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HomeMy WebLinkAbout20080806Comments.pdfDONALD L. HOWELL, II DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0312 IDAHO BAR NO. 3366 I 'ìq~:: 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 EAGLE WATER ) COMPANY'S ENGINEERING REPORT AND ) APPLICATION TO CONTINUE THE EXISTING)SURCHARGE. ) ) ) CASE NO. EAG-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, Donald L. Howell, II, Deputy Attorney General, and submits the following comments in response to Order No. 30605 issued on July 31, 2008. On August 6,2007, Eagle Water fied its Engineering Report and the present Application to recover the professional fees (engineering, legal, accounting) for preparation of the Report and the Application. In its Application, the Company requests authority to recover $201,434 in professional fees, in addition to what the Company is authorized to recover in the curent surcharge. On September 18, 2007, the Commission issued a Notice of Application and set a deadline for intervention. No person sought to intervene. The Commission's Notice also observed that the Eagle City CoUncil had approved an "Asset Purchase Agreement" that would allow the City to purchase the utilty. Order No. 30430 at 1. The transaction was initially supposed to close in November 2007. The parties were not able to complete the Asset Purchase Agreement and the Agreement expired on March 31,2008. Given this tum of events, the Commission Staff has completed its review of the reasonableness and prudency of the requested engineering, legal and STAFF COMMENTS 1 AUGUST 5, 2008 accounting fees. In Order No. 30605 issued July 31, 2008, the Commission directed that ths case be processed under Modified Procedure. BACKGROUND A. The Commission's Initial Order The history behind this case is contained in Order No. 30266 but the pertinent events are briefly outlined here. In August 2005, the Commission issued an emergency Order directing Eagle Water to "use all deliberate speed" to increase water pressure in a portion of its service territory. In addition to taing immediate actions, the Company was directed to prepare an engineering report to address the chronic low-pressure problems in its system and to project its water supply needs for the future. The Engineering Report was to "serve as a 'road map' for determining exactly what infrastructure improvements are necessar to serve present and future needs of Eagle Water and its customers." Order No. 29903 at 7. To recover the costs of preparing the engineering study, the Commission authorized Eagle Water to implement a rate surcharge. Order No. 29969. The surcharge was based upon the legal, accounting, and engineering fees necessar to prepare the Engineering Report and to file the accompanying Application. The Commission authorized surcharge was designed to recover $112,414. After the Commission issued its surcharge Order, Eagle Water and the Deparment of Environmental Quality (DEQ) signed a "Consent Order," which among other issues, required Eagle Water to submit the Engineering Report to DEQ for approvaL. DEQ directed that Eagle Water submit a preliminar Engineering Report for review and comment, followed by the preparation of the final report. Although the Commission directed that the Engineering Report should be completed as soon as possible, its submission to the Commission was significantly delayed. Eagle Water attributed the delay to various issues including: the health of its primary engineer; the need to engage another engineering firm; changing DEQ system requirements; and the lengthy DEQ review process. Order Nos. 30213,30266,30331. The Company also reported that the cost of preparing the Engineering Report greatly exceeded the amount authorized by the Commission. Order Nos. 30266 at 2, 30331 at 2. STAFF COMMENTS 2 AUGUST 5, 2008 B. The Cash Flow Order As par of its August 2007 Application, Eagle Water requested authority to borrow $110,000 for cash flow puroses. In Order No. 30440 issued September 21, 2007, the Commission granted Eagle Water authority to borrow up to $110,000. The Company was also granted authority to access the existing