COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC … cases/2014-00255...Jun 16, 2015  · Chris Crunfp^u / STATEOF KENTUCKY COUNTY OF FRANKLIN SUBSCRIBED AND SWORN to before me by Chris

RECEIVEDCOMMONWEALTH OF KENTUCKY

BEFORE THE PUBLIC SERVICE COMMISSION ^yPUBLIC SERVICE

In the Matter of: COMMISSION

APPLICATION OF BULLITT UTILITIES, INC. )

FOR A CERTIFICATE OF CONVENIENCE AND ) CASE NO 2014-00255. NECESSITY AND SURCHARGE FOR SAME )

MOTION TO INTRODUCE TESTIMONY OF CHRIS CRUMPTON

Comes Bullitt Utilities, Inc. ("Bullitt Utilities"), by counsel, and for its Motion to

Introduce Testimony of Chris Crumpton, states as follows:

1) On May 7, 2015, an Informal Hearing was held in the above-styled action, and during

this Informal Hearing, the parties were advised that the formal hearing may be scheduled for June

9, 2015,depending upon the availability of the members of the Public Service Commission

("Commission"). The Order scheduling the Formal Hearing on June 9, 2015, was issued by the

Commission on May 15, 2015.

2) On May 11,2015, Chris Cumpton, an engineer with BlueStone Engineers, Inc., was

advised that the Formal Hearing in the above-styled action had been scheduled to take place on

June 9, 2015. Mr. Crumpton was requested to keep this date open so that he could be available

to testify at the Formal Hearingon behalf of Bullitt Utilities. (See Attachment A)

3) On May 12, 2015, Mr. Crumpton responded by electronic mail indicating "I can keep

June 9'̂ open as needed." (See Attachment B)Thereafter, Mr. Crumpton issued his final

correspondence concerning the cause of the failure of the Hunters Hollow WastewaterTreatment

Plant ("WWTP").

4) On June 4, 2015,Mr. Crumpton's Pre-Filed Testimony was prepared and provided to

him for review and comment. Mr. Crumpton provided comments to his Pre-Filed Testimony,

1

and it was then finalized, reviewed and signed by Mr. Crumpton, and filed with the Public

Service Commission on June 5, 2015. (See Attachment C) Mr. Crumpton's Pre-Filed

Testimony was also listed as Exhibit 43 on Bullitt Utilities' Supplemental Exhibit List. Mr.

Crumpton's Pre-Filed Testimony provided the Commission with the report reflecting that the

failure of the Hunters HollowWWTP appears to result from lack of reinforcing steel in the outer

foundation section of the WWTP and was not caused by lack of maintenance.

5) On June 8, 2015, Mr. Crumpton was provided with a brief outline ofthe questions that

he would be asked during his testimony before the Commission. Theoutline was provided to

Mr. Crumpton by electronic mail after work hours.

6) TheForma! Hearing in the above-styled action was held on June 9, 2015, andMr.

Crumpton failed to appear at the hearing to testify. Efforts were made to contact Mr. Crumpton

by calling his office telephone number, his cell phone number and by sending text messages to

his cell phone. Mr. Crumpton could not be reached because he was in London, Kentucky, out of

cell phone range. (Affidavit of Chris Crumpton, paragraph 8) Since Mr. Crumpton was not

available for cross-examination, the Commission sustained the Attorney General's objection to

the introduction of Mr. Crumpton's Pre-Filed Testimony.

7) As indicated in Mr. Crumpton's attached affidavit, the only other case in which Mr.

Crumpton has testified before the Commission is An Investigation ofExisting and Future Service

ofBullitt Utilities, Inc., PSC Case No. 2014-00163. Mr. Crumpton testified in person, and no

Pre-Filed Testimony was introduced on his behalf. (Affidavit of Chris Crumpton, paragraph 3)

8) As indicated.in his Affidavit, Mr. Crumpton did not intentionally miss the Formal

Hearing in the above-styled action. Mr. Crumpton mistakenly believed that since Pre-Filed

Testimony was filed on his behalf, his presence at the Formal Hearing was not required. Mr.

