HomeMy WebLinkAbout20250303Staff 25-48 to FLS.pdf RECEIVED
Monday, March 3, 2025 11:38.56 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 ) SECOND 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
MONDAY,MARCH 24, 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.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY, INC. 1 MARCH 3, 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. 25: Please provide detailed workpapers, which calculate the
Company's cost of debt used in the proposed capital structure.
REQUEST NO. 26: Please provide workpapers, which calculate the Company's
weighted average cost of capital using actual debt and equity information.
REQUEST NO. 27: Regarding Exhibit No. 2 (E) "Testing,"please provide invoices for
all testing expenses used to calculate the 9-year averages.
REQUEST NO. 28: Regarding Exhibit No. 2 (H) "Shared Services,"please provide
details of how 2025 budgets are calculated. Please provide documentation of all reasoning of
updated budgets.
REQUEST NO. 29: Regarding Exhibit No. 2 (H) "Shared Services,"please provide an
updated workpaper which calculates each shared service expense category using expenses from
October 1, 2023, through September 30, 2024. For each category,please explain why the actual
amount differs from the 2025 budget.
REQUEST NO. 30: Regarding Exhibit No. 2 (H) "Shared Services,"please provide a
detailed explanation and calculation of how the "mass method percentage"is calculated.
REQUEST NO. 31: Please provide the most current customer count.
REQUEST NO. 32: For the years 2020 through 2025, please provide a list of employee
job titles and job descriptions. Please indicate dates in which an employee left the Company,
whether the open position was filled, date it was filled, and number of qualified applicants for the
position.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY, INC. 2 MARCH 3, 2025
REQUEST NO. 33: For the years 2020 through 2025, please provide dates in which
positions within the Company were created, removed, or reclassified. Please provide detailed
reasoning for each occurrence.
REQUEST NO. 34: Please provide a list of expenses between October 1, 2023, and
September 30, 2024, which occurred from the parent, Company NW Natural.
REQUEST NO. 35: Please provide a list of vendors used for expenses between October
1, 2023, and September 30, 2024, which can be classified as related parties. For each vendor
listed, please detail the relation to the Company or any of its employees.
REQUEST NO. 36: Please provide a list of vendors used for capital additions from
2024 through 2025, which can be classified as related parties. For each vendor listed, please
detail the relation to the Company or any of its employees.
REQUEST NO. 37: Please provide a maintenance log for all vehicles owned by the
Company.
REQUEST NO. 38: Please provide a list of all property the Company leases to others
and all property the Company leases from others. Please provide copies of all lease contracts.
REQUEST NO. 39: Please provide a list of prepaid items from October 1, 2023,
through September 30, 2024. Please list the date, amount, explanation of the prepaid item, and
account in which it was booked.
REQUEST NO. 40: Please provide documentation for the bank service charge terms
and conditions.
REQUEST NO. 41: Please state whether the bank service charge percentage is fixed or
if it fluctuates. Please provide documentation and/or workpapers which support the percentage
used.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY, INC. 3 MARCH 3, 2025
REQUEST NO. 42: Please provide documentation for all active Company insurance
policies.
REQUEST NO. 43: Please provide a list of occurrences of insurance claims made by or
against the Company from October 1, 2021, through September 30, 2024. For each claim,please
provide: date, description of incident, financial impact, whether the incident is included in this
case, and any other useful information.
REQUEST NO. 44: Please provide all transactions and journal entries to the
Company's ground water mitigation deferral account in Excel format. Please included item
name,brief description, cost broken down by month and year for 2022 to date.
REQUEST NO. 45: For the overproduction of groundwater, please provide the
supporting invoices for the total balance of$305,052.
REQUEST NO. 46: Please explain the Company's reasoning for purchasing additional
water rights in March 2025. Additionally,please provide a cost-benefit analysis for each
water right the Company is planning on purchasing in March 2025 and provide supporting
documents of the water right cost estimates.
REQUEST NO. 47: Exhibit 1 (D), Line 10 lists "Water Rights (21.5 Acres x $16,500
including Fees)" for a total amount of$354,750. Please explain what the "Fees" are and please
provide any supporting documents for the total amount.
REQUEST NO. 48: Please provide finalized bill of sale documents for the purchase of
the 21.5 acres of water rights when available.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY, INC. 4 MARCH 3, 2025
DATED at Boise, Idaho, this 3rd day of March 2025.
Adam Triplett
Deputy Attorney General
L\Utility\UMISC\PRDREQ\FLS-W-24-02 PR#2.docx
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY, INC. 5 MARCH 3, 2025
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE ON THIS DAY OF MARCH 2O25,
SERVED THE FOREGOING SECOND 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: prestoncarter(a ig venspursley.com 250 SW TAYLOR ST.
stephaniewggivenspursley.com PORTLAND, OR 97204
E-MAIL: matt.rowell a,nwnatural.com
K. SCOTT BRUCE
FALLS WATER CO., INC.
2180 NORTH DEBORAH DRIVE
IDAHO FALLS, ID 83401
E-MAIL: scottl(kfallswater.com
PATRICIA JORDAN
CERTIFICATE OF SERVICE