surcharge account conditioned upon the Commission's subsequent review to determine the reasonableness and prudency of the professional fees for preparation of the Engineering Report and the accompanying Application. The Commission found that "Eagle Water may be required to reimburse the surcharge account for any disallowed amounts paid from that account. If the outstanding loan covers disallowed costs, Eagle Water will be required to pay these amounts directly to the ban." Order No. 30440 at 3. C. The Current Status In Order No. 30430, the Commission directed that the paries should devise a recommended schedule to process the remaining phase of this case. The Staff and the Company met on July 24, 2008. They recommended that the remaining phase of this case be processed under Modified Procedure. Through June 30, 2008, the Staff reported that the surcharge has collected approximately $304,000. The Company was authorized to recover $112,414 and has an outstanding request for $201,434. In its Application, the Company requested $201,434 for professional fees made up of the following items: Additional Engineering Fees for the Engineering Report Additional Legal Fees for the Engineering Report Additional Legal Fees for the Previous Surcharge Application Additional Accounting Fees for the Engineering Report Estimated Legal Fees for the Surcharge Extension Application Estimated Accounting Fees for the Surcharge Extension Application Total $161,394 $16,232 $10,945 $263 $12,000 $600 $201,434 After completion of this proceeding, the paries anticipate that Eagle Water wil fie a new application seeking to recover new expenses for the cost of two new wells, a new booster pump, and the costs of interconnecting with the City of Eagle (see Case No. EAG-W-08-01). STAFF COMMENTS 3 AUGUST 5, 2008 STAFF ANALYSIS Additional Engineering Fees As previously mentioned, the Engineering Report was to "serve as a 'road map' for determining exactly what infrastructure improvements are necessar to serve the present and future needs of Eagle Water and its customers." Order No. 29840. This report was to include a comprehensive analysis of the existing system including projected water needs out to 2010 and consider all possible options including additional water supply, storage, booster pumps and additional mainlines necessar to meet existing and projected water requirements. The report was to also include the recommended system improvements, construction schedule and estimated cost of each individual project. The Commission directed Eagle Water to work closely with Commission Staffin the preparation of this report and advise the Commission within 21 days of when the engineering study would be completed and submitted to the Commission. On Februar 6, 2006, the Commission issued Order No. 29969 authorizing the Company to recover $79,895 for preparation of the Engineering Report and $8,011 in legal fees and accounting fees. In other words, the Commission authorized the Company to recover a total of $87,906 through the surcharge. Using the gross-up factor of 1.2788, the Commission found that Eagle Water was permitted to recover $112,414 from the surcharge account. Eagle Water used MTC, Inc. (MTC), an engineering consulting firm to prepare the Engineering Report based upon a study of the Company's system. Eagle Water submitted a draft Preliminar Engineering Report to the Commission on June 2, 2006 for informal review. Staff reviewed the report and sent comments to the Company on June 29,2006 (see Attachment A). The key issue raised by Staff was that the Engineering Report did not adequately respond to the concerns of Commission Order No. 29840, page 3, which directed Eagle Water to assemble an engineering report that: . . . shall include a comprehensive analysis of the existing system including projected water needs out to 2010. The analysis wil consider all possible options including additional water supply, storage, booster pumps and additional mainlines necessary to meet the existing and projected water requirements. The report shall include the recommended system improvements, construction schedule and estimated costs of each