Crumpton was advised that there was a chance that he would not have to testify at the Formal

Hearing, and he misunderstood and believed that he did not have to attend the Formal Hearing.

(Affidavit of Chris Crumpton, paragraph 6) Mr. Crumpton was never advised that he did not

have to attend same.

9) The record in the above-styled action will not be closed until on or about June 23,

2015, when the most recent invoices issued by the companies that provided temporary

wastewater treatment for the flow from the Hunters Hollow collection system are to be filed into

the record.

10) Mr. Crumpton's testimony is critical to enabling the Commission to have a

comprehensive understanding of the failure of the Hunters Hollow WWTP, and supports the

granting of the requested surcharge.

11) Since Mr. Crumpton's failure to attend the Formal hearing was due to a

misunderstanding and was inadvertent, Bullitt Utilities hereby moves the Commission to grant

the Motion to Introduce the Pre-Filed Testimony of Mr. Crumtpon and allow Bullitt Utilities to

present, for cross examination purposes, the testimony of Mr. Crumpton at: a) a hearing

scheduled before the Commission; b) a hearing held before a Hearing Officer appointed by the

Commission; or c) through the deposition of Mr. Crumpton. Allov/ing Mr. Crumpton's

testimony to be introduced through one of these three ways would enable the Commission's

decision on Bullitt Utilities' Application for Surcharge to be made on a full record, including Mr.

Crumpton's report concerning the failure of the Hunters Hollow WWTP.

12) Granting Bullitt Utilities' Motion to allow the introduction of Mr. Crumpton's

testimony will notprejudice the rights of anyotherparty to the case, as Commission Staffand the

Attorney General would have the right to cross examine Mr. Crumpton during a) a hearing before

the Commission, b)a hearing before a Hearing Officer, orc)his deposition. Nor will granting

the motion impact the ongoing treatment of the wastewater generated bythe Hunters Hollow

collection, as BCSD is currentlyaccepting the flow for treatment.

lespectfiill^ubmitted.

Lobert C. Moore

HAZELRIGG & COX, LLP415 West Main Street, f FloorP. O. Box 676

Frankfort, Kentucky 40602-0676(502) 227-2271

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was served by hand deliveryon Jeff Derouen, Executive Director, Public Service Commission, 211 Sower Blvd., P.O. Box615, Frankfort, Kentucky 40602 and by first clap-nraihafid^ail on Gregory T. Dutton andJennifer Black Hans, Assistant Attorney General 1024 CapitahCenter Drive, Suite 200,Frankfort, Kentucky 40601-8204, on this the 16'̂ ^y ofJun^^l5.

obert C. Moore

Joioif B. Baoohm.o?

Bobebt C. Moors

Ma-p-b- R. BREN-OEI-aiXX

Ha-zexbligg 8c Cox, LLPATTOSNEYS AT LAW

415 West Main Street, Suite l

P.O. Box 676

Fsajtkeoht, Kentucky 40602-0676

May 11,2015

Dyxe L. Hazbibxog (I88i-1970)

Louis Cox U907-l97i)

Fax: (502) 675-7158

Telephone: (502) 227-2271

Via Electronic Mail: Chris(a)Blitestoneeneineers.comChris CrumptonBluestone Engineers, PLLC3703 Taylorsville RoadLouisville, Kentuclcy 40220-1354

Via Electronic Mail: Larrvs76(a)Bellsoiith.net

Larry Smither

P.O. Box 137

Crestwood, Kentucky, 40014

Re: Bullitt Utilities, Inc. ("Bullitt Utilities") - Hunters Hollow

Dear Chris and Larry:

Theformal hearing ontheApplication forSurcharge Filed byBullittUtilities withthePublicService Commission is tentatively scheduled tobeheard on June 9, 2015. Ifpossible, please keepthis date open so that you will be available to testify on behalf of Bullitt Utilities. I will becontacting you todiscuss this matter, but wanted togive you a "heads up" so that you could attemptto keep this date open for the time being.

Thank you foryourattention to thismatter and please contact me should youwish todiscusssame.

