20250306FLS to Staff 1-14_16-22_24.pdf

RECEIVED
March 6, 2025
Preston N. Carter, ISB No. 8462 Idaho Public
Megann E. Meier, ISB No. 11948 Utilities Commission
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
18820527.1 [13988-221
Attorneys for Falls Water Co., Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION Case No. FLS-W-24-02
OF FALLS WATER CO., INC. FOR THE
AUTHORITY TO INCREASE ITS RATES FALLS WATER CO.,INC.'S RESPONSE TO
AND CHARGES FOR WATER SERVICE THE FIRST PRODUCTION REQUEST OF
IN THE STATE OF IDAHO COMMISSION STAFF
In response to the First Production Request of the Commission Staff to Falls Water Co.,
Inc. ("Falls Water" or"Company") dated February 13, 2025, Falls Water submits the following
responses. Responsive documents are available for download using the link provided in the
accompanying email. Confidential responses and documents are subject to the protective
agreement in this case, and are available for download using a password-protected link that will
be provided separately by email. The password will be provided in a third email.
Dated: March 6, 2025.
GIVENS PURSLEY LLP
By C✓
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RESPONSE TO STAFF's FIRST PRODUCTION REQUEST PAGE 1 OF 2

CERTIFICATE OF SERVICE
I hereby certify that on March 6, 2025, I caused to be served a true and correct copy of
the foregoing document to the person(s) listed below by the method indicated:
Monica Barrios-Sanchez ® Email
Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Fax
P.O. Box 83720 ❑ Hand Delivery
Boise, Idaho 83720-0074
[e-mail]
[e-mail]
Adam Triplett ® Email
Deputy Attorney General ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Fax
P.O. Box 83720 ❑ Hand Delivery
Boise, Idaho 83720-0074
Adam.triplett @puc.idaho.gov
Preston N. Carter
RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST PAGE 2 OF 2

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 1
Please provide a copy of the Company's general ledger including all entries from
October 1, 2023 through September 30, 2024.
Response:
Please see FLS-W-24-02 IPUC DR 1 Attachment 1.
FLS-W-24-02
IPUC Staff PR 1
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 2
Please provide copies of all invoices for outside rate case expenses included in the
Company's requested revenue requirement.
Response:
Please see Confidential FLS-W-24-02 IPUC DR 2 Attachments 1 and 2.
FLS-W-24-02
IPUC Staff PR 2
Page 1 of 1

FALLS WATER CO., INC.
CASE No. FLS-W-24-02
RESPONSE TO PRODUCTION REQUEST NO. 2
CONFIDENTIAL ATTACHMENTS I AND 2 PROVIDED UNDER
SEPARATE COVER

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 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.
Response:
Please see Confidential FLS-W-24-02 IPUC DR 3 Attachment 1 .
FLS-W-24-02
IPUC Staff PR 3
Page 1 of 1

FALLS WATER CO., INC.
CASE No. FLS-W-24-02
RESPONSE TO PRODUCTION REQUEST NO. 3
CONFIDENTIAL ATTACHMENT I PROVIDED UNDER
SEPARATE COVER

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 4
Please provide the detailed studies and/or other data used by the Company to evaluate
compensation of employees.
Response:
The Company has not completed any formal compensation studies. However, given the
salaries and benefits for comparable jobs in the area, and the nature of the work our
employees are responsible for, we believe the requested salaries are reasonable and
justified.
Compensation at the City of Idaho Falls water department is comparable to Falls
Water's compensation (please see FLS-W-24-02 IPUC DR 4 Attachments 1 and 2).
Because the City of Idaho Falls offers a pension plan for its employees and the
Company does not, the City's salaries alone understate the attractiveness of
employment with them by prospective job candidates.
Institutional knowledge is very important, knowing the layout of the systems and the
location of infrastructure requires spending significant time on the job. So even an
experienced new operator must undergo extensive training.
The Company has an aging employee base. Wages need to be competitive to attract
new and younger employees that will remain with the Company and build a career in
the water industry with Falls Water.
The office work involved with Falls Water is also difficult. Unlike a typical office
administration job, the Company's office employees are responsible for complicated and
extensive regulatory reporting, administering a billing system that issues about 7,100
bills a month, and fielding customer service calls and inquiries. Falls Water's regulatory
reporting requirements are extensive; for instance, we must produce sanitary surveys
for each individual water system. Most other regulatory reporting to the IDEQ is also
FLS-W-24-02
IPUC Staff PR 4
Page 1 of 2