individual project. Eagle Water and its engineer shall work closely with the Commission Staf in preparation of this report. STAFF COMMENTS 4 AUGUST 5, 2008 After submitting the preliminar Engineering Report, MTC had already purportedly accrued about $91,901 worth of professional services. This exceeded the original engineering study estimate and Commission-approved amount of $79,895 (Exhibit 6, MTC Invoice dated June 27, 2007, Case No. EAG-W-07-01). See Attachment B. On August 24,2007, in response to Staff Production Request No.5, the Company indicated that there were no written contracts between the Company and MTC to perform the Engineering Study. Staff questions the due dilgence exercised by the Company in initiating a work order to complete an expensive engineering study without any wrtten contract in spite of the anticipated complexity of the engineering analysis to be undertaken with an estimated cost of $79,895. As a result of comments from Commission Staff and DEQ, Eagle Water and MTC continued working on the Engineering Report. It appears that sometime in July 2006, MTC requested that Ward Engineering Group of Salt Lake City help complete the Engineering Report. Eagle Water indicated that there was no written agreement between MTC and Ward Engineering. However, the job invoice submitted by Ward Engineering to MTC on June 9, 2007, Attchment C, indicates at the top of the page the original price agreed to complete the Engineering Report was $43,000. Staff again raises the question of due diligence exercised by Eagle Water and MTC for initiating a large project without a written agreement, especially with the technical and complex nature of the job to be performed. The amount to be paid for services simply appeared in the June 9, 2007 invoice. MTC and Ward Engineering met with DEQ in early October 2006 to respond to DEQ's previous comments on the draft Preliminary Engineering Report. Additional comments were also received by MTC and Ward Engineering during that meeting according to the affidavit (Eagle Water's Response NO.4 to Staffs First Production Request) filed by Chet Hovey of Ward Engineering to the Commission on December 19,2006. After the meeting with DEQ, Ward Engineering continued the analysis to complete the Engineering Report. Staff reviewed available documents but it was not clear whether the result of this meeting with DEQ triggered the additional work and change order. There was no wrtten contract between MTC and Ward Engineering about this change order. Staff notes that the invoice submitted by Ward Engineering to MTC on June 6, 2007 showed a change order amount (additional services) of $53,064.73. Attachment C. The total amount shown in the invoice was therefore $96,064.73 (Original work order amount of $43,000.00 plus change order amount of$53,064.73). This additional change order amount of $53,064.73 was in conflct with the change order amount of STAFF COMMENTS 5 AUGUST 5, 2008 $42,476.73 included in a later invoice submitted by Ward Engineering to MTC on August 29,2007, Eagle Water's Response No. 6b toStafts First Production Request, Attchment D. Neither Eagle Water, MTC, nor Ward Engineering satisfactorily explained this discrepancy. MTC and Ward Engineering continued working on the Preliminar Engineering Report and submitted drafts to the Commission and DEQ on January 19,2007 and March 15,2007 for review. Comments were made by DEQ concerning the Engineering Reports. Finally, on July 6,2007, DEQ approved the Preliminar Engineering Report dated June 2007 with some recommendations for correcting deficiencies in the existing system. Staff also reviewed the Final Engineering Report submitted to the Commission on August 6, 2007 and believes that the report generally conforms to the requirements set out in Commission Order No. 29840. According to Eagle Water, the total fees due for completing the Engineering Report are $218,394.30 with the following details: MTC'swork Less amount paid to Ward MTC (net) Plus Ward's initial work order Plus Ward's change order Ward's total Grand Total $ 144,329.57 $ 22,000.00 $122,329.57 $ 43,000.00 $ 53,064.73 $ 96,064.73 $218,394.30 The total cost