an amortization expense
of $1,737 with a reduction of $4,013 from the Company's Application. See Attachment D.
Adjustment No. 5 - Rate Case Amortization
The Company requests that the costs associated with the rate case be amortized over four
years for recovery. They estimated these costs to be $4,418. Actual costs as provided by the
Company to date were $4,761. These costs include consultant fees for $2,200, postage of $111,
administrative work of $ 1,700, and water system operator work of $750.
Staff agrees that reasonable costs associated with the rate case should be recovered. The
Company has filed two rate cases since becoming regulated and the time between those rate cases
was four and eight years, respectively. Staff recommends that the amortization period for the rate
case expense be the average ofthe years between rate cases or six years.
In reviewing the invoices from the consultant, Staff found that $200 of those costs was
related to preparingthe2015 annual report. This expense, which was included under Contract
Services - Professional, is not associated with the rate case, and should thus be removed.
Although the consultant failed to provide proper documentation and responses to Staff s questions,
Staff does not believe this lack of cooperation necessarily warrants denial of the expenses paid to
the consultant.
The Company also claims 85 hours of work on the case by an administrative staffer, and
30 hours of work on this case by the water system operator. Staff finds that the hours worked and
the rates assigned to that work are acceptable. Staff recommends approving costs for this rate case
of $4,561, amortized over six years. The resulting rate case amortization expense is $794, or a
reduction of $31 I to the Company's proposed revenue requirement. See Attachment E.
Adjustment No, 6 - Salary Expense
The Company requests recovery of $9,431 as salary for the water system operator. In
Order No. 30455, the Commission authorized $6,968 for the water system operator. Using the
STAFF COMMENTS MAY 18,2016
Bureau of Labor Statistics from 2006 and 2015, Staff found that wages for Water and Wastewater
Treatment Plant and System Operators in the Coeur d'Alene area increased by an average of
22.98%. Staff recommends that the salary for the water system operator be increased by the same
percentage with $8,668 approved for recovery, thus reducing Diamond Bar's proposal by $763.
See Attachment F.
The Company requests recovery of $7,325 in salary for the bookkeeper. In Order No.
30455, the Commission authorized $3,600 for the bookkeeper. Using the Bureau of Labor
Statistics from 2006 and 2015, Staff found that wages for Bookkeeping, Accounting, and Auditing
Clerks in the Coeur d'Alene area increased by an average of 28,86%. Staff recommends that the
salary for the bookkeeper be increased by that same percentage, with $4,700 approved for
recovery, thus reducing Diamond Bar's proposal by $2,625. See Attachment G.
Staff recommends a total of $3,388 in salary reductions. This impacts the working capital
calculation, reducing rate base by $424. Thus the total revenue requirement reduction is $3,462.
Adjustment No. 7 - ll/ater Testing Expense
The Company proposed a water testing expense of $300. Different testing cycles for
various regulated water contaminants are required by the Idaho Department of Environmental
Quality (IDEQ); hence, it is common practice and necessary to normalize water testing costs over
several years. In consultation with IDEQ, Staff developed a complete list of required tests, with a
water testing cycle of nine years. Attachment H shows the required water quality tests for water
contaminants and the annualizedwater testing costs of $547. Staff recommends increasing the test
year water testing cost by $247 to reflect normalized levels.
Adjustment No. I - Purchased Power Expenses
The Company proposed purchase power and fuel expenses of $9,990. Of this, $405 was
related to natural gas use at the pump house, which was addressed separately in Adjustment 3.
The remainder of the request for purchase power and fuel is $9,585. The request includes an
adjustment of 5479 for what the Company claimed was in increase in Kootenai Electric
Cooperative's electric power rates. Staff recommends that this $479 adjustment be rejected
because the 2014 electric power costs reflect the current electric rates. There has been no increase
in Kootenai Electric Cooperative's electric power rates since test year 2014 bills were issued.
Separately, Staff recommends an adjustment to reduce power costs by an additional $437. This
STAFF COMMENTS MAY 18,20t6
downward adjustment to power costs reflects the removal of personal energy use from the power
cost total. Diamond Bar's owners' personal water use accounted for 4.8Yo of total water pumped
from the wells. Therefore, 4.8Yo of power costs was designated as personal use. The $437
adjustment represents 4.8%o of the adjusted power costs of $9,106 ($9,585 - $479).
The sum of the Staff-recommended $479 downward adjustment for power rates and the
$437 downward adjustment for personal use is a downward adjustment of $916, as reflected in
Attachment L No additional normalization adjustments were necessary for purchased power
expenses. The Company-proposed adjusted purchase power and fuel expenses of $9,585 accounts
for around 25.6% of the Company-proposed operating expenses of $37,434.
Staff adjustments result in total Operating Expenses of $27 ,627, and Total Expenses of
$32,628. The resulting Net Loss is $6,932.
Rate of Return
Staff agrees that the Company is currently completely owner-financed. Consistent with
Commission-authorized return on equity for many small water companies, Staff recommends a
l2%o retum.
Calculation of Revenue Requirement
Staff recommends a total rate base of $32,945, as shown on Attachment J. This is $7,453
less than the Company's proposal. StafPs recommended rate base consists of net plant in service
of$29,493andaworkingcapitalamountof$3,452. Staffcalculatedworkingcapitalbasedon
l/8th of the operating expenses of the Company. This is the same methodology used by the
Company in its Application.
Attachment K shows the Staff-recommended revenue requirement. Staff calculated the
revenues associated with the return on rate base (line 3) to be $3,953 ($32,945 x 12%). This
amount is subject to federal income taxes, state income taxes, and Idaho Public Utilities
Commission (IPUC) fees. The Staff-calculated net loss of 56,932 must be recovered and is also
subject to IPUC fees. The process of increasing the revenue requirement for taxes and IPUC fees
is referred to as the "gross-up." The gross-up factor is 128.0631o/o when the amount is subject to
income taxes and 100.1881% when not subject to income taxes. The process of calculating the
gross-up factors is detailed on Attachment K, Iines l7 to 24. These grossed up amounts result in a
9STAFF COMMENTS MAY 18,2016
total deficiency of $12,008 (line l3), which is $8,902 less than the Company's request. The Staff-
recommended revenue requirement percentage increase is 46.73%.
RATE DESIGN
The Company's current rate structure is a two-part (minimum charge & commodity usage)
charge) structure with: (l) a minimum monthly customer charge of $29.00 per month with a
volume allowance of 5,500 gallons per month; and (2) a single-block commodity charge of $0.80
per 1,000 gallons for consumption in excess of 5,500 gallons. Diamond Bar proposes to increase
the minimum monthly charge to $52.02 per month, and to increase the commodity charge to $1.44
per 1,000 gallons for consumption in excess of 5,500 gallons. The Company proposes to retain
the 5,500 gallon volume allowance. The Company's proposal represents a79.4%o and 80.0%
increase in the minimum monthly charge and the commodity charge, respectively. The slight
difference in the percentage increase is related to rounding. The Company-proposal is
summarized in the following table.
Charge Current Company Proposed o/o Change
Minimum Monthly $29.00 $s2.02 79.4%
Volume Allowance
Gallons/month 5,500 5,500 No Change
Commodity
($/1,000 gallons)$0.80 $l.44 80.0%
Staff believes it is appropriate to maintain the existing two-part, single block rate design
with a minimum-charge volume allowance. Other small water utilities regulated by the
Commission use this rate structure because it is simple, easy to implement, and reasonably cost-
based. Relative to a "flat" rate structure (minimum charge only with no commodity charge), the
proposed two-part rate design provides a better conservation incentive. Under the proposed two-
part rate design, a customer using more water pays a larger monthly bill, assuming that he or she
has usage in excess of the 5,500 gallon monthly allowance.