required to be done on a system-by-system basis. When customers have billing
questions, our employees must be able to determine and analyze the issue and then
respond to the customers in a timely way, not just follow a customer service script. This
requires familiarity with the billing software and Falls Water's tariffs as well as a
willingness and ability to solve problems and work out the math behind billing issues.
For these reasons, the office work is significantly more multifaceted than the typical City
of Idaho Falls administrative position.
The small size of Falls Water's staff means that when any one employee takes sick
leave or paid time off, the other employees are forced to put in significant extra effort. It
also means that the institutional knowledge any one employee would take with them if
they were to leave the Company's employment is significant. So, it is extremely
important for us to limit unnecessary employee turnover. For all these reasons, we
believe our employees' salaries are reasonable and justified.
FLS-W-24-02
IPUC Staff PR 4
Page 2 of 2

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 5
Please provide a list of all plant additions that have occurred from 2023 through 2025.
Response:
Please see FLS-W-24-02 IPUC DR 5 Attachment 1.
FLS-W-24-02
IPUC Staff PR 5
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 6
Please provide depreciation schedules for each plant-in-service item included in the
Company's proposed rate base.
Response:
Please see Confidential FLS-W-24-02 IPUC DR 6 Attachment 1 (which contains
customers' addresses).
FLS-W-24-02
IPUC Staff PR 6
Page 1 of 1

FALLS WATER CO., INC.
CASE No. FLS-W-24-02
RESPONSE TO PRODUCTION REQUEST NO. 6
CONFIDENTIAL ATTACHMENT I PROVIDED UNDER
SEPARATE COVER