of $218,394.30 for the development of the Engineering Report is almost three times the original cost estimate of $79,895 submitted by the Company as part of its Surcharge Application on August 24, 2005, which was subsequently authorized by the Commission in Order No. 29903. The original estimate was prepared by MTC, an expert in the field. Order No. 29903 directed the Company to complete the engineering study as soon as possible. It took the Company almost 10 months after the Commission Order No. 29840 to finish and submit a preliminar Engineering Report, which did not adequately address the items specifically outlined in Order No. 29840. At that point, MTC had already spent $91,901.97 more than the Commission-approved amount. See Attachment B. Yet it took the Company another year to fully address those items in completing and submitting the final Engineering Report. Eagle Water justifies the increase in the cost of Engineering Report from $79,894.75 to $218,394.30 due to the following reasons: (1) technical glitches with the Haested computer modeling software that was used in the report; (2) deparure of the MTC engineer who worked on STAFF COMMENTS 6 AUGUST 5, 2008 the initial draft; (3) lack ofa similarly qualified engineer on staff at MTC; (4) an aortic aneurism suffered by MTC's principal; and (5) contradictory peak flow stadards required by DEQ which necessitated no less than 36 revised computer modeling rus. Staff believes that Items 1 through 4 are either personal or professional business issues that the extra costs attributed by any of these items should be absorbed by MTC and not Eagle Water ratepayers. These are the risks of ruing a professional services business. The ratepayers should not shoulder the extra costs incured. Staff believes that the biled cost for the engineering study is excessive. Eagle Water failed to provide convincing justification for the costs incured by MTC in excess of the original estimate. Eagle Water failed to provide evidence that it exercised adequate oversight and cost control in the development of the Engineering Report. In addition, Staf notes that there was no wrtten contract between Eagle Water and MTC, the primar engineering consultant, and no wrtten contract between MTC and Ward Engineering. There appeared to be little cost control and an inconsistent biling process where at one time, the change order contract between MTC and Ward Engineering was $53,064.73(6/9/07 Ward Invoice). Subsequent bilings charged an amount of $42,476.73 (8/29/07 Ward Invoice) without adequate explanations. Staff believes that the $42,476.73 isthe more accurate amount for the change order because it is the latest invoice adjusting the original bil. Based on its investigation, Staff recommends disallowing all the costs incured by MTC over the original and previously Commission-approved engineering study estimate of $79,895. Staff believes it is reasonable for Eagle Water to recover the original MTC engineering estimate, the amount charged by Ward Engineering, and the change order fees charged by Ward to make DEQ required changes in the study. It is Staffs position that once MTC asked Ward Engineering to complete the study including change orders, additional engineering fees biled by MTC above the original estimate were unwaranted and became unecoverable. Therefore, Staff recommends that in addition to MTC' s original estimate of the cost to complete the entire report of $79,895; the Commission allow recovery of $43,000 for Ward Engineering to complete the study, and $42,476.73 for Ward to make all the model changes required by DEQ. Staff recommends that $85,476.73 of the additional engineering fees be allowed for recovery from the surcharge account. STAFF COMMENTS 7 AUGUST 5, 2008 Additional Legal and Accounting Fees In addition to supplemental engineering fees, the Company has requested recovery, from the surcharge account, of the additional legal and accounting fees incured to complete the Engineering Report and to process the previous surcharge application, Case No. EAG-W-05-02. Staffhas reviewed the amounts requested for recovery for these previously incurred charges and agrees