The Staff proposal substantially maintains the rate structure and is expected to generate the
Staff-proposed revenue requirement. The percentage changes in the Staff-recommended
minimum monthly charge and commodity charge are 41.4o/o and 46.3yo, respectively. While the
STAFF COMMENTS 10 MAY 18,2016
Staff-recommended percentage increases in the charges are similar, the percentage increase in the
commodity charge is slightly higher than the percentage increase in the minimum monthly charge.
The slight difference in these percentages results from rounding the minimum monthly charge to a
whole dollar amount ($41.00). Also, the direct relationship between usage level and percentage
bill increase promotes conservation. By maintaining similar percentage increases in the minimum
monthly charge and the commodity charge, and retaining the current volume allowance, the
percentage increases in bills will be similar across customers and across billing months.
Monthly bill increases will range from 41 .4%oto 45.0oA, and will average around43%o.
Most bill increases will fall between 41/% and 44.0o/o. Given that no customer expressed
dissatisfaction in comments or at the public meeting regarding how costs were distributed among
fellow customers, retention of the current rate structure is appropriate. The Staff proposal is
shown below.
Charge Current Staff Proposed Yo Change
Minimum Monthly $29.00 $41.00 41.4%
Volume Allowance
Gallons/month 5,500 5,500 No Change
Commodity
($/1,000 gallons)$0.80 s1.16 45.jYo
The following table shows the bill-impact by usage level:
t1
Monthly Usage (Gal)Current Bill Bill - Staff Proposal Yo Change
5,500 $29.00 $41.00 4t.4%
10,000 $32.60 $46.22 4l.\Yo
25,000 $44.60 s63.62 42.6%
50,000 $64.60 s92.62 43.4%
100,000 $104.60 sr s0.62 44.0%
150,000 $144.60 $208.62 443%
300,000 $264.60 s382.62 44.6%
STAFF COMMENTS MAY t8,20t6
Attachment L is a proof of revenue calculation. The proof of revenue calculation
demonstrates that when Staff s proposed rates (shown in the table above) are applied to test-year
customer counts and billed gallons, the resulting revenue is consistent with Staff s revenue
requirement recommendation.
Customer Notice and Press Release
The Company filed a proposed Customer Notice along with the Company's Application
for a rate increase on December 28,2015. The notice did not meet requirements in the
Commission's Rules of Procedure, IDAPA 31.01.01. The Company had not sent out the
Customer Notice prior to filing its Application and Staff recommended changes to the notice. The
Company made the necessary changes and sent the revised notice to customers in early January
2016. A copy of the notice was also sent as a press release to the Coeur d'Alene Press, which
published an article on January 13,2016, regarding the proposed rate increase.
In addition, the Commission issued a press release on March 17,2016, regarding the
Commission-sponsored customer workshop. The Coeur d'Alene Press published an article based
on the press release on March 18, 2016. The customer workshop was held April 19,2016,in
Rathdrum and was attended by more than 30 people.
Customer Comments Regarding the Proposed Rate Increase
As of May 18,2016,16 comments regarding the proposed increase in rates have been
submitted. All customer comments oppose the amount of the rate increase. Some customers
suggest that if a rate increase is necessary, it should be spread over a number of years.
The customers note that increases exceed any CPI/COLA allowances in pensions or Social
Security and maintain that the proposed increase in commodity rates for usage above the 5,500
gallons, included in the minimum charge, would affect customers' ability to maintain lawns and
pastures. Many of the concerns are from customers with fixed-incomes, or retired customers who
believe basic living costs are rising without income keeping pace.
The Diamond Bar Homeowner's Association and several customers express concern about
the Company's operations and maintenance costs over the years, as related to previous pump
failures, and whether the Company properly reported changes in plant in service in its annual
reports. Customers also express concern about the outages caused by the pump failures and
continued access to the back-up water source.
STAFF COMMENTS t2 MAY 18,2016
Customer Complaints
There are no customer complaints on record at the Commission for the past three years
(2013,2014 and 2015). In20l6, a customer contacted the Commission to get more information
about filing comments in the current case.
COMPANY TARIFF
The Company's current tariff, including its Rate Schedules and the General Rules and
Regulations for Small Water Utilities, was last updated in2007 at the conclusion of Case No.
DIA-W-07-01. In 2008, Commission Staff developed a Model Tariff, which includes revised
General Rules and Regulations and incorporates the Uniform Main Extension Rule for Water
Utilities based on Order No. 7830 (Case No. U-l500-22).
The Company's most recent Report of Sanitary Survey as released by IDEQ indicates that
the Company initiated a Cross Connection Control Program in 2004.1 In 2013, IDEQ revised the
requirements, but the Company's tariff has yet to be updated to reflect the changes.
Staff recommends that the Company update its tariff. Staff is willing to work directly with
the Company to ensure its tariff complies with the Commission's rules and regulations.
NON.RECURRING CHARGES
New Customer Connection Charge
The New Customer Connection Charge applies to a first-time connection with the
Diamond Bar system when an existing service line and meter base are already in place on the
property. Diamond Bar requests an increase in the New Customer Connection Charge from the
current $310 to $475 per connection. Staff believes the Company's requested $475 charge is too
high, and recommends that it be reduced. Staff estimated the cost of a new connection based on
meter cost, labor cost, and transportation, and recommends a New Customer Connection Charge
of $335. See Attachment M. The charge will have limited applicability because only about twelve
lots remain to be developed in the two subdivisions served.
I According to IDEQ, "a cross-connection is an actual or potential connection or piping arrangement between a
drinking water system and another source that could introduce any,thing other than the potable water intended to
normally supply the system. Cross-connections include bypass arrangements, jumper connections, removable
sections, swivel or changeover devices, and other devices that may cause non-potable water to backflow into the
potable water supply. Backflow occurs when the normal flow direction of the water system is reversed due to back
pressure or back siphonage." IDEQ Drinking Water Cross Connections Control Programs Fact Sheet (FS-0416).
STAFF COMMENTS l3 MAY 18,2016
Reconnection Fee
Staff recommends that the Company revise its Rate Schedule No. 2 to describe the
circumstances under which a customer may be disconnected. Staff is willing to assist the
Company in revising the Rules and Regulations section of its Company tariff to reflect Staff s
recommended changes.
Late Payment Charge
Late payment charges encourage timely payment and allow the Company an opportunity to
recoup some of the cost of collecting unpaid bills. The Company sends out its billing statements
at the beginning of every calendar month, for service provided the previous month. Staff supports
adoption of a late-payment charge to encourage prompt bill-payment. Staff recommends that the
Company be allowed to charge loh on any past-due balance owing at the time of the next billing
statement.
Billing Statements
The Company's meter-reading practice is to read the meters the last Saturday of each
month, except in the winter months. The Company generates the customer billing statements after
meter readings are taken at the end of the previous month, and usually sends the statements around
the first of each month. During the Commission's workshop, a customer raised an issue about the
billing statements. Customers did not know when the meters were read and were unable to
determine the length of the billing period.