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 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.
Response:
Please see FLS-W-24-02 IPUC DR 7 Attachment 1.
FLS-W-24-02
IPUC Staff PR 7
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 8
Please provide the Summary Plan Descriptions for any employer sponsored retirement
plans.
Response:
Please see FLS-W-24-02 IPUC DR 8 Attachment 1.
FLS-W-24-02
IPUC Staff PR 8
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 9
Please indicate whether the Company has a 401 k matching policy and what
percentage, if any, the Company matches.
Response:
The Company's 401 k retirement plan through Paychex is a safe harbor plan that has a
Company matching policy. The Company matches employee contributions at 100% for
the first 3% of the employee contributions. The Company matches the employees'
contribution at 50% for the next 2% of the employees' contribution. In total, the
Company will match 4% of the employees' wages if the employees contribute 5% of
their pay.
FLS-W-24-02
IPUC Staff PR 9
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 10
Please provide the details of the life insurance policies that the Company provides for its
employees.
Response:
The Company pays for a basic term life insurance policy for each employee. The policy
amount is based on the annual salary of the employee with a payout cap of $100,000.
FLS-W-24-02
IPUC Staff PR 10
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 11
Please provide a list of all vehicles owned by the Company and include the in-service
dates and end of depreciable life dates.
Response:
Please see FLS-W-24-02 IPUC DR 11 Attachment 1.
FLS-W-24-02
IPUC Staff PR 11
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 12
Please provide a mileage log of all vehicles owned by the Company.
Response:
Please see FLS-W-24-02 IPUC DR 12 Attachment 1.
FLS-W-24-02
IPUC Staff PR 12
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 13
Please detail the Company's process of recording debt as uncollectible/bad debt.
Response:
The Company's process for uncollectible/bad debt is as follows:
1. When a customer terminates service and moves out of the service area, the
unpaid balance remains on the books for two billing periods after the final billing.
The customer will continue to receive a monthly billing statement of the final
balance owed. These are mailed to the last known address of the customer.
2. If the balance remains unpaid, the Company will call the customer to remind
them of the unpaid balance and possibly collect it at that time or make an
arrangement for payment. The customer is also notified that the balance will be
turned over to a collection agency if it remains unpaid.
3. If the customer cannot be contacted directly, the unpaid balance is turned over to
a collection agency for collection. The unpaid balance is at that time removed
from the customer's account and booked as a bad debt.
4. If the customer pays the collection agency, the amount of the payment is
reversed as a bad debt on the customer's account and the payment is applied.
The uncollectible/bad debt is recognized at the time it is written off.
FLS-W-24-02
IPUC Staff PR 13
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 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
Response:
Please see FLS-W-24-02 IPUC DR 14 Attachment 1.
FLS-W-24-02
IPUC Staff PR 14
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 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.
Response:
The systems owned and operated by Falls Water Co., Inc. have separate Facility
Planning studies. The Falls Water system study was completed in 2019 and will be
updated in 2025. The Morningview and Taylor Mountain Water systems' facility studies
were completed and approved by the Idaho Department of Environmental Quality
(DEQ) in 2024. Digital copies of all three studies accompany this response as FLS-W-
24-02 IPUC DR 16 Attachment 1.
The Facility Planning studies contain the information requested. The studies contain
information about the system as of the time the studies were created. The following
information can be found in the corresponding section of each study:
Falls Water Study:
1. Existing Conditions of the system are found in Section 2.0
a. Description of Existing Water System in Section 2.3
b. Existing deficiencies are found in Section 2.6
2. Future conditions of the system are found in Section 3.
a. Forecast of demand is found in Section 3.2
b. Hydraulic model analysis is found in Section 3.4.
FLS-W-24-02
IPUC Staff PR 16
Page 1 of 2

c. Drinking water improvements needed for a minimum 20-year period is found
in Section 3.5.
3. Water right reserve capacity memo is found in Appendix C.
Morningview Study:
1. Existing system information is found in Chapter 3.
2. Water requirements are found in Chapter 4.
a. Demand
b. Consumption
c. Peaking factors
d. Water production
e. Future water demands
3. Water supply and storage information is found in Chapter 5
4. Peak hour and maximum day demand information is found in Chapter 6
Taylor Mountain Study:
1. Existing Conditions of the system are found in Section 2.0
a. Description of Existing Water System in Section 2.3
b. Existing deficiencies are found in Section 2.6
2. Future conditions of the system are found in Section 3.
a. Forecast of demand is found in Section 3.2
b. Hydraulic model analysis is found in Section 3.4.
c. Drinking water improvements needed is found in Section 3.5.
3. Water right reserve capacity memo is found in Appendix B.
FLS-W-24-02
IPUC Staff PR 16
Page 2 of 2

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 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)
Response:
Please see below:
Falls Water's Wells:7100030
Well #1 — E0007128 Township 2N, Range 38, Section 14, Southwest 1/4
Well #2 — E0007131 Township 2N, Range 38, Section 14, Southwest 1/4
Well #4 — E0007130 Township 2N, Range 38, Section 14, Southwest 1/4
Well #5 — E0007132 Township 2N, Range 38, Section 11, Southwest 1/4
Well #6 — E0007129 Township 2N, Range 38, Section 14, Southwest 1/4
Well #8 — E0008065 Township 2N, Range 38, Section 10, Southeast 1/4
Well #9 — D0048514 Township 2N, Range 38, Section 10, Southeast 1/4
Well #10 — D0073750 Township 2N, Range 38, Section 2, Northwest 1/4
FLS-W-24-02
IPUC Staff PR 17
Page 1 of 2

