Goss • Samford - Kentucky cases/2015-00301/20151113_Knott... · Goss • Samford PLLC ^ X Attorneys at Law ... f E. BUDGET AMENDMENTS ... HOTION TO APPOINT EDDIE CAMPBELL. BONNIE

Goss • Samford PLLC

^ X Attorneys at Law

Mr. Jeff Derouen

Executive Director

Public Service Commission

211 Sower Boulevard

Frankfort, Kentucky 40602

L. Allyson [email protected]

(859)368-7740

November 13, 2015

RECEIVEDNOV 1 3 2015

PUEliC SERVICECOMMISSION

VIA HAND DELIVERY

RE; In re the Matter of: Joint Application ofKnott County Water and Sewer, Inc. andTroublesome Creek Environmental Authority, Inc., for an Order Approving the TransferofOwnershipand Control ofa Jurisdictional Asset - Case No. 2015-00301

Dear Mr. Derouen:

Please find enclosed for filing with the Commission, in the above referenced case,an original and ten copies of Knott County Water and Sewer, Inc., and Troublesome CreekEnvironmental Authority, Inc.'s, Responses to Commission Staffs Second Request forInformation.

Please return a file-stamped copy of these filings to my office.

Enclosures

Very truly yours,

L. AllysoMIonaker

2365 Harrodsburg Road, Suite B-325 | Lexington, Kentucky 40504

13 [m

(kkP--:LIC SERVICE'̂OiVnVIISSION

COMMONWEALTH OF KENTUCKY

BEFORE THE PUBLIC SERVICE COMMISSION

In the Matter of:

JOINT APPLICATION OF KNOTT COUNTY WATER

AND SEWER, INC. AND TROUBLESOMECREEK ENVIRONMENTAL AUTHORITY, INC. FORAN ORDER APPROVING THE TRANSFER OF

OWNERSHIP AND CONTROL OF A JURISDICTIONAL

ASSET

CASE NO.

2015-00301

RESPONSES TO COMMISSION STAFF'S SECOND REQUEST FOR

INFORMATION TO KNOTT COUNTY WATER AND SEWER, INC., AND

TROUBLESOME CREEK ENVIRONMENTAL AUTHORITY, INC.

DATED October 30,2015

KNOTT COUNTY WATER AND SEWER, INC.

AND


PSC CASE NO. 2015-00301

PUBLIC SERVICE COMMISSION'S SECOND REQUEST FOR INFORMATIONDATED 10/30/15

Knott County Water and Sewer, Inc., ("KCWSD") and Troublesome Creek

Environmental Authority, Inc., ("TEA") hereby submit responses to the information

requests of the Public Service Commission Staff ("PSC") in this case dated October 30,

2015. Each response with its associated supportive reference materials is individually

tabbed.



In the Matter of:

JOINT APPLICATION OF KNOTT COUNTYWATER AND SEWER. INC. ANDTROUBLESOME CREEK ENVIRONMENTALAUTHORITY, INC. FOR AN ORDERAPPROVING THE TRANSFER OFOWNERSHIP AND CONTROL OF A

JURISDICTIONAL ASSET

CERTIFICATE

COMMONWEALTH OF KENTUCKY ))

COUNTY OF KNOTT )

CASE NO.

2015-00301

L. J. Turner, Manager ofKnott County Water and Sewer District, Inc., being duly sworn,states that he has supervised the preparation of the responses of Knott County Water and Sewer,Inc. and Troublesome Creek Environmental Authority, Inc., to the Public Service CommissionStaff's Requests for Information issued at the informal conference on October 19, 2015, and thesecond set ofRequests for Information issued on October 30,2015 in the above referenced case,and that the matters and things set forth therein are true and accurate to the best of hisknowledge, information and belief, formed after reasonable inquiry.

Theforegoing Certificate was signed, acknowledged and sworn to before me thisday of November, 2015, by L.J. Turner.