Considering the Company's current meter reading schedule, the number of days in a
billing period could vary from 28 days to 35 days. Staff recommends that the Company include
the first and last dates of its meter-reading period on its billing statement, as required by Rule
201.03 of the Utility Customer Relations Rules, IDAPA 31.21.01. The Company has already
agreed to this change.
RECOMMENDATIONS
Staff recommends that the Commission approve the following:
L Using a 2014 test year with plant in service updated to December 3 1, 2015.
2. A 12% return on equity.
3. A rate base of $32,945.
STAFF COMMENTS t4 MAY 18,20T6
4. An annual revenue requirement of $37,704, or 46.73Yo increase.
5. Maintaining a volume allowance of 5,500 gallons for a minimum customer charge.
6. Staff s proposed rate design.
7. A requirement that the Company install a solid state soft start on the main well pump as
soon as feasible.
8. An increase in the new customer connection charge to $335.
9. A late payment fee of lYo of the past due balance at the time of the next billing statement.
10. A requirement that the Company work with Staff to revise its tariff, including rate
schedules and General Rules and Regulations.
1 1. A requirement that the Company revise its billing statements to include first and last dates
of its meter-reading period.
Respectfully submitted this lW day of May 2016.
Technical Staff: Joe Terry
Bentley Erdwurm
Chris Hecht
i:umisc:comments/diaw I 5. I djhjtcwhbe comments
Deputy Attorney General
STAFF COMMENTS l5 MAY 18,2016
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Attachment A
Case No. DIA-W-15-01
Staff Comments
05118/16
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FoF Attachment B
Case No. DIA-W-15-01
StaffComments
05118/16
Diamond Bar Well lnvestigation
Observation Report
September 2015
ffiliix:r*
Electrical and Control Systems Engineplring
Attachment C
Case No. DIA-W-15-01
Staff Comments
05118/16 Page I of53
AEI#w*
tO38 W. oavldson Avenue I Coear d,'l6ne, lD 838f4
,08,666"4001 | fax [phone] I ww.irolngineering.cof,
September 23,2015
Diamond BarWater Co.
PO Box 1870
Hayden lD 83835-0081
Attention: Mr. Bob Turnipseed
Subject DiamondBarWelllnvestigation
Observation Report
Dear Bob.
From our conversations and historical data received, it is our understanding that the well pump
located at Diamond Bar Estates has experienced problems since 2002; having to be replaced
multiple times. Since November 2012,the motor has been replaced three times (Appendix C).
On August 27, 2015 AEI Engineering, lnc. made its initial site visit for the purpose of providing
condition assessment and evaluation of the well house's electrical system serving the well pump.
The scope of this evaluation included analysis of the utility service, surge protection devices,
grounding system and pump motors.
On September 1, 2015 AEI observed the existing 6" pump motor being removed from service
and exchanged with a new 8" 60 HP pump. After being removed, AEI observed the existing
pump motor to have "blueing"; evidence of overheating. See appendix A. This is the fourth time
the motor has been replaced since November 2012.
A complete electrical metering investigation was conducted from September 8,2015 through
September 11,2015. AEl, KEC and United Crown Pump and Drilling were contributors and/or
witnesses of this metering investigation. See appendices D, E and F.
The following summarizes the existing electrical system:
1. The facility is fed by Kootenai Electric Cooperative (KEC). The utility service is comprised
of 3 single phase, 25K/A, 480V, pole mounted transformers in a corner grounded Delta
configuration. The existing electrical service, a fused disconnect, is located inside the well
house and is rated 200A at 480V, 3 phase. The electrical service distance from the utility
transformer is over 200 ft.
2. The fused disconnect distributes three phase 480 volt power to a gutter system. The
gutter system serves (1) 60 HP well pump motor combination starter, (1) 20 HP fire pump
motor combination starter, (2) 3 HP booster pump motor combination starters and (1)
load center via a disconnect and transformer. This gives the site a total motor load of 86
HP. Allmotors have across-the-line starters.
3. The well pump is monitored and protected by a Franklin Electric SubMonitor, a Square D
SDSA3650 surge protection device and Delta Lightning Arrestor.
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page2 of53M1 51 1 2 Exeortive Summary
September 23,2015
4. The grounding system is comprised of grounding electrode conductors, bonds to piping,
a bond to the well case and ground rods.
5. The well pump feeder conductors between the starter and well head were replaced with 2
AWG copper conductors on September 2,2015.
The following electrical issues were observed:
1. The starting voltage dip on the system is approximately 15 percent.
2. The only Surge Protection Device (SPD) unit installed is under sized and located in the
well pump branch circuit which makes it less effective for the service entrance.
3. The current utility transformers are under sized.
a. Per the pump manufacture/s instructions (Appendix B), the 60 HP pump needs a
75kVA transformer. Cunently, the 75kVA transformer at full load can produce 90
amps. When all pumps are running, the service transformer is forced to produce
roughly 115 amps; this loads the transformer to 128% rated load.b. The transformer is in a comer-grounded delta conflguration.
4. The 60 HP well pump has a Full Voltage Non-Reversing (FVNR) or "across-theline
started'.
a. Per the KEC electric service handbook, motors over 20 HP are required to be soft
started (Appendix G).
5. The overall grounding (bonding) system is segmented and uses multiple connections,
conduit, equipment supports to make an interconnected system. This method of bonding
meets the minimum code requirements, however, it does not provide adequate grounding
for transient events as each connection provides a source of substantial voltage
differential during a transient event (lightning or power system disturbance).
6. Per NEC 230.90(8), the existing service equipment is not acceptable for the existing
corner grounded Delta utility service. A breaker must be used to simultaneously open all
phases (Appendix H),
7. The voltage drop from the well pump starter panel to the motor terminals was calculated
to be approximately 11.8 volts (Appendix E). Therefore, when voltage at the starter panel
is measured to be 471.7 volts or less, the motor is not being provided its rated voltage of
460 volts. This is shown in Appendix F.
Recommend actions to improve system protection:
1. Replace all end connectors on grounding system. Due to the sites history of lightning
strikes, replacing all of the end connections of the grounding conductors will give the
electrical system a more solid grounding system. This will provide increased protection
from lighting and faults in the system.
2. lnstall a new SPD to protect the service entrance of the system in addition to the existing
monitoring and protection equipment currently in use. At a minimum, provide the following
sPD: Attachment c
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 3 of53M151 12 Ex€qitive Summry
Page 3
the motor while running.
Several appendix sections have been included for this report:
Appendix A contains site visit pictures.
Appendix B contains well pump manufacturer's instructions (Franklin Electric).
Appendix C contains sequence of events summary logs.
Appendix D contains KEC metering data
Appendix E contains AEI Field Report -918115.
Apoendix F contains AEI metering data.
Appendix G contains KEC's Electrical Service Handbook.
Appendix H contains NEC reference.
We appreciate this opportunity to provide our services to you.
Please do not hesitate to contact me if you have any questions.
Sincerely,
Ryan Litzko, E.l.Parrmnnr{ I \A/a+lzinc p.f,
3.
September 23,2015
a. Service entrance protection (Square D, HWA-8OKA).
Provide a larger 112.5 1(/4, 480V1277, Wye connected service transformer. Preferably, a
pad mount type located next to the building.
lf the service is not upgraded, replace the existing service fused disconnect.
Replace the FVNR across-the-line starter serving the well pump with a solid state soft
starter.
a. The soft starter will not only be less stressful on the electrical system (reduced
inrush current) and pump motor but will also provide a higher levelof protection to
4.