they were reasonably incurred. Staff recommends recovery of $16,231.84 in legal fees for the Engineering Report, $10,945.22 for the legal fees associated with the previous surcharge application, and $262.50 for the accounting fees associated with the Engineering Report. The Company has also requested recovery, from the surcharge account, of the estimated legal and accounting fees for the curent application. The Company estimates that the legal fees will total $12,000, and that the accounting fees wil total $600. Staff recommends that these amounts not be recovered in the curent application but that the Company, in its next proceeding, ask for recovery. At that time the Company can submit the invoices supporting the actual amounts for these services. The Surcharge Account Over the course of this case and the prior case, Staffhas monitored and audited the surcharge account. Commission Order 29903 states: To avoid the mixing of surcharge revenue with other Company revenue, Eagle Water shall book the surcharge revenues in a separate account. Withdrawals from the separate account shall be restricted to payments for the engineering study, and for legal and accounting expenses incured in preparation of the Surcharge application and actions authorized in this Order. Staff shall audit this account for compliance. The scope of each audit was to examine the surcharge collections authorized in Case No. EAG- W -05-02. Staff examined the books and records documenting the surcharge, including the accounting records of the company, the monthly savings account statements, and the monthly loan statements. Staff verified that the surcharge was correctly calculated, that the surcharge fuds were separated from the general funds of the Company, and that the withdrawn surcharge fuds were used for the authorized puroses. STAFF COMMENTS 8 AUGUST 5, 2008 Current Status Through the month of June 2008, Eagle Water has collected $304,366 in surcharge revenue. The surcharge is based on usage, approximately 19 cents per hundred gallons over the first 600 gallons used ($0.451/100 gallons x 42.5% surcharge). The curent authorized surcharge was originally designed to recover $112,414. In this case, Staffis recommending that an additional $144,397 be recovered by the surcharge. The breakdown of this amount is shown in the following section. The surcharge collections and Staff recommendation is shown on Attchment E. STAFF RECOMMENDATION Staff recommends that the Company be authorized to recover an additional $144,397 from the surcharge account for additional engineering, accounting and legal expenses and that the surcharge on rates be discontinued. After subtracting the authorized amount in this case, Staff recommends that the remaining surcharge balance be held to cover future costs associated with capital expenditures required by the Engineering Report (i.e., the next application). Staff specifically recommends the following costs for the Engineering Report be recovered by Eagle Water Company from the present surcharge account: Ward Engineering Ward Engineering Total Engineering Report Sub-Total This Case $ 43,000.00 (First Work Order) $ 42,476.73 (Change Order) $ 85,476.73 Staff fuher recommends the following costs for legal and accounting fees be recovered by Eagle Water Company from the present surcharge account: Additional Legal Fees for the Engineering Report Additional Legal Fees for the Previous Surcharge Application Additional Accounting Fees for the Engineering Report Legal and Accounting Fees Sub-Total $16,231.84 $10,945.22 $262.50 $27,439.56 STAFF COMMENTS 9 AUGUST 5, 2008 Total Expenses (EngineeringlLegal/ Accting) Income Tax Offset (Gross-Up Factor of 1.2788) Total Surcharge Recommendation This Case $112,916.29 $31,481.06 $144,397.35 Thus, the tota recoverable costs from the surcharge account should be: Previously Authorized Amount Recommended Amount This Case Total Surcharge Recovery $112,414 $144,397 $256,811 Respectfully submitted this 5-1 day of August 2008. ¡¿~~~ Deputy Attorney General Technical Staff: Kathy Stockton Gerr D. Galinato i: :umisc/comments/eagw07.1 dhklsgg STAFF COMMENTS 10 AUGUST 5, 2008 IDAHO PUBLIC UTiliTIEScommission James E. Risch, Governor P.O. Box 83720, Boise, Idaho 83720-0074 June 29,2006 Paul Kjellander, President Marsha H. Smith, Commissioner Dennis S. Hansen, Commissioner Mr. Robert V. Deshazio, Jr. Eagle Water Company, Inc. PO Box 455 Eagle, il 83616 EAG-w-o..