20170427Staff 21-24 to FLS.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 334-03s7
IDAHO BAR NO. 7956
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
FALLS WATER COMPANY,INC. FOR
AUTHORIZATION TO BUILD A NEW WATER
SOURCE, AND ACCESS TO THE SPECIAL
PLANT RESERVE ACCOUNT
CASE NO. FLS-W.17.01
THIRD 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,
Brandon Karpen, Deputy Attomey General, request that Falls Water Company, Inc. (Company;
Falls Water) provide the following documents and information as soon as possible, by
THURSDAY, MAY 18,2017.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
THIRD PRODUCTION REQUEST
TO FALLS WATER
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I APzuL 27,2017
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 21: In response to Production Request No. 7, the Company supplied an
Excel spreadsheet titled "Well 10 Estimate to Well 9 Costs." Staff reviewed the spreadsheet and
observed that a number of values within it are to be determined. Additionally, the spreadsheet
does not include a$98,252.00 generator cost listed in Exhibit 6-3. Please provide an updated
spreadsheet with formulas intact that includes values that are now known or to be determined
items. Include values for any known items not detailed in the original such as the above
mentioned generator.
REQUEST NO. 22: The Company's Response to Production Request No. 1 provided
the electronic spreadsheet showing the calculations supporting the deposits to Account
No. 127.1 - MXU Project Depreciation and Savings for 2016. Please provide the same
spreadsheets to support the calculations for each year (by month) since inception of the fund
through 2017 as available.
REQUEST NO. 23: The Company's Response to Production Request No. 4 provided
the detailed transactions for Account No. 127.1 as of December 31, 2015 (Exhibit 1-1) and
December 31,2016 (Exhibit 2-1). Please provide similar exhibits for each of the other years
since inception of the fund through20IT as available.
REQUEST NO. 24: The Company's Response to Production Request No. 6 provided
project financing details. Please provide additional details for the owner funds:
a. Are the short-term owner funds a request for debt authority?
b. Will the owner funds be temporarily treated as owner paid-in capital?
c. Will these funds be returned (reduced) once cash becomes available from operations?
THIRD PRODUCTION REQUEST
TO FALLS WATER 2 APRIL 27,2017
Dated at Boise,Idaho, this "ZVry day of April2llT.
Attorney General
Technical Staff: Kevin Keyt/2|
Terri CarlocW22-24
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THIRD PRODUCTION REQUEST
TO FALLS WATER J APRIL 27,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27fi DAY OF APRIL 2017,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO X'ALLS WATER COMPAIYY, INC., IN CASE NO.
FLS-W-I7.OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
K SCOTT BRUCE
FALLS WATER CO INC
2180 N DEBORAH DR
IDAHO FALLS ID 83401
E-MAIL: scott1 (Efallswater.com
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CERTIFICATE OF SERVICE