5.
ry/^"*lryb ?%**ry zMt,*,*
OriginalSigned By:
Raymond Joseph Watkins
Dated Original Signed: 9123115
Original Location: AEI Engineering !NC.
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18116 Page 4 of53Ml5112 ExeoJtive Summry
APPENDIX A
Site Visit Pictures - 9l1,lL5
Attachment C
Case No. DIA-W-15-01
StaffComments
05/18116 Page 5 of53
Overheating causes the
"blueing" effect shown here.
Attachment C
Case No. DIA-W-15-01
Staff Comments
05118116 Page 6 of53
Figure 1: Failed 6" well pump motor
APPENDIX B
Well Pump Manufacturer's !nstructions
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 7 of53
Oistribution transformers must be adequately sized to satisfy the kVA requirements of
the submersible motor. Vl/hen transformers are too small to supply the load, there is a
reduction in voltage to lhe motor.
Iable 4 references the motor horsepower rating, singlelhase and three-phase,total
efiective kVA required, and the smallest transformer required for open or dosed
Iable 4 Transformer Capadty
three-phae systems.0pen systems require larger transformers since only two
tansformers are used.
Other loads would add directly to the kVA sizing requhements of the transformer
bank.
kVA ratings are shown. lf
company experience and practice
transformer loading higher than
igher loading values may be
to meet total effective kVA required,
correct voltage and balance is
Eflects ol Iorque
4lsl7s Il0 75
15 l0
20 t5
25 15
l0 20
40 25
50 30
60 35
90
120
150
r75
t00
210
50
65
85
100
115
130
40
50
60
10
15
During starting of a submersible pump, the torque developed by the motor must be
supporled through the pump, delivery pipe or other supports. Most pumps rotate in
the direction which causes unscrewing torque on righthanded threaded pipe or pump
stages.All threadedjoints,pumps and other parls ofthe pump supporl system must
be capable of withstanding the maximum torque repeatedly without loosening or
breaklng. Unscrewing joints will break electrical cable and may cause loss of the
pump-motor unit.
To safely withstand maximum unscrewing torques with a minimum safety factor of 1.5,
tightening all threadedjoints to at leastl0 1tsft per motor horsepower is recommended
(Table 4A),ll may be necessary to tack or strap weld pipe joints on high horsepower
pumps, especially at shallower settings.
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 8 of53
Iable 1A loruue Required (Examples)
APPENDIX G
Sequence of Events Summary Log
Aftachment C
Case No. DIA-W-15-01
StaffComments
05/18/16 Page 9 of53
United Pump Event Summary Log - Page 1 of 1
Diamond Bar Well Pump Service Record
. 812A02 Pulled 6" 50hp (failure unknown) replaced motor & #2flaljacked wire.
- 812004 Pump unscrewed from the pipe. Upgraded from a 50hp motor to a 6" 60hp motor
and a
Berkeley 8T-500 pump.
. 812A11 Phase to ground short on the B phase of the well pump panel. Replaced
breaker and starter.
- 612012 Well pump tripped overload on starter. Metered pump and everything checked out
ok.
- U2A12 The C-Phase of power blew two days in a row at Rob's house. Kootenai Electric
Cooperative replaced the transformer.
. 1112012 Motor was shorted to ground and had open windings. Replaced motor only.
- 812013 Motor was again shorted to ground. Replaced motor only. Sent back to the
factory for inspection. See report.
- 812014 Motor was again shorted to ground. Replaced motor only. Sent back to the
factory for inspection. See report.
- 912014 Discovered a bad neutral lug in the utility meter. KEC to repair. Also installed
Franklin's
Sub-Monitor.
. 612015 C-Phase fuse blown on the transformer. KEC repaired. While waiting for KEC to
show up we metered the well pump and discovered a short. No faults where recorded
on the Sub- Monitor and the reservoir was full. Sent back to the factory for inspection.
See report.
- 612A15 The C-Phase of power had biown a fuse in the punrp house at Robs
- U2A15 Short to ground down hole. Sub-Monitor recorded 4 unbalanced current faults
before shorting out.
Note: the items in RED are from Rob's well site.
Affachment C
Case No. DIA-W-15-01
Staff Comments
05ll8l16 Page l0 of53
KEG Event Summary Log - Page 1 of 2
KooteneiElectric
C O O P E frA I l V T
A Tiruclurnnc Enargy'*nnprnrtive df '
September S, 2015
Mr, RlcfiBrd Agu,erot
United 0rown Purnp and f,rillinB
2125W HsydenAve
Hayden, lD 83835
Re: OutagesAffe*ting Diarnsnd Ear Ettates Well Purnp Service
Dear Mr. Aguorcs"
Thank you ior tha ssrvice reeurd irformaiisn you sent over for the Diarnond Bar Eatat*s well
pump and Rob Turrripseed'$ well pumps. Many of the servic€ daies you provlded do n6t
conelato vJith dny KEC outages- lnfarmauon prior to 2007 on our outags rnflnsg8mBnl sy*tetn
is not ar complote so I udlt limH my eornments sn €ysBm outager affacting ltrosc f#o ssruice$
from 2007 to today.
Wa show the followlng sutagsa lmpactlng both well sitaa:
1l27t2AA? Tree fell aerass por/r,isr llrte tripping *ub*lAtion breater6/17n008 Car hlt pollsr poto tripping subetaliofl hraakrr
Et21lZD12 Lighiing hit power line trlpptng *uhslalion breaker7fiEAl{ Small animalgal into power lkla and stsrtsd pole lir e tripped subata{ion breaker
6130/2015 *ar htl pnuler pate trlpplng subslatisfi breaker
Outagua thst only lrapa*lad ttrr* Elamond Bar Ettafres Wpll SiiE:
8/?3/2014 Surnp truelt with ds bed up hit power lines5/&201S $ohed{jed outage for work on tap to well eite
6/101?015 tsloun Fuse an Traneformar Elank - fla-fused (Purnp Bad)
Outages lmpac$ng on$ Rc! Tsmtp*aod's well ssrvlce:
W1l2O12 Ughting strike HEEfby blaw fuee on trrnsfonner, re-fusedgl22lz112 Replaced tran$forn6r. TranEformar damaged by lightning striteAlA2014 Transrormer hit by *ighling. Transformer replamd514/2015 Schaduhd mahtenarce fcr wort on tap to wellsRe,
AJso. I checked wilh our tachnician regarding wfio performod ths ropaim on tha bad met6r bffi€
nautral lug on 91il2f,!4. H* indirated that ii wsg United Crown's elee{riclan ss meter ba*Ea aie
membar orirnsd agulpffrent snd repalrs lo ihern arg the responsibility of the mrmber,
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/l8l16 Page il of53
'1,1[,\,ti hlf|]inrt,,,. t!;t1t:*;i Lli,lrr,]:)jlt'liil.jl.{i?,i*"1tuil;lli l.lr.l(r l./t-ltyta i!{,ial.}{tl{siL{
KEG Event Summary Log - Page2 of 2
Mr, Rt*srd AguerptPryc2dI
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B6f Ragards,
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$hawn Dokn. P"E"
Mamgnr eil €nggnffiing
Cc: Ftny Wetkine, AIE Engirnanng
Erdwulpx
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 12 of53
APPENDIX D
KEC Metering Data - gl8lL| to glLll 15
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 13 of53
Revolution at Transformer - Page 1 of 2
Attachment C
CaseNo. DIA-W-15-01
staff comments
05118116 Page 14 of53
Revolution at Transformer - Page 2 of 2
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 15 of53
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CaseNo. DIA-W-I5-01
Staff Comments
05/18/16 Page l6 of53
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05118/16 Page l7 of53
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Case No. DIA-W-15-01
staff comments
05/18/16 Page l8 of53
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Case No. DIA-W-15-01
staff comments
05/18/16 Page l9 of53
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05118/16 Page 20 of53
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$10.nV,0-000 Sac". o*r
Vallage Tranaients:
ffill08llBl 5 62:itt):5{. I I Fhase A-F
Artra
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Attachment C
Case No. DIA-W-15-01
staff comments
05/18/16 Page 2l of53
PX5 Recorder - Page 5 of 7
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CURRENT ShrnnolA $h.nnslE
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Median Ampe 65 S.5
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Max Ampe 2S,40S oo 0C/r 1&015 00:50:00
Median turpg 0.377
Average Arnpe 1,079
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page22of53
PX5 Recorder - Page 5 of 7
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05118/16 Page23 of 53
PX5 Recorder-Pagel of7
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page24 of53
APPENDIX E
AEI Field Report -gl8,lts
Attachment C
Case No. DIA-W-15-01
StaffComments
05/18/16 Page25 of 53
AEli#xx*
7O38 W. Oavidson Avenue I Coeur d'Alene, lO 83874
208.6$6.4001 | Fax [phone] I waw.aei4ngiBeilng,.cofi
Field Report
Voltage and current measurements taken are summarized below:
Meters: PX-5 & Metrosonics Vab
(la)
Vbc
(tb)
Vca
(lc)
Measured
Load All Pumps 476
(-)
476
(-)
475
(-)
A voltage drop calculation through the roughly 450 ft, 2 AWG Cu wire from the pump panel to
the pump motor was conducted and resulted in a 11.8 V loss. Combining the voltage drop
calculations with the voltage readings gathered at the well house start up on 918115, the
following can be concluded.