-- ø:i Dear Mr. Deshazio: The Idaho Public Utilties Commission received your Preliminary Engineering Report on June 2, 2006. We are pleased that you have responded to the Commission's Order to improve the Eagle Water Company system. Although we recognize that the Report is not yet final, Staff deems that the Engineering Report does not adequately respond to the concerns addressed in the Order. Commission Order No. 29840 page 3, directed Eagle Water to assemble an engineering report that: ...shall include a comprehensive analysis of the existing system including projected water needs out to 2010. The analysis wil consider all possible options including additional water supply, storage, booster pumps and additional main lines necessar to meet the existing and projected water requirements. The report shall include the recommended system improvements, constrction schedule and estimated cost of each individual project. Eagle Water and its engineer shall work closely with the Commission Staffin preparation ofthis report. The existing report essentially contains the implementation of one alternátive: completion of well #7 and improvements to the booster station near SH-55. While these steps demonstrate positive improvements for system pressure, no other alternatives were offered. In addition, you did not include any cost-effectiveness analyses. The Commission Staffis seeking further information as it relates to the Eagle Water Company, its system, and its plan for the future. Specifically, the Staff would like to see your analysis as to why the new well and booster is the most cost-effective alternative, analysis of other alternatives, impacts of storage and mitigation strategies, and a more explicit plan for future company growth and maintenance. Additionally, we expect Eagle Water to file an Application to implement the findings in the engineering report. Located at 472 West Washington Street, Boise, Idaho 83702 Telephone: (208) 334-0300 Facsimile: (208) 334-3762 Attachment A Case No. EAG-W-07-1 Staff Comments 08/05108 Page 1 of 2 Robert Deshazio, Jr. June 29, 2006 Page 2 Your attention to ths matter is greatly appreciated. Should you have any questions or concers, please contact me at 208-334-0355. L Dave Schunke u:dave Schunkeleagle water co Itr Attachment A Case No. EAG-W-07-1 Staff Comments 08/05/08 Page 2 of 2 I MTC, INC.I CONSUTING ENGINEERS, SURVE RS AND PLANNERS 1707 N. 27t STREET I I Boise, 10 83702 I20- 34780 fa 208 34967 FOR PROFESSIONAL ENGINEERING SERVICES FEDERA # 82-0398542 ACCOUNT OF JOB NUMBER EAGLE WATER COMPo 05-8 P.O. BOX 455 EAGLE, 1083616 . JOB #05-8 JUNE 27, 207.. PUC STUDY FOR EAGLE WATER COMPANY BILLED $PAID-Date AUGUST 2005 4,377.50 4,377.50 SEPTEMBER 3,962.50 3,962.50 OCTOBER 9,571.75 9,571.75 Water Program 5,04.95 5,0495 NOVEMBER 10,808.10 10,808.10 DECEMBER 2005 10,976.4 10,976.4 44,741.29 12--8-2005--paid JANUARY..2006 $13,165.00 FEBRUARY $12,714.70 MARCH $10,028.75 APRIL $10,131.58 MAY $11,928.75 JUNE $1,919.96 JULY $791.88 AUGUST $34.00 SEPTEMBER $890.00 OCTOBER $582.91 NOVEMBER $34.00 DECEMBER-2006 $680.00 MTC PAID to WARD ENGINEERING 22,000.00 paid 12-11-2006 I I loace 1 Attadiment B Case No. EAG-W-07-1 Staff Comments 08/05/08 Page 1 of 2 , JOB # 06-8 JUNE 27, 2007.. PUC STUDY FOR EAGLE WATER COMPAN BILLED $Dat PAID JANUARY 2007 6,892.50 printing 12 books $381.00 FEBRUARY $977.50 MARCH $696.00 APRil 1,43.75 MAY 1,815.00 JUNE 2,975.00 TOTAL JUNE 27, 2007 $144,329.57 44,741.29 12-8-D6les total paid $44,741.29 TOTAL DUE $99,588.28 paae2 AttaclientB Case No. EAG-W-07-1 Staff Comments 08/05/08 Page 2 of 2 06/26/2097 08: 37 WARD ENINERING GRO PAG 02 Date ,Paid, 12!1310.~,'8/07 s. ~:3/z.7 S ).'3100' $ 3l8!2007 S 313.12007 S $ S S S l8al 4878668 MTC IlIee . rob l Mi~OO2~ , Or Con..Amt: Tot Cll Orde Amo~ßt: Revis ttit AmUDt:. ' .. Con.t Amou R~ntg.: S43,"00.00 $S3,064.73 (Additional Senicia) $96.0~4.73 . WaCW S)te Sr. .lle Wilter Cog_y . . :JlWoiç~ .' . .lìJok ' Invoice .NWf Da Amount4 . 