20150520Staff 1-5 to Falls Water.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6864
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
FALLS WATER COMPANY INC FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. FLS.W.15-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
FALLS WATER COMPANY,
INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Falls Water Company Inc. (Company, Falls
Water) provide the following documents and information as soon as possible, but no later than
WEDNESDAY, JUNE 10, 2015.
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 identifu the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY INC.MAY 20,20t5
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a list of current customers, in table format, according
to location (i.e., by service area and areas covered under the existing Amended Certificate No.
236), meter class, customer type. Please also provide the date when the Company started
delivering water and started charging fees for water service (i.e., month and year).
REQUEST NO. 2: Please provide the following maps:
l) Plat map(s) of Falls Water service areas showing legal descriptions similar to Exhibit
A, except on a larger scale with legible notations.
Water System Overall Site Plan(s) on a larger scale with legible notations. Please
indicate location of the wells and other facility locations (well house, pumps, valves,
mainline, and distribution lines indicating pipe size, etc.) on the same map. Please
also show the components of the water system that have been built and currently are
being used to provide water service to current customers.
Please show on a separate plat map(s) any areas that are (a) undeveloped, (b) being
supplied with irrigation water, and (c) actively under construction and will require
future water service.
REQUEST NO. 3: In response to Staff Request No. 34 in the FLS W-12-01 case, the
Company withdrew its proposal to create a new schedule for Private Fire Sprinkler and Service.
Staff then recommended that the Company further investigate how many customers have private
fire sprinkler lines for firefighting purposes connected to the Company's distribution System.
Please provide the following:
1) Results of the Company's additional investigations on firefighting-related
connections.
2) A map of the fire hydrant locations.
3) All available fire hydrant testing data.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY INC.
2)
3)
MAY 20,2015
Any correspondence with the Fire Marshall regarding the adequacy of the fire
response system including the number of fire hydrants, the presence of adequate
pressure or other service adequacy issues.
A list of anticipated firefighting services (i.e., fire hydrants and associated
services such as application, inspection, pressure testing, bacteria testing, and
mapping). Please explain.
REQUEST NO. 4: Please provide any water quality and water system issues or
violations identified since the completion of the most recent Sanitary Survey. Please also
provide the status of compliance regarding all issues and/or violations.
REQUEST NO. 5: Please describe and estimate the cost of any major capital
improvements planned during the next three years.
4)
s)
DATED at Boise, Idaho, thisJ 0bauy of May 2015.
Technical Staff: Johanna Bell/l-5
i:umisc:prodreq/fl swl 5. I npjb prod req I
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY INC.
Deputy Attorney General
MAY 20,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF MAY 2015, SERVED
THE FOREGOING F'IRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO FALLS WATER COMPANY,INC., IN CASE NO.
FLS-W-15.01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
K SCOTT BRUCE
FALLS WATER CO INC
2180 N DEBORAH DR
IDAHO FALLS ID 8340I
E-MAIL: scottl @fallswater.com
CERTIFICATE OF SERVICE