RCM/neb

cc: Bullitt Utilities, Inc.

urs trul

febert C. Moore

/I

—jRobert IVIoore

To: Chris CrumptonSubject: RE: correspondence from Robert C. Moore attached

ChriSj Thanks^ Rob Moore 051315

Original MessageFrom: Chris Crumpton rmailto:chris(abluestoneengineers.com1Sent: Tuesday^ May 12, 2015 6:19 PMTo: Nancy Bailey; Robert MooreCc: 'Larry Smither'Subject: RE: correspondence from Robert C. Moore attached

I can keep June 9th open as needed.

Chris Crumpton, P.E.BlueStone Engineers, PLLC502-292-9288

Original MessageFrom: Nancy Bailey fmailto:nbailevtalhazelcox.comiSent: Monday, May 11, 2015 2:11 PMTo: chrisObluestoneengineers.com

Cc: Larry SmitherSubject: correspondence from Robert C. Moore attached

Original MessageFrom: scanner(8hazelcox.com rmailto:scanner<fl)hazelcox.comlSent: Monday, May 11, 2015 2:56 PMTo: Nancy BaileySubject:

This E-mail was sent from "RNP87A01B" (Aficio 2045e).

Scan Date: 11.65.2015 13:55:31 (-0500)Queries to: scanner0hazelcox.com

3

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COMMONWEALTH OF KENTUCKY RECEIVEDBEFORE THE PUBLIC SERVICE COMMISSION JUfj 05

In the Matter of; PUBLIC SERVICECOMMISSION

APPLICATION OF BULLITT UTILITIES, INC. )FOR A CERTIFICATE OF CONVENIENCE AND ) CASE NO 2014-00255NECESSITY ANDSURCHARGE FOR SAME )

PRE-FILED TESTIMONY OF CHRIS CRUMPTON

1. What is your name and business address?

Answer: My name is Chris Crumplon, and my business address is Bluestone

Engineers, PLLC, 3703 Taylorsville Road, Louisville, Kentucky 40220-1354.

2. Are you an engineer, and, if so, please state yourengineeringqualifications.

Answer: Yes. I obtained my degree as a Civil Engineer from the University of

Kentucky in 1995. Since that time, 1have become licensed as a Professional Engineer, andam

licensed to practice as an engineer in Kentucky, Indiana, Illinois, Ohio, and Georgia. 1have

provided engineering design services for wastewaier treatment systems and wastewater treatment

plants for entities located in Kentucky, including the Louisville and Jefferson County

Metropolitan SewerDistrict, the Oldham County Environmental Authority and others.

3. Are you familiar with the Hunters Hollow Wastewater Treatment Plant site and

how did you become familiar with it?

Answer: Yes. Bullitl Utilities retained me to conduct an investigation of the

Hunters Hollow collection system and I have prepared a Sanitary Sewer Evaluation Studyof that

collectionsystem. Additionally, I was contacted to conduct an investigationof the Hunters

Hollow WWTP after it failed on or about March 29, 2015.

ArmCHMENT_^

4. Did you infact conduct an investigation ofthe Hunters Hollow WWTP, and did

you issue a report containing ilie details ofyour investigation?

Answer: Yes. As stated inAttachment A to myPre-Filed Testimonyi [ inspected

the Hunters Hollow WWTP site on several occasions and myconclusions after conducting this

investigation are set forth in Attacliment A.

5. In your opinion, was the failure ofthe Hunters Hollow WWTP due toadesign

flaw or due to lack of maintenance?

Answer: Based onmyinspection of the concrete foundation ofthe Hunters Hollow

WWTP, and the determination that there was no reinforcing steel in the outer foundation area,

the failure ofthe WWTP appears tobe the result ofthis design flaw. In my opinion, lack of

maintenance was not acause or contributing factor of the failure of the Hui^rs Hollow WWTP.

Chris Crunfp^u /

STATE OF KENTUCKY

COUNTY OF FRANKLIN

SUBSCRIBED AND SWORN to before me by Chris Crumpton, this the 5"^ day of June,

My Commission expires:

OTARY PUBLIC

^ RespectKill;^subniittcd,

t c- A?'/Robert C. Moore

HA2ELRIG0 & COX, LLP

CERTIFICATE OF SERVICF.