Best case scenario: Measured from Kootenai's Fluke Model 26lll
A. Voltage at panelwhen all pumps are running is 480V
B. Projected voltage at well pump terminals would be 468.2V
Worst case scenario: Measured from PX-S and Metrosonics Recorders
A. Voltage at panelwhen all pumps are running is 475V
B. Projected voltage at well pump terminals would be 463.2V
Both seem to give tolerant voltage levels at the motor terminals.
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18116 Page 26 of 53
PROJECT NUMBER:M15112
PROJECT DESCRIPTION:Diamond Bar Well lnvestigation
ENGINEER:Ryan Litzko, E.l.
DATE OF VISIT:91812015
Meter: Fluke 26lll True RMS Vab
(la)
Vbc
(tb)
Vca
(lc)
Measured
Load
No load 496
(n/al
496
(n/al
494
(n/al
WellPump 485
(7s)
484
(7e)
485
(7sl
All Pumps 480
(772)
480
(116)
481
(717)
All But Well Pump 481
(113)
480
(116)
481
(116)
APPENDIX F
AEI Metering Report - 9/8/15 to 9t11t15
Attachment C
Case No. DIA-W-I5-01
StaffComments
05118116 Page27 of 53
AEI Metering Report: Per Appendix E, AEI Field Report, the voltage drop from the well pump
starter panel to the motor terminals was calculated to be approximately 11.8 volts. Therefore,
when voltage at the starter panel is measured to be 471.7 volts or less, the motor is not being
provided its rated voltage of 460 volts, Sustained voltage sags below the motor's voltage rating
will be indicated in the following pages by a RED rectangle. Note that sustained voltage sagging
occurs on the last day of recording. Other indications will be explained via text box.
Fluke 1735 Power Logger Recorder- Page 1 of 22
51t
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 28 of53
Evcnt Profrc ltto. 22 of 257 9i&€015 2:11:12 Ftt',{ 0reec
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05118/16 Page29 of 53
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05118116 Page 30 of53
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Attachment C
Case No. DIA-W-15-01
StaffComments
05/18/16 Page 31 of53
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05118116 Page 32 of53
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 33 of53
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Case No. DIA-W-15-01
StaffComments
05/18/16 Page 34 of53
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05118/16 Page 35 of53
Fluke 1735 Power Logger Recorder - Page 9 of 22
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Attachment C
Case No. DIA-W-15-01
Staff Comments
O5l18116 Page 36 of53
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Attachment C
Case No. DIA-W-15-01
staff comments
05/18/16 Page 37 of53
Fluke 1735 Power Logger Recorder- Page 11 of 22
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 38 of53
Fluke 1735 Power Logger Recorder- Page 12o122
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 39 of53
Eycrt s.e$a tlo. 183 a,?57 911 1G013 349:"1{ Al{ 3&$trxcc
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 40 of53
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Attachment C
Case No. DIA-W-15-01
Staff Comments
oSflSltO Page 41 of53
Eysot Prolib No. 231 ol 257 911 ll?013 311:01 A& oSArEcc
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page42of53
Esnl hofi No 2X2 al X7 !ll1112015 51?:{6 Al, 656mstc
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05118116 Page 43 of53
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05118/16 Page 44 of 53
fyBni Profdi No, 2d8 ot ?97 9, t/201S &08:45 AX 191ro"c
Fluke 1735 Power Logger Recorder- Page 18 ot22
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 45 of53
Evcnl kofdt No. 249 ot 237 S1112015 e09:01 Ald 191m?c
Fluke 1735 Power Logger Recorder - Page 19 ot 22
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Attachment C
Case No. DIA-W-15-01
StaffComments
05/18/16 Page 46 of 53
Fluke 1735 Power Logger Recorder - Page 20 of 22
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05ll8l16 Page 47 of 53
Fluke 1735 Power Logger Recorder - Page 21 ol 22
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Attachment C
Case No. DIA-W-15-01
staff comments
05/18/16 Page 48 of53
ly8nl Profde No. 2S2 o1297 grl lrrilg &20;0{ Arl 466lec
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Fluke 1735 Power Logger Recorder - Page 22 of 22
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Attachment C
Case No. DIA-W-15-01
Staff Comments
05ll8l16 Page 49 of53
APPENDIX G
KEC Electrical Service Handbook
Afiachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 50 of53
A. lnspection and Gods
Thc mertb*r is rcspnnsible {'tr eomplying rvlth all requirements tor templran und p*rmanent xen'ice equipment.
All of vour elecrrical equipment must comph *'ith the nlost rurrent editir:;r of the National [lertric Code {|,{EC)
and an! $etc or lncat ctrde requiretnents. ldaho ele(trical insper;lors can aftswer anl' NEC cde questions. Call
1.800.95-i.3044 ttlr an ldaho elecrrical insgxction. Statr electrir;al insper:tors are available to ansuer crxle-related
questions fronr 8 a.rl. to 5 p m. [,{onday'thrnugh Fridtr.
A sutc electrical permil ntusl hc obtaine.d to initiate electrical serrice. (Jn h*meorvner-installed sen'rcc equipment.
the serv*irrr equ.rpment and the inslallatinn murt br approved hy tlx stale e lectrical huleau pnor tn t"nerylrzing the
-cervice.
l:rrr furti:er infonnati*n regarding inspecti*n*, permils, cxles :rnd e$semeilt$, c{)fitaet KIIC at :,{i8.?65. t?fiCI.
B. Ternporary Servics
For hnmeor,r.ner irutalled lemp$rary sen,ices, KIiC wilt connect and iil*taJl an electris meter rrnl1, aller inspec,tion
urd approvul hy the slate rlectrical inspertor.
