20190927Staff 1-4 to Falls Water.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83120
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
REO EIV[O
:ii9 SEP 2l [!{ ll:2 |
: , "iid.iiiJ,\t*'n'*
Street Address for Express Mail:
11331W CHINDEN BVLD, BLDG 8, SUITE 2OI.A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
FALLS WATER CO.,INC. FOR APPROVAL OF
ACQUISITION OF THE ASSETS OF THE
WATER BUSINESS OF TAYLOR MOUNTAIN
WATER AND SEWER DISTRICT
cAsE NO. FLS-W-19-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
FALLS WATER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Falls Water Company
(Falls Water; Company) provide the following documents and information as soon as possible,
by FRIDAY, OCTOBER I I, 2019.r
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
person preparing the document, and the name, location and phone number of the record holder
t Staff is requesting an expedited response. If this is problematic, please contact Staffs attorney at [phone]
or karl.klcin @-' puc.iclaho.gov
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY
)
)
)
)
)
)
)
)
I SEPTEMBERZ7 ,2019
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3t.01.0t.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. 1: Please provide a legal description of the property that the Company
proposes to add to the legal description in CPCN No. 236.
REQUEST NO.2: Exhibit No. 6 of Palfreyman's direct testimony provides a map
showing the "Application POU." One parcel, the SW 7+ of NE Y+ sec 29 Township I North
Range 38 East, does not currently appear to be connected to the existing water system. Does the
Company plan to connect this parcel to the Taylor Mountain Water system? If so, how will this
parcel be connected, and what capital improvements will be necessary to make this connection?
REQUEST NO.3: For Taylor Mountain, please provide all financial statements
prepared for estimating the revenue requirement. If not clearly labeled in the workpapers, please
provide assumptions on the cost of capital and annual (or quarterly, if applicable) expected
revenue and costs, including plant in service, book depreciation, tax depreciation, income taxes,
deferred taxes, property taxes, and other items typically included in a discounted cash flow
analysis.
REQUEST NO. 4: For Taylor Mountain, please provide a listing of all plant in service,
along with the in-service dates, original costs, and depreciation rates.
1t-
Dated at Boise,Idaho, this n day of September 2019.
/Ual'
Gr Matt Hunter
Deputy Attorney General
i/utility/umisc/production requests/flswl9. lmhbemmkls prod req I
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 SEPTEMBER 2] ,20T9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF SEPTEMBER 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO FALLS WATER COMPANY IN CASE NO.
FLS-W-19-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
PRESTON N CARTER
CHARLIE S BASER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: prestoncarter @) givenspurrsley.com
charl iebaser @) gi venspursley.com
kendrah @_) gi ve n s pursle\Lco [n
ERIC W NELSEN
SR REGULATORY ATTORNEY
NW NATURAL
220 NW 2ND AVE
PORTLAND OR 97209
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE