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Home My WebLink About20250303Staff 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