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HomeMy WebLinkAbout20250213Staff 1-24 to FLS.pdf RECEIVED Thursday, February 13, 2025 11:34:47 AM IDAHO PUBLIC UTILITIES COMMISSION ADAM TRIPLETT DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334- 0318 IDAHO BAR NO. 10221 Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF FALLS WATER CO., ) INC.'S APPLICATION FOR AN ORDER ) CASE NO. FLS-W-24-02 AUTHORIZING INCREASES IN THE ) COMPANY'S RATES AND CHARGES FOR ) WATER SERVICE IN THE STATE OF ) FIRST PRODUCTION IDAHO ) REQUEST OF THE COMMISSION STAFF TO FALLS WATER COMPANY, INC. Staff of the Idaho Public Utilities Commission,by and through its attorney of record, Adam Triplett, Deputy Attorney General, requests that Falls Water Company, Inc. ("Company") provide the following documents and information as soon as possible, but no later than THURSDAY, MARCH 6, 2025. This Production Request is to be considered as continuing, and the Company is requested to provide,by way of supplementary responses, additional documents that it, or any person acting on its behalf, may later obtain that will augment the documents or information produced. Please provide answers to each question, supporting workpapers that provide detail or are the source of information used in calculations, and the name,job title, and telephone number of the person preparing the documents. Please also identify the name,job title, location, and telephone number of the record holder. FIRST PRODUCTION REQUEST TO FALLS WATER COMPANY, INC. 1 FEBRUARY 13, 2025 In addition to the written copies provided as response to the requests,please provide all Excel spreadsheets and electronic files with formulas intact and enabled. REQUEST NO. 1: Please provide a copy of the Company's general ledger including all entries from October 1, 2023 through September 30, 2024. REQUEST NO. 2: Please provide copies of all invoices for outside rate case expenses included in the Company's requested revenue requirement. REQUEST NO. 3: Please provide the salary percentage increases for each employee and/or position for the years 2020 through 2025. Please list the implementation dates, as well as the percentage increase. REQUEST NO. 4: Please provide the detailed studies and/or other data used by the Company to evaluate compensation of employees. REQUEST NO. 5: Please provide a list of all plant additions that have occurred from 2023 through 2025. REQUEST NO. 6: Please provide depreciation schedules for each plant-in-service item included in the Company's proposed rate base. REQUEST NO. 7: Please provide a list of, and the quantity of, chemicals purchased for the years 2018 through 2025 with associated unit cost price ranges for each year. REQUEST NO. 8: Please provide the Summary Plan Descriptions for any employer sponsored retirement plans. REQUEST NO. 9: Please indicate whether the Company has a 401k matching policy and what percentage, if any, the Company matches. FIRST PRODUCTION REQUEST TO FALLS WATER COMPANY, INC. 2 FEBRUARY 13, 2025 REQUEST NO. 10: Please provide the details of the life insurance policies that the Company provides for its employees. REQUEST NO. 11: Please provide a list of all vehicles owned by the Company and include the in-service dates and end of depreciable life dates. REQUEST NO. 12: Please provide a mileage log of all vehicles owned by the Company. REQUEST NO. 13: Please detail the Company's process of recording debt as uncollectible/bad debt. REQUEST NO. 14: Please provide up-to-date and separate geo-spatial system maps that outline all contiguous water utility systems operated by the Company. The map should include the location and elevation of major equipment including wells, distribution piping, storage tanks, booster pumps, shut-off valves, meters, fire hydrants, water treatment equipment, etc. NOTE: Please provide this map in electronic format(pdf) which can be scaled and enlarged to identify all aspects of the system. REQUEST NO. 15: Please provide a thorough and complete description of the water system including the following details regarding the system as applicable: a. The depth, width, length, capacity, construction materials of each well (including backup wells, if any), and length of