NOTARYPUBLIC, Notary #Commission expiration: g J j /L



In the Matter of:

JOINT APPLICATION OF KNOTT COUNTY

WATER AND SEWER, INC. ANDTROUBLESOME CREEK ENVIRONMENTAL

AUTHORITY, INC. FOR AN ORDERAPPROVING THE TRANSFER OF

OWNERSHIP AND CONTROL OF A

JURISDICnONAL ASSET

CERTIFICATE


COUNTY OF KNOTT )

CASE NO.

2015-00301

Kyle Smith, Chief Financial Officer of Knott County Water and Sewer, Inc., being dulysworn, states that he has supervised the preparation of the responses of Knott County Water andSewer, Inc. and Troublesome Creek Environmental Authority, Inc., to the Public ServiceCommission Staffs Requests for Information issued at the informal conference on October 19,2015,andthe second set ofdata requests issuedon October30,2015, in the above referencedcase,and that the matters and things set forth therein are true and accurate to the best ofhis knowledge,information and belief, formed after reasonable inquiry.

KyJjfSmith

Theforegoing Certificate was signed, acknowledged and swom to before methis /3day ofNovember, 2015, by Kyle Smith.

ITARYPU

Commission ex

fotary #[ration:



In the Matter of:

JOINT APPLICATION OF KNOTT COUNTY

WATER AND SEWER, INC. ANDTROUBLESOME CREEK ENVIRONMENTAL

AUTHORITY, INC. FOR AN ORDERAPPROVING THE TRANSFER OF

OWNERSHIP AND CONTROL OF A

JURISDICTIONAL ASSET

CERTIFICATE


COUNTY OF LETCHER )

CASE NO.

2015-00301

Calvin Randall Tackett, Outside legal counsel of Knott County Water and Sewer, Inc.,beingduly sworn, states that he has supervised the preparation of the responses of Knott CountyWater and Sewer, Inc. and Troublesome Creek Environmental Authority, Inc., to the PublicService Commission Staff's Requests for Information issued on October 30, 2015, in the abovereferenced case, and that the matters and things set forth therein are true and accurate to the bestofhis knowledge, information and belief, formed after reasonable inquiry.

Calvin Randall Tackett

The foregoing Certificate was signed, acknowledged and sworn to before me thisday ofNovember, 2015, by Calvin Randall Tackett.

NOTARY PUBLIC, Notary #Commission expiration: 9,. ao\-7

PSC Request 1

Page 1 of 11


AND


PSC CASE NO. 2015-00301


REQUEST 1

RESPONSIBLE PERSON: C. Randall Tackett

COMPANY: Outside legal counsel for Knott County Water

and Sewer, Inc.

Request 1. In Case No. 2003-00326, the applicant in that proceeding, in describing

itself, states that it was "a water district of Knott County, Kentucky, created and existing

under and by virtue of Chapter 74 of the Kentucky Revised Statutes"^ In the Joint

Application in this case, Knott County Water and Sewer, Inc. identified itself, in pertinent

part, as "a Kentucky corporation, originally incorporated on April 16, 2003, that it is in

good standing and operating as a special district formed under KRS Chapter 74,et. seq."^

Request l.a. State whether Knott County Water and Sewer, Inc., is the same utility that

filed the application in Case No. 2003-00326. If so, explain and reconcile the difference

in the descriptions in the two applications.

^Case No. 2003-00326, TheApplication ofKnott County Waterand Sewer Districtfor a Certificate ofPublic Convenienceand Necessity to Construct and Finance Pursuant to the Provisions ofKRS278.023(Ky. PSC filed Aug. 25,2003), Application at 1.Âpplication at 1.

PSC Request 1

Page 2 of 11

Request l.b. State whyKnott County Water and Sewer, Inc., is incorporated pursuant to

KRS,Chapter 273. Include in the response whether Knott County Waterand Sewer, Inc.,

was created in accordance with theprocedures of KRS 65.810 or KRS Chapter 220.