I hereby certify that a tnie and correct copy ofthe foregoing was ser\'cd by hand deliveryon Jeff Derouen, Executive Director, Public Service Commission, 211 Sower Blvd., P.O. Box615, Frankfort, Kentucky 40602 and United States Mail and electronic mail to Gregor>'J. Duttonand Jennifer Black Mans; Assistant Attorney GenprnlHoi?Capital Center Drive. Suite 200,Frankfort, Kentucky 40601-8204. on this the 5'̂ dav of/une, 201:^ /

M, .obert C. Moore

BlipieStoneEngln^ftrj, PUC

Mr.' Robert C. MooreHazelrigg&Cox.lLP4lS West Ma|n StreetP.O. Box676

Frankfort, KY 40602-0676

SUBieCT:

Dear Mr. Moore;

Hunters Hollow Treatment PlantFfeldInspection for Steel TankBufijh Gqurity, ken'tyckv

TPAU7WEIN.eNC3ir>ipeB!N!

Apfll30,2014

This letter serves as a summary of a structural field' Inspect'ton and review bf sjieCondlliohs for the recent taiik failure at.the Hunleiis HdDdw Tfeatrheh't Plant in BuliltlCounty, Kentucky;

.The field review noted tl^ multlpre sections of the steel aeration tank separated fromWlh the concrete foundation and <;larifl^ tankage spiilirig contents of the treatment'facility across the site and parldng area. 'A temporary• treatment Vysiem has been',(rtslajled on-site to curreiiily hapdle tf^a.t/nept of $s much 00^ ^.possllrie. SesUriti.s ofthe steel aeration tarik-wcre observed laying at different' localions just outside thetank's orlfilrta! perimeter .with ?gme sections Intoct while others had been cut Iq allowsections to be.stacked r^eareach other.

Inspection of the existing weWs.dtd not identify that structural tank failure occurred atthese vrtid Iqjritj, a.s^ji bei.Seen iq ^e 'atuched phqtp^pHl •;th.e sl^el tahii pieceswere Wel^d ^ a piece of 8* chahnel t6 Join the tank- iHat was dfl '̂riiily set Iri acpndriete .fpundaUbh about .4- deep fbn th?..thahnel). . thesel ileel tSnk' fj'idtes, b'hdchannel were observed to have been ripped out of Ihe.cqricr.ele fpurrdatlon of rhe'tank.Add't.'.qnajly, jarge chiihkS of concrete fpundatjjiJrt wfrg scattered aboyt the site andafdundthesteellankplec^thafhadbeenstacked.

•Since the lower portion-of the tank receives a higher structural load and based onreview of the channel pul'led frorh the concrete" fbundallor>, wb have istimated thatse^atlorl.rhust have occurred at the bottom of the" tank and fro'ni 'a possible rupture orfdjlpre directly at the concrete fquhdaWcn leyej; This could hay? been" caused fromcorraele cracking, or Insufftctent 'sub-surface cdncHtions thai alloWs differentialsettlement. It was noted from talking wlpi the trea^ent plant qperatpr that this'siie •has typically bpen Wentlfied as awet ^swampy" area adja'ceht.tp ttiis existing strea'm.

Wo were unable to Inspect .the tank copcfetp feundatibn in detail "due to the greaitamount ofsludge that was covering the entire foundation section. Once this materfalhas been cleared from the sjte addtlonal.jfup^tipn of the concrete fbundatloh 5!?hrecommended. Ad.drtlqnally, testing by a geqtechniMi engineer to,determine concretefpun.dalibh thickness, soil testing beneath the slab, .arid depth to rock Is also

ATTACHMENT /A

.Eh'9ln0ef$-.:pLlC

recommended. 7hji•coufd,al$o deterrnln'e.if iny'grOuhdwaler Is 'Resent underneath-the slab.. Additionally, once the. sludge has been removed specific areas of the .concretefpiipdatro.n can be further Inspected.tp (dehtify if the exact Idotlon of the failure:can.bedetermined.

