20250213Staff 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: [e-mail]
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