Response l.a. Knott County Water and Sewer, Inc., ("KCWSD") is the same entity that

filed the application in Case No. 2003-00326. KCWSD was originally created as Knott

County Water and Sewer District, in February 1999 by a resolution of the Knott County

Fiscal Court. On April 16, 2003, KCWSD filed Articles of Incorporation with the

Kentucky Secretary of State's office, and later filed a Certificate of Assumed Name

whereby Knott County Water andSewer, Inc., assumed thename of Knott County Water

and Sewer District,

Response l.b. According to the February 1999 Knott County Fiscal Court Resolution,

KCWSD was to be governed and operated under the rules and procedures established

under KRS Chapters 74 and 220. It appears that in April 2003 when the Articles of

Incorporation were filed, KCWSD filed the form Articles of Incorporation for a nonprofit

corporation which state that it is doing so pursuant to KRS Chapter 273. (A copy of the

Articles of Incorporation, the Resolution of the Knott Fiscal Court and the minutes firom

the Knott Fiscal Court meeting are attached to this response). Based on the records

available, includingthe petition and the resolution for the creation, it is presumedthat the

proper procedures were followed in creating KCWSD.

u

aki+ / -t-a-iREGULAR MEETING

FEBRUARY 10-, 19?9

PSC Request 1Page 3 of 11

pl

- DfjlMEMBERS PRESENT - COUNTY JUDGE EXECUTIWE - DONNIE NEWSOMEMAGISTRATE DIST. 1 - HASKEL RITCHIEMAGISTRATE DIST. 2 - RONNIE-ADAMSIWGtlSTRATE DIST. 3 - RAY BOLENMAGISTRATE DIST. 4 - JAMES HUFF

AGENDA:

C. APPROVAL OF MINUTES - RAY BOLEN- MADp THE MOTION -TO APPROVETHE MINDTES OF THE PREVIOUS MEETINGl. JAMES HUFF SECOND,ALL VOTE YES. MOTION CARRIES.

D. TREASURER'S REPORT - RAY BOLEN MADE THE MOTION TO APPROVETHE TREASURER'S REPORT. JAMES HUPF| SECOND. ALL VOTE YES,MOTION carries.

f

E. BUDGET AMENDMENTS - FIRST READINGS j- HASKLE RITCHIE MADETHE MOTION TO APPROVE THE FIRST REfÎNG. RONNIE ADAMSSECOND. ALL VOTE YES. MOTION CARP

F. NEW BUSINESS

1. CATHY GUESS - NO MOTION MADE

2. DAVID COOLEY - USA WASTE - DID NC

IBS.

I APPEAR.

3. APPOINTMENT OF DOG WARDEN - RAY BOLEN MADE THE MOTOPNTO APPOINT ROGER HICKS. RONNIE ADAMS SECOND. ALL VOTEYES. MOTION'CARRIES.

4.

5.

9.

KNOTT COUNTY WATER AND-SEWER DISTRICT - RAY BOLEN.MADETHE MOTION TO APPROVE A SPECIAL piSTRICT TO PROVIDEWATER AND SEWER SERVICES FOR KNOTT CO. AS SITED IN THE

ATTATCHED RESOLUTION TO THE. MINUTES. JAMES HUFF SECOND.ALL VOTE YES. MOTION CARRIES. |PERSONNEL - HIRING OF BILLING SPECIALIST - RAY BOLEN MADE

THE MOTION TO HIRE MALANIE LITTLip. JAMES HUFF SECOND.ALL VOTE YES. MOTION CARRIES. \

rjiiiPERSONNEL - HIRING 0 PART-TIME JAIL EMPLOYEE - RAY BOLENMADE TEE MOTION TO HIRE CAROLYN .kiCKLES: RONNIE ADAMSSECOND, all'VOTE YES. MOTION CARRIES.

PERSONNEL - HIRING OF ROAD - RAY BOLEN MADE THE MOTIONTO BIR£:R0GER SERUM AND DOUGLAS bPARKHAN AT ?6;-e6/HR.RONNIE ADAMS SECOND. ALL VOTE YES. MOTION CARRIES.