10041 J lIt t-200 S 23.214.49 2(115 lli151200 S 603.7 S20336 ! 121126.$ 4.22.30 20532 I2/JZOO S 5,5ib.OO2092 ll6OO S 3,712.50 i0934 1120.12007. S 455.00 ii~,i: 113lJ $ 8,272.3921329 2'!-17127 $ '977.0 Credt L~ued i/8.'2007 3/812007 3/812001 31&'2007(Overyment) 216(5 '11112007 S i.~.OO 2ril~3~,11200'S 3ll.7~ 21967 414/2'0 S ;J3.15 224U 5/\21Q&i.:$15.954.00 ii731 . :6/912111 S . . 24.46.'0 Job Sta 6(9107 T&M AmOl Paìå. Ok ~.214.cR 60.75 4.22.50 5,520,00 3.712.50 455.00 &.Z1ZJ9 ()1.50 10',021.67 Amoun Bil to Date: Aioùn Paid to Dati Cre Juue: Jt~..' Am Du~ $ 96~06.73 $ S7,000.00 $ S 39,~4.73 6/9/2Q07 Dae:'Thrp, P.Dent Mange . WARD ENGlEmuÔ GROUP. (11)41'....' C0MMTS: It 1.$% imst chqe sbt be- adde and billed ~cely each immth on any amont overdue. P"SiÖlll: S. Taltri.:_ Attachment C Case No. EAG-W-07-1 Staff Comments 08/05108 Job Statement MTC Engineering Job # MTC002-06 Origin Contract Amount: Total Change Order Amount: Revised Contract Amount: Contract Amount Remang: T&M $43,000.00 $42,476.73 (Additonal Servces) $85,476.73 Water System Study - Eagle Water Company Invoice Invoice invoice Credit Date AmountNumberDateAmountIssuedPaidPaid 20041 11/11/2006 $23,214.49 12/13/06-3/8/07 $23,214.49 20215 1112512006 $603.75 3/8/2007 $603.75 20336 12/9/2006 $4,222.50 3/8/2007 $4,222.50 20532 12/23/2006 $5,520.00 3/812007 $5,520.00 20692 116/2007 $3,712.50 3/8/2007 $3,712.50 20934 1120/2007 $455.00 3/812007 $455.00 21152 2/312007 $8,272.59 3/8/2007 $8,272.59 21329 2/17/2007 $977.50 31812007 $977.50 (Overpayent)3/8/2007 $10,021.67 21615 3/17/2007 $7,990.00 21816 3/31/2007 $318.75 21967 4/14/2007 $363.15 '~îi.". It .' .' iJ'\l 'iiO¡j224225/12/2007 $15,954.00 Your account ;8 overdue.22732 6/912007 $13,872.50 Me MDuld apprec.afe payment. Amount Biled to Date:$85,476.73 Amount Paid to Date:$57,000.00 Credits Issued:$ Remaining Amount Due:$28,476.73 8/29/2007 Brendan Thorpe, P.E. Deparent Maager WAR ENGINERIG GROUP (801) 487-8040 COMMENTS: Date: A 1.5% interest charge shall be added and biled separately each month on any amount overdue. President: S. Tabriz_ Attachment D Case No. EAG-W-07-1 Staff Comments 08/05/08 oc n ( ' ; i oo ¡ ; ~ : : ô. . v . ¡ , Vl ' " ( ' n Ô( ' Z ; : 00 0 0 S § ~ g (' ; i ; ~ ' ? ~o-.i- Ye a r Co l l e c t i o n s 20 0 5 $1 , 7 5 9 . 7 3 Le g a l a n d A c c o u n t i n g F e e s Ad d i t i o n a l L e g a l F e e s Or i g i n a l E n g i n e e r i n g R e p o r t F e e s Ad d i t i o n a l E n g i n e e r i n g F e e s Ad d i t i o n a l L e g a l F e e s Ad d i t i t i o n a l A c c o u n t i n g F e e s To t a l E x p e n s e s In c o m e T a x O f f s e t 1 . 2 7 8 8 % St a f f T o t a l S u r c h a r g e R e c o m m e n d a t i o n Ea g l e W a t e r C o m p a n y Ca s e N o . E A G - W - 0 5 - 0 2 Ca s e N o . E A G - W - 0 7 - 0 1 Su r c h a r g e C o l l e c t i o n s 20 0 6 $1 3 0 , 8 0 5 . 5 0 20 0 7 $1 3 8 , 7 5 8 . 0 1 $5 , 5 0 0 2, 5 1 1 79 , 8 9 5 85 , 4 7 6 27 , 1 7 7 26 3 $2 0 0 , 8 2 2 55 , 9 8 9 $2 5 6 . 8 1 1 Or i g i n a l S u r c h a r g e A p p r o v e d b y C o m m i s s i o n St a f f R e c o m m e n d a t i o n f o r A d d i t o n a l E x p e n d i t u r e s $1 1 2 , 4 1 4 $1 4 4 , 3 9 7 St a f f R e c o m m e n d a t i o n Su r c h a r g e C o l l e c t i o n s t h r o u g h J u n e 3 0 , 2 0 0 8 Re m a i n i n g S u r c h a r g e B a l a n c e $2 5 6 , 8 1 1 $3 0 4 , 3 6 6 $4 7 , 5 5 6 Th r o u g h Ju n e 3 0 t h 20 0 8 $3 3 , 0 4 3 . 0 3 To t a l Co l l e c t e d $3 0 4 , 3 6 6 . 2 7 Co m m i s s i o n A p p r o v e d Co m m i s s i o n A p p r o v e d Co m m i s s i o n A p p r o v e d St a f f R e c o m m e n d a t i o n St a f f R e c o m m e n d a t i o n St a f f R e c o m m e n d a t i o n CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF AUGUST 2008, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. EAG-W-07-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, to THE FOLLOWING: ROBERT DESHAZO PRESIDENT EAGLE WATER COMPANY INC 172 W. STATE STREET EAGLE ID 83616 MOLLY O'LEARY RICHARDSON & O'LEARY PO BOX 7218 BOISE ID 83707 ,Jl2oASECRETARY -- CERTIFICATE OF SERVICE