As .can be expected, the portion of the exterior wall of the, .main aerailun look stillsUhding was" more heaVfly reinforced i.h the ja.tea cdnnecte'd tp the digesWf ^n.k andIhtenor.-darlfieF taril^ as well as being wpporicd by the stalrs-and .connecting ca^alks-

this section is still $tSndlit| and pieces of the st.eej tinjtf^eparotcd fiomthis section at" the welds diie to the force of ihb wall.being.pulled oiif ofthe coiitfeie•foundation.

Agairi,.vy.e ,;ecprnriierTd that additional; InsRection and testfrig be performed; mOrder toidcnfify.m'dre details of the failure.'

Ifypy:hav4'q\iestl6ti'$ please do hot liejItaje.lQ.^ve me acall af(s02):292-9'288.

Sincerely,

•Christopher Crumptoo/Gyll Engineer .Robert T, Trautweln/S.tVucty'ral Engineer

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.review pfo^Ssjgxhlbit ." '̂? 'Varf;fle3aj'yiew"^ the.sne.>ppj.orito-.rhe..failure.l6'oking easr•tpvyffds 0tue,:L[^.8~^ .-s• ,.. . ,.

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The mwt notable area;of damage;is shown the.soy^hMst.guadrant" of the/lankage ~thi?-..afea-looks',tp.h^ve;:.rfcejved.:tHe..mprt;damage:albn^•cpmparedjq/^st ofy>e perimeter fquhda\ionV-fh^ beseeh in EKKibit'Erf''' l ' ' '' ' , . ' . "Most im^rtanl to note.ls ^at-:none;$f;the;exterior pp,rtjon Qf-.lhe;con(cr;etp,'fpuh^^^^^at-held.the^steekcha In place Jnclud^;^^ remfpicqrheini OSgh failure,

these•.^crftj.r^^ cbrigele" s;iab se'̂ aratcd Intp^plirai 3* arid smilfer s^a^o^ tliat

awav.frbm:thetarik:fdundatibh-^^

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' ' ;be'seen {n the'attached p/iofpg.rqjj^^ Theiteel tgHk- pieces'

iqiindattq^ ihe channel)r. Ti^se:steel i^kpieces ond chp^ne)'Were.out of ^^o fohcfptfi fg^undqijor^^^

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? =! .i. •FrpmJrisp^lQn of ihe-.lnleriof slab,cqndlUph.{yj;iV;gi>p^);:a>.Wel);a5;iri$^bie fpundatlon seglon (piece$.thai ha3^:brdi5.n.oU^^^

.are: scartered'. aboi^ the site).,thiVf^is;;lh|lJCatlj^^:/oy^?!3tJon;between^•thelnte>^o^•anW.e«ertpr^scctlqrtsJ^^^^^^ ..'chahnel.wn<l!nctalii»ri (-|»» Tvliihir 'rt* inr '

•foundaUbn.fr6ni;the ^ channel but^rd-separatcb alpngitheisbcan'Xre>. frprn .iheJnterior foundation and. slab"during 'the faiiyfe^^^^^ the plant. ?tejosjjikeiy•lhi.s;!oauncd;at^ foundaUoh's .v^akertvpG/ntiaipngsthc. perhneieri^Which-

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'fiis dl$.ws^edipreyjq.u$_ly, ad^ditionai,tMtinj.fnay be perforrned by-a geotechnicai engineerto .cKC?yate theei:ijrilng slab M-^SpedRed lo^atio^.to compare depth and thicknesses ofthe.'roncfeTe's(ab:and foundadbn.-Kowevef-.ihrs ma'y not be heeded stnda it Is-iippare'ntthat: ; • " ••'•" V'

1. Along the tee'fior.of the concrete•.fdund.atlph .that -the iab. ari'dvfdUhd^tibnthickness varies. ' "

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Exhibit "A" - Hunters Hollow WWTP(looking East)

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BlueStoneEnBtnocrj. PUC

Exhibit "^" - Interior Concrete Slab(looking East)

BlueStoneEnglncors. PLLC

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Exhibit "C" - Interior Concrete Slab

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BlueStoneEnQineors. PLIC

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able Exterior

dation Widths

Exhibit "D'' - Concrete Slab Edge &Variable Exterior Foundation Widths

BlueStoneEngineois. PLLC

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Exhibit "G" - Foundation Section(shear plane failure)