PERSONNEL - HIRING CP EMT'S " RONNIE ADAMS MADE THE MOTIONTO EIRE BRANDON R. THOMAS AND DZ^LAS L. ANDERSON 6$7.3a/HR. RAY BOLEN SECOND. AiC.L VOTE YES. MOTIONCARRIES.

SHERIFF'S TAX AUDITS - 1996AND 1TWrg -motion TO REIMBURSE TO THE106".'37 FOR OVERPAYMENTS SHOWN TBRO HIS 1996 AND" 1997AUDITS, RAY BOLEN SECOND. ALL iVOTE YES. MOTION CARRIES.

997 - RONiaE ADAMS MADE

HOTT COUNTY SHERIFF

10. OLD VOTING MACHINES - DECLARE SURPLUS - RONNIE ADAMSISPOSAL OP ALL OLDRITCHIE SECOND. ALL VOTE

MADE THE MOTION TO APPROVE THE COBSOLET VOTING MACHINS,YES. MOTION CARRIES.

HASI^L

11. COUNTY ROAD SYSTEM ADDITIONS - lAY BOLEN MADE THE MOTIONTO ADD 6 SPOTS TO 911 SYSTEM'.&T.T. VOTE YES. MOTION-CARRIES.

mSKEL RITCHIE SECOND..

12.

13.

14.


BID OPENING - EQUIPMENT LEASES - BONNIE ADAHS HADE THE HOTIONTO APPROVE HAYNE SUPPLY'S EQUIPtffiNTS BID ON A BACKHOE.JAMES HUFF SECOND. ALL VOTE YES EXCEPT POR.HASKLE RITCHIEVOTES NO. MOTION CABBIES.

RONNIE .ADAMS MADE THE .MOTION TO APPROVE |«HAYNE SUPPLY'S BIDFOR A GRADER-. JAMES HUFF SECOND. ALL VOTE YES. MOTIONCABBIES.

BID QPBNING-ROADNAY/ROADnAY SHOULDER REPAIR - RAY BOLEN MADETHE MOTION TO ACCEPT AND SPLIT EQUALLY -PREMIER CONSTOCTION'SBID AND DON'S ESCAVATING BID ON ROADNAY SHOULDER REPAIR.IF EITHER' COMPANY -DOESN'T MANT TO PARTICIPATE THE NHOLE JOBWILL BE GIVEN TO-THE OTHER PARTY.

VOTE YES. HOOÔN CARRIES.JAMES HUFF SECOND. ALL

APPOINTMENT OF FUNDS RECEIVING AGENT - BAY BOLEN MADE THEHOTION TO APPOINT EDDIE CAMPBELL. BONNIE ADAMS SECOND. ALLVOTE YES. MOTION CARRIES.

15. CREATION OF EMERGENCY MANAGEMENT AGENCY p RONNIE ADAHS MADE THEMOTION TO APPROVE. JAMES HUFF SECOND. ALL VOTE YES. MOTION

CARRIES.

16.

17.

18.-

G.

NEW JUSTICE CENTER - RONNIE ADAMS MADE T^ MOTION TO APPROVETHE RESOLUTION. JAMES HUFF SECOND. ALL VOTE YES. MOTION CARRIES.SEE ATTATCHED.

CLAIMS LIST - JAMES HUFF MADE THE MOTlOl^ TO APPROVE THE CLAIMSLIST AS PRESENTED. RAY BOLEN SECOND,. AjLL VOTE YES. MOTIONCARRIES.

TRANSFERS - RAY BOLEN MADE THE MOTION Ip APPROVE ALL TRANSFERS.JAMES huff SECOND. ALL VOTE YES. MOTIO|H CARRIES.COMMENTS FROM CITIZEN'S - HASKSL RITCHII^-MADE. THE MOTIONTO LEASE A LOT BESIDE THE COUNTY 0U(AGE |FOR'$200 A MONTH.JAMES HUFF SECOND. ALL VOTE YES. MOTION CARRIES.