C. lnstalling and Removing Meters
Onlv uutharieed md qualilied KliC prrsr:nnel maf inrtall and remol'e m*ters. \Yith solne t1'pes ol meter s*ckets.
removal of the nrcter does rrr.rl de-e ncrgize the existing sr slem .
D. Third Parly Easements
Anv third p{utv easefients &re the rcspr:nsihilig' of the upplicant tr: ohtzun aruJ .submit to KIIC. KIC will assisr in
the procrss o[ pmvrding a blank e&senent for sign*ure; howel'er rt is the applicturt's resprnsibilitl' to nurk ryith
land uwncrs. All easements lrill be recorded b1' KIC mmt comply uirh KEC Polie1'No. ]-;1.
E. Protection of Elsctrical Eguipment
Tk menrber shall providr prolective equipncent as rcquired by tl're Natianal lllecrrie Code {NlC) or orkr appli-
{:at:lc code{xl. Forall threc-phase motor ins{a.llatir:ns, tk me rnber is rcsrymxitrle li:r in*talling pr*tection rquipmcnt
against k:ss ofphase condrtions.
F. Sorvice Yoltages for ilsw Sarvices
Ior single-phasr installations, I30D40 l'r:11 scn'ice is avrilable. Thir is the tvpical thres-wire sen,ir,:e usrd lor
residencrs, 120 volt. trvr>rvirc'scn'ice rs not al'arlable.
lor three*phase in$sllutiorrs. lllr/30t1 and 277/4S0 volt servi*es are eLvailuhle.'Ilres.e are the t-vpical f*ur-wire
services used in commercial buildiugs and irrigation. KEC no longer acc*pts an]* nelv delta services"
G. llllotors. l'he lliilxrmum molor sr;zr allorrc'd on a srn!,le.nhase lrne rs lU hn.
. The rlarinrum mulor size allorved un r nvo-pha* line is l5 hp.. Variable liequrnc5' drives must rneet *le industrl' studard (lllEfi Standard i lS- 19S1) for lurrlanicx. lt'they
don't, it i.s llre memtxr's rcsponsibilitv to prol'rde tlre necesssn' harmunic filters to hring the in"rtsllation into
cr"rmpliance.
f,S alatu k rr.# k rJ{./s.i0lJ
4
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page5l of53
APPENDIX H
NEC Reference
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 52 of53
Artide !3O r Servicss
tine side of lhe dbconned. Fro'tfctlon againsl graund fqufts and
shsri circuib is provided by th€ sFecial requir*nxnls for rerl/i{e
csndudor pro{*rtion nnd lfi€ &}calion ol the cunductrrs,
On msilthrire air{uitl {rar sr three aingk"pore *itdres or clr-
cui{ breahers tfiai are capoble cd i*dividual operation are perm}t-
ted a5 ene prsterliyr device Sre{ided the sri"tthes or circuit
breakers arr equipped with handle ii€5 or B master handle, *o
thal an ungroilnded cc,nductors of a servlce can be dlsroilBEded
$,ith not more lkan r,ix sFerdhftr o{ ti}e hand, per 3}*.71 {B},
(A) Ltagnounfud Cwdrt{or, Sirch Fddfftitrr rhall be pwlitied
ry ea orefflrrer{ dtvhe in seri*s with mdr ut4roudod servicr
rorldilc.t$r &at h&s r rd.tog tr s:tring not hiShi{ thlo lhe sllsfflblc
atBpacit:* of lle corductof, A 3et of fus$ slull be eomsifuod all
the fuses rquil?d to pft{mt all the ungrumd$ clrductors of {
girr"$al Sir$ls-prllE cirruit bmaltrrs. Efrruped in acffrdeflrc rrillt
:-t{.}.? l(B}, shrll be cossidered a5 otp p,mlettive devict-
Er{qttisfl Na. I: for sr$ror-,rlflrrin8 currefil\, r.rrin8.r ,fid,
camp* *'ith +-it.,.-ll. -il*lrl^r;. and J-rr7.r:J slwlt be permined.
The service OCPD for a load thal includes moters as nE{, as ligffi-
ing or a lighli&g and arrpliane bad b ssbjBd to lhe rfiolor-ltarting
crrrrE&ts for all of thr mstols 1'Jilhin B buildlng. This exception
atlows lhe ceruke OCpD lo be sized using the requiremenls of
&1iiir 4f 0 io armrnmodate the mslordarthg and runnjflg crlr-
ren{ plu= {hr sther loads wilhin the bullding All of thr building
&rads are determlned in acrodance wi{h fu{icle 120. and the ser
vicr orductors and 0{}D must be sired to carry thd lsad- OtPDs
for rnstsr loadr are permitted lo Eave a raling or setling that
exceeds the allowabk Bmporily sf Ire ciffuit mnduchm. and thb
exdet{ion extends thet permissio* lo the service O[PD. Fo* an
ind*iud mc{or. tfie rating is s?eiifred by 410,!}; for tl*e or ntre
rooiors. {he rating is specified by "130,51; and br a motor{r} Ioad
Fkrs lightingand appfaffie lo,ad, the ratinB is speclfied tV {l0.Sf"
ErrqplranJfa, 2: tsusrs and cjrrni, Sreatrrr a.irrr d rotrns or
rcilrxg l&ril rarrpli*.r trilh :1it.4l ttj or ( C l dN :1tJ {' shsll b{
ptrmilted,
lryherE {ie Grldilcbr a$p*{i}y do€s not mneryond lo lhe dandard
arpere ratingof a cinnil brcaker Dr fuse this ex(eption permns th€
nex!.hrger*ize circuil bre*er or ftse to be indalled. The Fernission
to 'rrund ut' ir limitgd by i40.4iSF! to ra[hrp no{ excee$ng 8O0
amperes. This Xwbion only permib muniling up to fhe *ext stili-
dard sim fr.se or cirtuit breaker ratirg and dse: nat permit the had
to exceed tfie atbuable amFdity of ste servi{E condu<iors. See
140-6 for*andad arrperc dings ef ftre* and cinuit bredrers,
I:rrr,glr-oa f{o. J: Ir+u 1., sir cir.trfl brea*ers ilr tcls ({ful€t
r*afl be permincd&r tlr overrsrren I dtricc rfi prsvid( dtrfr\rr-
toad pntttrliaa. The ytn af lht fsiln$s a{ lhe drcai, brr*kers
flrfuwr sh{/,lb€ Wt,nitted M $ecdtlraqrydn a{he wn'ice
{andwtars. prwidrd tlw calrula$d k}ad, dars n&t xceed tht
artptlritf a//Ire .sdn:idf, rondrr:forJ.
lf multipfe swltcfie5 cr OfPDl are used as the dls(snnedifig
mearE" lhe amparily o, the service conrludsr5 must be egual to
lrto
Calcrdded loed = tr6 A
Bar,r,ica-efluengast*raots:$0lrml
Cc 7E!C = Ilt0 A
6or*inxd natlr4r - 3l& A
35&A main b.eehsr
parmiBad
The tctd cdrulaledlordmlbmsd
3.t0 A
E}J$W| 23.AJ,6 An emmple ln whrdr {he cornff d raiirrys d lrte
fie orwrunanl denicc arep€nnilH b Ercd lhr omltrr:W d ilw
senocF condrrlors.
or grealer than the load calculated in accordance *ith Artr-
cle 3lS; however, lhe cpnductor amparity is nol regulred to be
.qual to or gre8ter lhan thB mmbifled rathg of lhe multlple ser-
vice OCFDs. The rombined raling of service dismnneding means
is muered in 210.80.