BlueStone.rnglncert'. PlLC

nginee/s. PUC TRAUTWEINEb/PINEeBlbIG

Mr. Robert C. Moore

Hazelrigg & Cox, LLP415 West Main StreetP.O. Box676

Frankfort. KY 40602-0676

SUBJEa:

Dear Mr. Moore:

Hunters HollowTreatment PlantAddendum for Field Inspection &Analysis forStructural Slab/FoundationBullitt County, Kentucky

May 20, 2015

As discussed In our follow-up summary letter dated June 22. 2014 for structuralinspections of the Hunters Hollow Wastewater Treatment* Facility. ar\d based on thereview of the concrete foundation, the lack of reinforcing steel in the outer foundationsection would not have been identified from normal inspection or maintenanceactivities. Therefore, lack of maintenance of the facility does not appear to be a causeor contributing factor ofthe failure ofthe Hunters Hollow WWTP.

If you have questions please do not hesitate to give me acall at (502) 292-9288.

Sincerely.

Christopher T.CrumptonProject Engineer

In the Matter of:

COMMONWEALTH OF KENTUCKYBEFORE THE PUBLIC SERVICE COMMISSION

APPLICATION OF BULLITT UTILITIES, INC. )FOR A CERTIFICATE OF CONVENIENCE AND ) CASE NO 2014-00255 'NECESSITY AND SURCHARGE FORSAME )

AFFIDAVIT OF CHRIS CRUMPTON

Comes the Affiant, Chris Cnimpton, and afterbeing duly sworn, states as follows;

1. My name is Chris Cnimpton, and my business address is BIuestohe-Ensineers '

PLLC, 3703 Taylorsville Road, Louisville, Kentucky 40220-1354.

2. I obtained mydegree as a Civil Engineer from the University of Kentucky in

1995. Since that time, I have become licensed as a,Professional Engineer,.and am licensed to .

practice asan engineer in Kentucky, Indiana, Illinois, Ohio, and Georgia. I have provided

engineering design services for wastewater treatment systems and wastewater treatment plants

for entities located in Kentucky, including tlie Louisville and Jefferson County Metropolitan

Sewer District, the Oldham County Environmental Authority and others.

3. That I have testified before the Kentucky Public Service Commission on only one

occasion, and that was at the Formal Hearing in the case ofAn Investigation ofExisting and

Future Service ofBullilt Utilities, Inc., PSC Case No. 2014-00163. Prior to this case, I have

never filed Pre-Filed Testimony.

4. That on May 11, 2015,1 received correspondence from Robert Moore, counsel

for BullittUtilities, advising me and Larry Smither that that theFormal Hearing in this casehad

beenscheduled to take placeon June9, 2015. Mr. Moore's letter requested me to keep this date

open so that I would be availableto testify at the Formal Hearingon behalfof Bullitt Utilities.

(See Attachment A) I advised Mr. Moore byelectronic mail on May 12, 2015, that "I can keep

June 9'̂ open as needed." (See Attachment B)

5. Tliat the report concerning the cause of the failure of the Hunters Hollow

Wastewater Treatment Plant ("WWTP") was finalized during late May 2015, and discussed with

Mr. Moore. The report shows that the failure of the Hunters Hollow WWTP appears to result

from lack of reinforcing steel in the outer foundation section of the WWTP and was not caused

by lack of maintenance.

6. That on June 4, 2015, Mr. Moore forwarded a document called Pre-Fiied

Testimony of Chris Crumpton to me for review and comment. Freviewed the document and • . -

discussed it with Mr. Moore. The document was then finalized and sent back to me for

signature. Mr. Moore stated that I may not have to testify since the Pre-Filed Testimony was

being filed into the record, and I misunderstood'and believed that I did not have to attend the

June 9, 2015, Formal Hearing.

7. That because I did not think that I had to appear at the June 9, 2015, Formal

Hearing, I scheduled a meeting in London, Kentucky for that day. I did not speak with Mr.

Moore on June 8, 2015, but he did forward an email to me after work sending me a dr^ of ray

proposed testimony at the hearing. I did not see this email until I returned to the office on June

10,2015.