MEETING ADJOURNED.

JUDGE EXECUTIVE - DONNIE NEWSOHE

MAGISTRATE DIST. 1. HASKEL RITCHIE

MAGISTRATE DIST. 2. RONNIE ADAMS

MAGISTRATE DIST. 3. RAY BOLEN

MAGISTRATE DIST. 4. JAMES HUPP

&v,r. .r .-immm- -.v-.

2-{0-99

ARESOLUTtONESTABLrSHING AND CREATINGA SPECrAL DISTRICT TO PROVIDE WATER,AND SEWER

SERVICES TO THE RESIDENTS OF KNOTTCOUNIX KENTUCKY

BE IT RESOLVED BY THE KNOTT COUNTY FISCAL COURTAS FOLLOWS;

WHEREAS, the legislature ofthe Commonwealth of Kentucly has

delegated responsibility to the local governmental units to adopt mid

and resolutions to take action promoting the health, safety and geners

of KnottCounty,Kentuckyand,

WHEREAS, many rural areas of Knolt County do not

water and suitable sanitary sewer septic systems to the meet the need

residents of those areas, and,

WI-IERHAS, the lack ofsuch organized water and sew:ersystems has lead to

extremelycritical environmental problemssuch as pollutionto the streams, rivets and aquifers,

which furtlier creotes contaminated drinking water in Knott Coimty, Kentucky,

NOW, THEREFORE, BEIT RESOLVED BYTHEKNOTT COUNTY

FISCAL COURT that there is herebycreateda special district to be hnownas THE KNOTT

COUNTY WATER AND SEWER DISTRICT, and shall be govemea and operated under the

rules and procedures established under KRS Chapter 74, relating.to vj'ater districts and KRS

Chapter 220 relating tosanitatfcn districts.

mplement ofdmaiices

I welfare of the citizens

ave adequate potable

of the citizens and


n

n

n

ThBtthis special iUstrtct IS created for thepurpote orprovldinQ county-wi'dc Nvatsr

andsewersystemsInordertojjrovidesafeand edequaie-.potoble watertutdasomiary sewer

s>'stem toadequately dealwitht|iedisposal thereof iiithose aroas of (he County locking In

such systems.

dated this lO***. day ofFebruary, 1999.

Kfjorr COUNTY JtJbQEDQE/EXECUTJVE

Aês. NAYS:

The vote takenon said Rosolution at theRegularMeetingof the fCnoH County*

Fito&l Court on Februaty 10'^ 1999^ the results being 66 shotvm above.

tt/ic 0* Txs Fife/fs of /4tT7

Multi-page document. Select page: 12 3 4


http://apps.sos.ky,gov/ImageWebViewer/(S(wnq55xi2tnwfzveerih5ob45))/obdbdisplayim... 11/19/2014

n

n

n

Petition for Q^tion ofaCounty-Wide Water &Se

We the undersigned all being properly owners and residents of fC

vcr District

otl CounQrdo hereby

petition llie Knotf County FiscalCourt to Create a County-Wide Water and Sewer District fortiie

residents ofKiiott County.

Nome Address bale

RSC Request 1Page? of 11

W

7-e/t ]). .3^ Ui-i Pty Oee-K.

J4. ^ ^_////

COMWMWeAUtH OP KENTUCKVJOHNY.BMOWNfll

DEGRETARVOFeTATE

0868283.09JohffY.BfBMtltl'

ReMfvedoftd RMOV1BQ003l9:33:40AM

''"ffiw PSC Request 1Page 8 of 11

ARTICLES OP iNCORPCRKTIONNenpnnOffpQRiflHt

ForU)e-.piupeM9. oF foflniflfi t> fMnpr«ffl- .IFr. KMHkFv Fvrtudnt (o KR$' CtiROUr KRS 273, (he im^rslgnedInavpontorfi) hereby .ovbrnK^t) Ote foQowing Atbcies eflncMponUM toOieêaratory ofState forflnng;AnieiR I: 'Thene(ni of(Im osiportUsn (»