time in service. b. The make, model, type, and rating of each well pump motor, and length of time in service. c. The make, model, capacity, and limit switch settings of each pressurized storage tank, and length of time in service. d. The make, model, capacity, and limit switch settings of each unpressurized storage tank/reservoir, and length of time in service. e. The make, model, and rating of each booster pump and motor, and length of time in service. FIRST PRODUCTION REQUEST TO FALLS WATER COMPANY, INC. 3 FEBRUARY 13, 2025 f. The make, model, and capacity of all water treatment equipment, and length of time in service. g. The year, make, model, and capacity for backup generation supporting the well pumps, and length of time in service. Indicate if the generation has an Automatic Transfer Switch or if it must be manually started. h. The distribution piping line size and materials specified in the installation, and length of time in service. REQUEST NO. 16: Please provide detailed information related to the capacity and sizing of the system and the ability of the system to meet historical and future system peak demands. Provided information should include not only capacity or constraints of/or within the system, but also consumption and consumption at peak periods. Please provide necessary workpapers in spreadsheet(e.g., Microsoft Excel) format with formulas intact. REQUEST NO. 17: For each well used by the water system, please provide the following: a. The Idaho Department of Water Resources ("IDWR")Well Tag Number that is currently on-file with the IDWR. b. Location(Township, Range, Section, and Tract) REQUEST NO. 18: Please provide the monthly power bills indicating the amount of electricity(kWh)used and corresponding electricity cost (in US Dollars) for each well and booster pump from January 2019 through December 2024. Please provide your responses in spreadsheet(e.g., Microsoft Excel) format with formulas intact. REQUEST NO. 19: Please provide the monthly metered amount of water(gallons) pumped from each well. from January 2019 through December 2024. Please provide your responses in spreadsheet(e.g., Microsoft Excel) format with formulas intact. FIRST PRODUCTION REQUEST TO FALLS WATER COMPANY, INC. 4 FEBRUARY 13, 2025 REQUEST NO. 20: Please provide the monthly metered total customer water usage data (gallons)by customer types from January 2019 through December 2024. Please provide your responses in spreadsheet(e.g., Microsoft Excel) format with formulas intact. REQUEST NO. 21: Please provide an estimate of total unaccounted water losses due to leaks,wasted water, etc. by month from January 2019 through December 2024. Please provide your responses in spreadsheet(e.g., Microsoft Excel) format with formulas intact. REQUEST NO. 22: Please provide a copy of the Company's latest Idaho Division of Environmental Quality Sanitary Survey. REQUEST NO. 23: Please provide the average monthly pressure data in the main distribution line from January 2019 through December 2024. Please provide your responses in spreadsheet (e.g., Microsoft Excel) format with formulas intact. REQUEST NO. 24: Please describe the Company's methodology for developing, managing, executing, and completing Capital Projects in a least cost manner. Please provide a copy of all Company policies and procedures documenting the process_ DATED at Boise, Idaho, this 13th day of February 2025. Adam Triplett Deputy Attorney General I:\Utility\UMISC\PRDREQTLS-W-24-02 PR#I.docx FIRST PRODUCTION REQUEST TO FALLS WATER COMPANY, INC. 5 FEBRUARY 13, 2025 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE ON THIS I DAY OF FEBRUARY 2025, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO FALLS WATER COMPANY, INC., IN CASE NO. FLS-W- 24-02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING: PRESTON N CARTER MATT ROWELL GIVENS PURSLEY LLP MANAGER OF WATER RATES AND 601 W BANNOCK ST REGULATORY BOISE ID 83702 NW NATURAL E-MAIL: prestoncartergpivenspursle .com 250 SW TAYLOR ST. stephaniew& ig'venspursle .com PORTLAND, OR 97204 E-MAIL: matt.rowell@nwnatural.com K. SCOTT BRUCE FALLS WATER CO., INC. 2180 NORTH DEBORAH DRIVE IDAHO FALLS, ID 83401 E-MAIL: scottl&fallswater.com PATRICIA JORDAN CERTIFICATE OF SERVICE