8. I did not receive any calls of communications from Mr. Moore on his office on

June 9, 2015, because I did not have cell phone coverage in London, Kentucky.

9. That my failure to appear at the Formal Hearing was inadvertent and due to a

misunderstaDding, and Iwill make myself available to testify before the Commission, aHearing

Officer appointed bytheCommission orbyDeposition.

10. Further Affiant Sayethnot.

STATE OF KENTUCKY

COUNTY OF FRANKLIN

SUBSCRIBED AND SWORN to before me by Chris Crurapton, this thei^ day of June,2015.

My Commission expires: 2,/ 2 '̂Z^ / f

N6TARY PUBLIC ^

submitted.

Lobert C. Moore

HAZELRIGG & COX, LLP415 West Main Street, FloorP. O. Box 676

Frankfort, Kentucky 40602-0676(502) 227-2271

CERTIFICATE OF SERVTCE

I hereby certify that a true and correct copy oftheforegoing was served byhand deliveryon JeffDerouen, Executive Director, Public Service Commission, 211 SowerBlvd.,P.O. Box615, Frankfort, Kentucky 40602 andUnited States Mail and electronic mail to Gregory T. Duttonand Jennifer Black Hans, Assistant Attomey General/]024^apital Center Drive, Suite 200,Frankfort, Kentucky 40601-8204, on this day\fJune^lS.

Lobert C. Moore

tJoax B. BAtrosMAN

Robbbt C. Mooss

Mask R. Bsej^gbuhax

Ha.zei.kigg & Cox, LLPATTORNEYS AT LAW

415 West Main Steeet, Suite l

P.O. Box 676

FhAITKFOBT, KeNTIJCICY 40602-0676

May 11,2015

Dyke L. Hazexeiog (1881-1970)Louis Cox (1907-J971)

Fax: (502) 875-7158TbiephONe: (502) 227-2271

Via ElectronicMail: Chris(^Bluestoneen^ineers.comChris CrumptonBluestone Engineers, PLLC3703 Taylorsville RoadLouisville, Kentucky 40220-1354

Via Electronic Mail: Larrvs76(a)Bellsouth.net

Larry SmitherP.O. Box 137

Crestwood, Kentucky, 40014

Re; BuUitt Utilities, Inc. ("Bullitt Utilities") - Hunters Hollow

Dear Chris and Larry:

The formal hearing ontheApplication for Surcharge Filed by Bullitt Utilities with thePublicService Commission istentatively scheduled to be heard on June 9, 2015. Ifpossible, please keepthis date open so that you will be available to testify on behalf of Bullitt Utilities. I will becontacting you to discuss this matter, but wanted to give you a"heads up" so that you could attemptto keep this date open for the time being.

Thank you for your attention tothis matter and please contact me should you wish todiscusssame.

RCM/neb

cc: Bullitt Utilities, Inc.

Lobert C. Moore

ATTACHMENT /I

Robert Moore /4~c^0h-^To: ^ Chris CrumptonSubject: RE: correspondence from Robert C. Moore attached

Chris, Thanks, Rob Moore ©51315

Original MessageFrom: Chris Crumpton rmailto:chris0bluestoneengineers.comiSent: Tuesday, May 12, 2015 6:19 PMTo: Nancy Bailey; Robert MooreCc: 'Larry Smither'Subject: RE: correspondence from Robert C. Moore attached

I can keep June 9th open as needed.

Chris Crumpton, P.E.BlueStone Engineers, PLLC502-292-9288

Original MessageFrom: Nancy Bailey fmallto:nbailev(8hazelcox.comiSent: Monday, May 11, 2015 2:11 PMTo: chris0bluestoneengineers.comCc: Larry SmitherSubject: correspondence from Robert C. Moore attached

Original MessageFi"om: scanneriahazelcox.com \mailto:scannertahazelcox.com]Sent: Monday, May 11, 2015 2:56 PMTo: Nancy BaileySubject:

This E-mail was sent from "RNP87A01B" (Aficio 2045e).

Scan Date: 11.05.2015 13:55:31 (-0500)Queries to: [email protected]

AITACHMENT 3