Well #11 — D00841000 Township 2N, Range 38, Section 9, Northwest 1/4
Taylor Mountain's Wells:7100023
Well #1 — E0007186 Township 1 N, Range 38, Section 21, Southeast 1/4
Well #2 — E0007187 Township 1 N, Range 38, Section 28, Northeast 1/4
Morningview's Wells:
Well #1 — E0006772 Township 4N, Range 39, Section 30, Northeast 1/4
Well #2 — E0006771 Township 4N, Range 39, Section 30, Northeast 1/4
Well #3 — D0062972 Township 4N, Range 39, Section 30, Northwest 1/4
FLS-W-24-02
IPUC Staff PR 17
Page 2 of 2

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 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.
Response:
Please see FLS-W-24-02 IPUC DR 18 Attachment 1.
FLS-W-24-02
IPUC Staff PR 18
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 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.
Response:
Please see FLS-W-24-02 IPUC DR 19 Attachments 1-3.
FLS-W-24-02
IPUC Staff PR 19
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 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.
Response:
Please see FLS-W-24-02 IPUC DR 20 Attachments 1-3.
FLS-W-24-02
IPUC Staff PR 20
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 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.
Response:
Please see FLS-W-24-02 IPUC DR 21 Attachments 1-3.
The higher water loss during the winter months is most likely due to older meters in our
system. The older meters are impeller style meters that are not very accurate at low
flows which are prevalent during the winter months. We are currently working to replace
all of the older impeller style meters in our system over the next few years. We have
scheduled 738 meters for replacement in 2025. We replaced 250 meters in 2024.
During the summer when customers are irrigating their lawns the meters are more
accurate with higher flows. The meter replacements will be a magnet field reading meter
that can start registering flows at 0.03 gpm.
FLS-W-24-02
IPUC Staff PR 21
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 22
Please provide a copy of the Company's latest Idaho Division of Environmental Quality
Sanitary Survey.
Response:
The most recent Sanitary Surveys for the Company's three systems are provided as
FLS-W-24-02 IPUC DR 22 Attachment 1.
FLS-W-24-02
IPUC Staff PR 22
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
FLS-W-24-02
IN THE MATTER OF FALLS WATER CO., INC.'S APPLICATION FOR AN ORDER
AUTHORIZING INCREASES IN THE COMPANY'S RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO
Data Request Response
Witness/Preparer: Scott Bruce
Telephone: [phone]
Email: [e-mail]
Request No.: FLS-W-24-02 IPUC DR 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.
Response:
To develop, manage, and execute capital projects in a cost-effective and least-risk
manner, Falls Water Co., Inc. first identifies a deficiency that will require capital
investment either through maintenance and operations, through IDEQ Sanitary Surveys,
or through Facilities planning. The Company then defines the project scope and
objective, determining what resources, personnel, equipment, and materials might be
needed. The Company analyzes potential options for achieving the project objective by
conducting a base feasibility process which looks at design options, and cost estimates
to identify the most cost-effective and least-risk approach. A budget is determined with a
breakdown of major project components and a closer look is taken at these individual
parts to identify potential opportunities for cost reductions. Falls Water Co., Inc.
researches potential materials and service providers to ensure we are receiving the
most competitive pricing options. We then enter the procurement phase where we
collect competitive bids, and review vendor or service contracts to minimize any
potential cost risk. Upon executing the contract, we begin scheduling via a previously
established project calendar that assists us in identifying milestones and monitoring
progress to minimize or eliminate change orders or cost increases and other risks.
Monitoring the progress also allows us to ensure quality control across all aspects of
construction. Finally, upon completion we review the project costs to ensure alignment
with quotes and financial expectations. The Company currently does not have a written
policy or procedure documenting the process.
FLS-W-24-02
IPUC Staff PR 24
Page 1 of 1