The cornbined ratingr of the Bve OCPDs (350 amperes)
shorsn ln tj{nibit 1"30.16 exceed lhe ampaclly o{ the service.
enlrance mnductors (310 ilmpereg that is permitted by this
exceptbn. As spedfied, tie ampacity of iie *ruic*entran{e @n-
durtors is suflicimt to carry ttx cakulated load. The combine{
rating of the lfue servire discoftnecting mesfts abo (omplies $ilh
130.80, rvhidr requires that lhe csrnblned ratlng p50 amperes)
b€ not less than the cakulated load {:105 ampererl, the minimum
size required for the srrvice OCPO sFedfed b,y ?4O.4 and 210.80.
lfl addition" the rating of tie equlpilten{ (pafiEthoard} ln whidl the
five OCPIls or seryice disconnecting rn€ans are instalkd cannot
be less than the calculated load in acmrdancr with the require
menls of 40&.10. This exeptiofl allowsfor somedeign flexibility
by nol nquiring thr sum of the ratings b be equal to or hss lian
the ampacity of the service.entrarxe mnductors.
For example, the calculaled [oad supplied by the two
8&anpere devices shffin in Exhiblt 110-26 may be 73 ampetes.
Sectisn 140.6 ilen{ifies 70 arnperes ard 80 amperEs a standard
OCPD sizes. A 7(Fampere dgdce is too smoll, but an 8$ampere
device can be used in accordaxe rrylh.]40.4. The feeder conduc-
tors srpplied by the gtramp€re device are required lo h8ve an
arpacity nol less than the cakllated load, vi,hiln in &is eromple
is 73 anperer
I*ceptifia No- 1: Otzrload qtm$*iott Ior lire pwp suppnu
ronduclors shsll rrrmplv wi#r ri95.ltBN2fial-
f:ir,epio$ No. 5: Owrtad pwtctioa{or 12tr24&twlt,l-wire,
srnglr-piasr dx'elllag -ttt:.lilres .rhall M plrmitted h atcotdrrrt(
Sr4 N.at onal El€d]itrel Cade HandM
Attachment C
Case No. DIA-W-15-01
Staff Comments
05/18/16 Page 53 of53
af 3t$.15(Bltz).
Figure 1: NEC 230.90(8)
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frEBi!=FiEt*;flso.=.\EE;o o-zE*o358 Atachment D
CaseNo. DIA-W-15-0I
Staff Comments
05/18/16
Diamond Bar Estates Water Co.
Plant ln Service
Case No. DIA-W-15-01
Application Rate Case Expense
s 4,418.00
Emailfrom Cristy on 4/29/20L6
Professional Fees 5 2,200
Postage 5 111
DBEW Admin Work S 1,700 Hours 85 Rate S 20
Water Master Time S 750 Hours 30 Rate S 25
TOTAL COST 5 4,761
Fees for Annual Report $ (200)
Net Rate Case Expense S 4,561:
lnitial Rates Set 2003
First Rates 2OO7
This Rate Case 2015
Average years Between Rate
Cases 6
Requested 4 Year Amortization
s 1,105.00
6 year amortizations 7s4.00
Adjustment
s (311.00)
Attachment E
Case No. DIA-W-15-01
Staff Comments
05/l 8/16
o oo \oN665E$ F;' EEH<'H
$E E$ EE
=q z9 ex6E <5 69:,* q,N E,H
$E g$ E$
oB 98 oEEi Ei' Ea
d oa Po o\ b-8R EN I3E -I E'
-l -'Rq E& RSL 6 I, M L 6K* X,. HTl-lI-E
=R =S =6Eg E9 EEr=tEt-.R Es .xE* FP C:atddl?l
oS 9R oEId l'i.i EdtJH Xd tJdid r 4dl?l
zB z-e zX<i D@ <Fi>o z'E >s
a E3 Szq !!o zl:dF <NU I UN=-=-t -l
-93bt9fsg"'3t80-o-cEEEgg-*T*
PEEEoot-zEE-e!-qao:.?-E690EEE:fi;UgEEFFsEbEEE;.99'583c==59 59 3!
EdE6EdFL FL FLlo lo loE5 Eg g5
!!e E* !!e58 C8 68UE -'6 U@,.1 * s'* ,.1 *U6 P6 Uhovo
EE €38. H 5EoA< =<< 9r <<Z2.i sz.t q z.b
=<'i qi<': i <'=huoaroxuoRE8 =8 i8
E!coEEo.qHgFvUlCh No o ;o E-t. EE R E3- 5e.tE- Id E.i 9oo' ;oi
g,*! E- E- !- E-igq E ! € g EEE€ : H ; ; E3gB E I P i E-Attachment F
Case No. DIA-W-15-01
StaffComments
05/18/16
HR EHx,$ H,*
!3 F*
zo >P*E =sti!! 6diUN
't=<<l
!$ HH
fA E$d,R H,$
Eq B*KR E}I r,Nr-'
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T
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exF$H,d
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o o
qtuc>-9zit-<fUOdo<U
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Fs
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oB
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d
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OT
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cd
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EaB t- t- :;- t*,t,i} = E S q
EHE E E * g E
EI* E r ; E E3gS E E P E E-Attachment G
Case No. DIA-W-15-01
Staff Comments
05/18/16
Diamond Bar Estates Water Co.
Water Testing Expense
Case No. DIA-W-15-01
Well#1
A/ell#1 Nitrate Annual I S zo.oo $ 180.00 $ 20.00
uVell#1 Nitrite 'l in I Years 1 S zo.oo $ 20.00 $ 2.22
v1/ell#1 Alpha 1 in 9 Years 1 S as.oo $ 85.00 $ 9.44
vVell#1 Radium 226 1 in 9 Years 1 S 13o.oo $ 130.00 $ 14.44
yVell#1 Radium 228 1 in 9 Years 1 S r2o.oo $ 120.00 $ 13.33
yVell#1 Uranium 1 in 9 Years 1 s ss.oo $ 55.00 $ 6.11
/Vell#1 Arsenic 1 in 9 Years 1 s 2s.00 $ 25.00 $ 2.78
/Vell #1 Sodium 1 in 3 Years 3 S zs.oo $ 75.00 $8.33
fUell #1 Flouride 1 in 9 Years 1 S zo.oo $ 20.00 $ 2.22
Well#1 loc **1 in 9 Years 1 s 210,00 $ 210.00 $23.33
fUell #1 voc**1 in 6 Years 1.5 S 160.00 $ 240.00 $26.67
Sub-total $ 128.89
Well #2*
** IOC = lnorganic Contaminants
VOC = Volatile Organic Contaminants
DBP = Distribution By-Products*** Fewer tests are required for Well 2 than for Well 1
Attachment H
Case No. DIA-W-15-01
staff comments
0s/18/t6
Diamond Bar Estates Water Gompany
Power Cost Adjustment
DIA-W-I5-1
Line
1
2
Description
Company Proposed Power Costs
Less Natural Gas Costs Separately Handled
Adjusted Proposed Power Costs (Kootenai Electric)
Remove Company Proposed Adj for Rate lncrease
Remaining Power Costs
Remaining Power Costs
Remove 4.8% of Power Costs (Personal Use)
Staff Recommended Power Costs
Sum of Staff Adjustments
$9,990
$405
3
4
5
o
7
8
$9,585
$9,585
$479
$9,106
$9,100
$437
$8,669
$916
Attachment I
Case No. DIA-W-15-01
StaffComments
0slr8l16
Diamond Bar Estates Water Co.