KWQgT OOUMTV WATBW ARD flBHBR. IWC.provide waber/wastewater

qn JtiF^pR ryifiXCT pa-ytfpKentucky |i

KY JJ41822JLrfipciilJ

•nd thenemaofthe{hHHtlfiiêtered ^jail at.that cfflco Is Alice- Ri-tchia

Tham<Dtngad<insaoft|ticerperiSilenr»prft)e4wiflfReeia

—p ,n, TO.iASiu, ^ttinanflo

•AiUgI* lb Tho. AwnlMr of-cUractoni ccMOMna flu InlU&l- bond of dkarhMB(n 5BtHierweoF thepsreonawfiQian to soivooethstn^l boani of.djmotonare aa fiitiowa:

Rm A1-.t-anhfM*nl! V 1

nw ittmeo and malltng

^ "wwc" • •

AithtlcVl: Yhenamoaral:maiIinoa(Mre«ief«ati)hiBoipefa!ori&q^|ihof1 t> rt ,2l^Tu£lEi,

•••« •• • — - "W

. KV 41tt99

• — — ivuj

1*84;

\1

i?

HiBiiB

IMS

SyoQUtadbytfitiwowoiatMfavon April 16. 2003ST

—an-pff RÂCte.».wk.

TTi»taeg»Kot>etiB)Biia».WMtN Mi(O}

aoeNU)i(i(Cp

8E£ AtTACHMERtr # 2

AMcq Ritchie-BfSm

Revo

j oemwiie «Mww CtQ noitteê cQcijon eiotg eoiRonifai-

" •' • 'mmm. ^'m.

mcp- Rltj^^^^^^ChajirpareonYMfiMM cemietSMInMMlltmMie SofyteOMr tofllneiM Motln «r(rtwiMiatton.

{BMMKMI MMOI MhltuCCM)

Multi-page dQcument. Select page: 123 4

http://apps.sos.ky.gov/ImageWebViewer/(S(xdr2c] 555poc2y452dlrqw55))/OBDBDispla... 11/19/2014

A1TACMMBNT«:1

KJiOTrCOUNTY W/TSRAND SBW?R DlSTTHCTi INC.

AKm Rttehl», di^fpenon fiSTilUtteCrec^Rsnd Ilasinl KY 41701

DsleUunlM. ViceChair P.0.D(»tJ4 KY 41S42

Do{om Allen 6591'UittiiO^lUBii Httvd RY 41701

MaeAfilftirOwnhs HMy. 721 Box2944 Ku^ KY 41701

RfaenOtbson ^ lOÎI^MerUdllow Mellle KY 4I83S

Multi-page document. Select page: 12 3 4


http://apps.sos.ky.gov/ImageWebViewer/(S(wnq55xi2tawrzveerih5ob45))/obdbdisplayiin... 11/19/2014

2-10-99

A R-ESOLCfTIONfiSTABLlSHINq AND CRgATINOA SPECIALdistrict TOPROVIDE WATER ANDSEWER

SERVrCES TO THE RESIDENTS OF KNOTT COUNTY, KENTUCKY

BEITresolved by THEKNOTT COUNTY FISCAL COURTAS FOLLOWS:

whereas, the kglslaiuft ofthe Cqmnion*>"ealth ofKentuckyhas

responsiblUcy lo thelocal govemrnehtal units toqdopt andimplement ordinances

cnd-resoIuiiptis-to-iaktHieiioivprQmoiingihe-healthraafirtyand-gcncfahwIftre-oPthreitizCTS—

of KnottCoun^. Kentuckyand.

WTIEREaS, maityruralarnss of KnoitCoun^ do not haveodequate potoble

>vnier and suitable sanitaryitwer septicsysiems.tothe rneerthe needaof thecitizensand

residents of those areas, and,

kVHEREAS, lbs lack of such orgenlzed water and sewer systemshas iead to

CKtremely. critical envlrdnmenitlproblemssueh'as.pollulion to the streams;riversand aquifers,

which fUnherereatesepntaminated drinkingwater in KnottCounQ^ Kcniueky,

NOW. THEREFORE.BE TT RESOLVED 3Y THE KNOTT COUNTY

FISCAL COURT thatthere ishereby creatird a special district to be known iDs THE KNOTT

COUNTY WATER ANDSEWER OISTHlCTt andslull begoverned andoperated underthe

(tiles and procedures established under KRii Ch^ter74,relating towater districts and KRS

Chapter220'.retflting to sanitation dispfcts.

Multi-page document. Selectpage: 123 4


http://apps.sos.ky,gov/ImageWebViewer/(S(wnq55xi2tnwfzveerih5ob45))/obdbdisplayim... 11/19/2014

Thatthis Qpseial distitcl lacreated for the purpose ofprovfdind county-wide water

andsewersystemsin orderto providesafetnd edequatepotable waterandO'Sonilaty sewer

s>!Stefh to adequately deal with the disposslthereofiR (hose areas ofthcCounty tacking in

suchsystems.

DATHOlhis iQ''*. dayof-FebruQty» 1999.

l?f?6Tr COUNTY J(JDGEfEXECUTJVE

A>e3. NAVS;

The vote takenonsaid Rcsolutionrat theRegtilar Meeilog ofthe Knott County

Fiscol Cobn onFebruary 10", 1999i (he tesults being asshown above.

Clinic of r>ti Fwe/?i cf l^mrr

Multi-page document. Select page:12 3 4


http://apps.sos.ky.gov/ImageWebViewer/(S(wnq55xi2tnwfeveerih5ob45))/obdbdisplayim... 11/19/2014

PSC Request 2

Page 1 of 1

KNOT! COUNTY WATER AND SEWER, INC.

AND


PSC CASE NO. 2015-00301


REQUEST 2

RESPONSIBLE PERSON: L.J. Turner

COMPANY: Knott County Water and Sewer, Inc.

Request 2. Per The tariffs on file with the Commission for the Knott County

Water and Sewer District, Knott County Water and Sewer District adopted the tariffs of

the Caney Creek Water and Sewer District on February 10, 1999.^ State whether the

tariffs of the Knott County Water and Sewer District on file with the Commission are the

tariffs of Knott CountyWater and Sewer, Inc. If not, indicate why Knott County Water

and Sewer, Inc., does not have tariffs on file with the Commission.

Response 2. Yes, the tariffs on file with the Commission for Knott County

Water and Sewer District are also the tariffs of Knott County Water and Sewer, Inc.

^Knott County Water and SewerDistrict Rates, Rulesand Regulationfor Water and SewerServices, P.S.C.Ky. Adoption Notice No. 1.

PSC Request 3

Page 1 of 1


AND


PSC CASE NO. 2015-00301


REQUEST 3

RESPONSIBLE PERSON: Kyle Smith

COMPANY: Knott County Water and Sewer, Inc.

Request 3. Per the most recent Annual Report of the Knott County Water and Sewer

District on file with the Commission, the utility stated that it was organized on February

10, 1999.'̂ Reconcile the February 10, 1999 date of organization per the Annual Report

with the April 16, 2003 date of incoiporation stated in the application in this case.

Response 3. KCWSD was originally organized on February 10, 1999. However,

KCWSD did not become incorporated until April 16, 2003. (See Exhibits attached to

Response l.b.) Therefore, both dates are actually correct.

*AnnualReport of Knott County Waterand Sewer District to the Public Service Commissionfor YearEnded December 31, 2014, at 10 and 11.

Documents

Goss • Samford - Kentucky cases/2015-00301/20151113_Knott... · Goss • Samford PLLC ^ X Attorneys at Law ... f E. BUDGET AMENDMENTS ... HOTION TO APPOINT EDDIE CAMPBELL. BONNIE