20191220Staff 113 to Falls Water.pdf

Street Address for Express Mail:
I133I W CHINDEN BVLD, BLDG 8, SUITE 20I-A
BOISE, ID 83714
Attorney fbr the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
FALLS WATER COMPANY, INC, TO AMEND
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY NO. 236
CASE NO. FLS-W-I9-02
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
FALLS WATER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Gem State Water
Company, LLC (Gem State; Company) provide the following documents and information as
soon as possible, by FRIDAY, JANUARY 10,2020.
This Production Request is continuing, and the Company is requested to provide, by way
ofsupplementary 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 ofthe record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3l .01 .01 .228.
FIRST PRODUCTION REQUEST
TO FALLS WATER
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DECEMBER 20,2OI9
MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. 10655
RECEIVED
i0l9 DEC 20 AH t0: 35
- ' r. -r PiieLICi :, I i-,t COi{lJlSSlON
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In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with fbrmulas activated.
REQUEST NO. l: Please describe how the purchase price of $43,385.50 for the
transfer ofdistribution assets to the City ofldaho Falls is calculated.
a. Please include a list ofcomponents ofthe purchase price, with a description and
the associated dollar amount.
b. Please include workpapers in Excel, ifavailable.
REQUEST NO.2: Please provide the net book value olthe assets being transferred to
the City, by plant account and subaccount.
REQUEST NO. 3: Please provide the continuing property records lor the distribution
assets being transferred by account number and original cost, accumulated depreciation. and net
book value.
REQUEST NO. 4: Please provide Exhibit A and Exhibit C as ref'erenced in the "Asset
Purchase Agreement between Seller and City of ldaho Falls, Idaho" from Exhibit C ofthe
Application.
REQUEST NO, 5: Regarding the Purchase Agreement with the City of Idaho Falls,
please provide a map showing the location of the l2-inch main and 6-inch lateral, including all
interconnections with the Company's system.
REQUEST NO. 6: Regarding the Purchase Agreement with the City of Idaho Falls,
please provide the following:
a. The work that will be needed to disconnect the 12-inch main and 6-inch lateral from
the Company's system.
b. A cost estimate for this work.
c. Verification that the City of Idaho Falls will be paying these costs.
FIRST PRODUCTION REQUEST
TO FALLS WATER 2 DECEMBER 20.2019
REQUEST NO. 7: Please provide a cost breakdown of the estimated upgrades
necessary to serve Honey Bee Acres.
a. Please explain whether the current water system will be entirely replaced or just
the main line.
b. Will the service lines to the customers be replaced? Please explain and describe
planned work.
c. Will the customers be billed under the Line Extension policy for the service lines?
Please provide an explanation lor Falls Water's approach.
d. Will the customers be billed under the Line Extension policy for the main line?
Please provide an explanation for Falls Water's approach.
REQUEST NO. 8: Please provide Honey Bee Acre's current rates, rate structure and
other charges.
REQUEST NO,9: Were Honey Bee Acre's customers noticed of the request for Falls
Water to service Honey Bee Acres and Falls Water's Application to amend CPCN No. 236?
a. If so, please provide a copy oflhe notice.
b. If not, please explain why Falls Water did not notify these customers.
REQUEST NO. 10: Will any Honey Bee Acres assets be transferred to Falls Water if
Falls Water starts providing service to Honey Bee Acres? Specifically, will wells, mains, service
lines, water rights or any other assets be transfered?
a. Ifassets will be transferred, please provide a list ofthe assets and identify if
money will be exchanged fbr any of the assets.
REQUEST NO. 11: Does Falls Water Company have any Memorandums of
Understanding with any of the surrounding cities (other than Idaho Falls), homeowners
associations or municipal water systems?
a. Ifso, please provide copies ofthese documents.
FIRST PRODUCTION REQUEST
TO FALLS WATER J DECEMBER 20,2OI9
REQUEST NO. 12: Were the customers with wells in the proposed service teritory
notified ofthe expansion ofthe CPCN?
a. If so, please provide a copy of the notice.
REQUEST NO. 13: Has Falls Water informed the Area 14 customer of the proposed
transfer?
a. Ifso, please provide a copy ofthe notice.
b. If not, please explain why Falls Water did not notify this customer.
4Dated at Boise, Idaho, this ZO day of December 2019.
Matt Hunter
Deputy Attorney General
i/utilily/umisc/production requcslVflswl9.2mhbe prod r€q I
FIRST PRODUCTION REQUEST
TO FALLS WATER 4 DECEMBER 20, 2019
CERTIFICATE OF SERVICE
ERIC W NELSEN
SR REGULATORY ATTORNEY
NWNATURAL
220 NW 2ND AVE
PORTLAND OR972O9
E-MAIL: eric.nelsen(a)nwnatural.com
SF,CRETAR
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I I'IAVE TIIIS 2O,I'H DAY OF DECEMBER 2019,
SERVED THE F'OREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO FALLS WATER COMPANY IN CASE NO.
FLS.W-I9-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
K SCOTT BRUCE
FALLS WATER CO INC
2180 N DEBORAII DR
IDAHO ITALLS ID 8340I
E-MAIL: scott I @fallswater.com