Rate Base Calculation
Case No. DIA-W-15-01
Application
49,389
L2,669
Staff
Recommendation
39,670
1o,777
Difference
(8,718)
(2,492)
1 Plant ln Service
2 Accumulated Depreciation
3 Net Plant in Service
4 lnventory
5 Working Capital
6 Total Rate Base
7
8
9 Working Capital Calculation
10 Total Operating Expense
11 Working Capital (1/8 Rule)
35,719
4,679
29,493
3,452
(6,2261
(1,227],
40,398
37,434
4,679
32,945
27,627
(7,453)
(9,807)
(7,227].3,452
Attachment J
Case No. DIA-W-15-01
Staff Comments
05118/16
Diamond Bar Estates Water Co.
Revenue Requirement
Case No. DIA-W-15-01
1 Rate Base
2 Required Rate of Return
3 Return on lnvestment
4 Net Operating lncome Realized
5 Net Operating lncome Deficiency
Revenue Requirement lncrease
9 Subject to lncome Tax
10 Tax Gross Up Factor
Tax Grossed Up Amount
11 Not Subject to Income Tax
12 Gross Up Factor not Subject to lncome Taxes
Not Subject to lncome Taxes Amount
Revenue Requirement lncrease
13 Revenue lncrease Required
14 Total Revenue Collected in Test year
15 Revenue lncrease %
16 Total Gross Revenue Requirement
Gross-up Factor Calculation
17 Net Deficiency
18 PUC Fees
19 Bad Debts
20 State Tax @ 8%
21 Federal Taxable
22 FederalTax @ t5%
23 Net After Tax
24 Net to Gross Multiplier
78.02610% 99.75t90%
t28.16224% L00.24872%
78.086sO% 99.8L230%
728.06371% 100.18805%
Company Case
S qo,rgs
t2.00%s 4f48
s (14,661)
S rg,sos
Staff Case
s 32,94s
t2.00%s 3,953
s (6,e32)
S ro,ses
s
s
Subject to
lncome Taxes
100.00%
0.2487%
0.0000%
20,910
s20,910
s26,338
79.39%
547,248
Excluding
lncome Taxes
700.o0%
0.248t%
0.0000%
3,9s3
L28.0631%
s,063
6,932
100.1881%
6,945
Subject to
lncome Taxes
100.00%
0.7877%
0.0000%
12,008
s12,008
s 2s,696
46.73%
5 ztJoq
Excluding
lncome Taxes
100.00%
0.7877%
0.0000%
4,848
728.7622%
6,213
14,661
100.2487%
14,697
S
s
99.7579%
7s607%
99.7519%
0.0000%
99.8723%
7.9607%
99.8123%
0.0000%
97.7978%
t3.76570%
99.7519%
0.00000%
91.8522%
73.76570%
99.8723%
0.00000%
Attachment K
CaseNo. DIA-W-15-01
Staff Comments
05118/16
Diamond Bar Estates Water Company
Proof of Revenue
DtA-W-15-1
Current Rates
Billing
Months
Apr-14
May-14
Jun-14
Jul-14
Aug-14
Sep-14
oct-14
Nov-14
TOTAL
Customersl
228
45
45
44
45
44
44
44
Current Min
Charge
$29.00
$29.00
$29.00
$29.00
$29.00
$29.00
$29.00
$29.00
Billed Gallons
215,720
48,710
511,470
2,344,540
4,166,480
2,725,360
2,712,210
647,700
13,372,',l90
Charge:
$29.00
$0.80
Current
Usage
Charge
$0.80
$0.80
$0.80
$0.80
$0.80
$0.80
$0.80
$0.80
Revenue
from
Minimum
Charge
$6,612
$1,305
$1,305
$1,276
$1,305
$1,276
$1,276
$1,276
Revenue
from Usage
Charge
$1 73
$3e
$409
$1,876
$3,333
$2,180
$2,170
$51 8
Total
Revenue
$6,785
$1,344
$1,714
$3,152
$4,638
$3,456
$3,446
Current Minimum (incl. 5,500 gallons/month)
Current Usage Charge (per 1,000 gallons)
$1,794
539 $15,631 $10,698
Current Revenue Target:
Difference:
$26,329
26,338
(e)
$
$
Note 1: April Billing is sum of 5 usage months: Nov. 2013-Mar 2014.
Staff Proposed Rates
Staff Proposed Minimum (incl 5,500 gallons/month)
Staff Proposed Usage Charge (per 1,000 gallons)
% Change
Charge: from Current
$41.00 41.4%
$1.16 45.0o/o
Billing
Months Customersl
Staff
Proposed
Staff Proposed Usage
Min Charge Billed Gallons Charge
$41.00 215,720 $1.16$41.00 48,710 $1.16
$41.00 511,470 $1.16
$41.00 2,344,540 $1.16
$41.00 4,166,480 $1.16
$41.00 2,725,360 $1.16
$41.00 2,712,210 $1.16
$41.00 647,700 $1.16
13,372,190
Apr-14
May-14
Jun-14
Jul-14
Aug-14
Sep-14
Oct-14
Nov-14
TOTAL
228
45
45
44
45
44
44
44
$
$
$
$
$
$
$
$
Revenue
from
Minimum
Charge
9,348
1,845
1,845
1,804
1,845
1,804
1,804
1,804
Revenue
from Usage
Charge
$ 250$
$ 57$
$ 5e3$
$ 2,720 $
$ 4,833 $
$ 3,161 $
$ 3,146 $$ zst$
Total
Revenue
9,598
1,902
2,438
4,524
6,678
4,965
4,950
2,555
539 22,099 $ 15,512 $37,611
37,704
93
Staff Proposed Revenue Target:
Difference:
$
$
Amout By Which Proposed Target Exceeds Current Target $ 11,366
As a Percenl: 43.2o/o
Note 1: Apil Billing is sum of 5 usage months: Nov. 2013-Mar 2014.
Attachment L
Case No. DIA-W-15-01
Staff Comments
0s/l 8/16
Diamond Bar Estates Water Company
New Customer Connection Charge
D|A-W-15-1
Current Charge:
Company Proposed Charge:
Staff Recommended Charge:
$310.00
$475.00
$335.00
Backup for Staff Recommedation:
Line Description
1 Meter $291.00
Labor
lnstallation:2 t hour at $21 .24lhour+30% loading $27.61
(source: Bureau of Labor Statistics
hourly wage Occupation Code 47-2150)
3 Bookkeeping / Admin / Customer Service $10.00
Transportation
4 12 miles @ 55 cents per mile $6.60
5 Total Lines 1-4 $335.21
Round to: $335.00
Attachment M
Case No. DIA-W-15-01
Staff Comments
0s/18/16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ISTH DAY OF MAY 2016,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. DIA-W.Is-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
ROBERT TURNIPSEED
DIAMOND BAR ESTATES
WATER CO
PO BOX 1870
HAYDEN ID 83835
E-MAIL: avondalecon(Ofiontier.sorn
ALDEN HOLM
9446 W FAIRVIEW AVE
BOISE ID 83704
E-MAIL : alden(#Jtreasurevalleycpa.com
CERTIFICATE OF SERVICE