20191230Staff 1-13 to Falls Water.pdf

MATT HUNTER RECENED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION i9 DEC 20 AN 10:35
PO BOX 83720
BOISE,IDAHO 83720-0074 .Sl0N(208)334-0318
IDAHO BAR NO.10655
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
FALLS WATER COMPANY,INC.TO AMEND )CASE NO.FLS-W-19-02
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY NO.236 )FIRST PRODUCTION
)REQUESTOF 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 followingdocuments 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
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 informationused 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
and if different the witness who can sponsor the answer at hearing if need be.Reference IDAPA
31.01.01.228.
FIRST PRODUCTION REQUEST
TO FALLS WATER l DECEMBER 20,2019
In addition to the written copies provided as response to the questions,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.1:Please describe how the purchase price of $43,385.50 for the
transfer of distribution assets to the City of Idaho Falls is calculated.
a.Please include a list of components of the purchase price,with a description and
the associated dollar amount.
b.Please include workpapers in Excel,if available.
REQUESTNO.2:Please provide the net book value of the assets being transferred to
the City,by plant account and subaccount.
REQUESTNO.3:Please provide the continuing property records for the distribution
assets being transferred by account number and original cost,accumulated depreciation,and net
book value.
REQUESTNO.4:Please provide Exhibit A and Exhibit C as referenced in the "Asset
Purchase Agreement between Seller and City of Idaho Falls,Idaho"from Exhibit C of the
Application.
REQUESTNO.5:Regarding the Purchase Agreement with the City of Idaho Falls,
please provide a map showing the location of the 12-inch main and 6-inch lateral,includingall
interconnections with the Company's system.
REQUESTNO.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
REQUESTNO.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 entirelyreplaced 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 for 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.
REQUESTNO.8:Please provide Honey Bee Acre's current rates,rate structure and
other charges.
REQUESTNO.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 of the notice.
b.If not,please explain why Falls Water did not notify these customers.
REQUESTNO.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 transferred?
a.If assets will be transferred,please provide a list of the assets and identify if
money will be exchanged for any of the assets.
REQUESTNO.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.If so,please provide copies of these documents.
FIRST PRODUCTION REQUEST
TO FALLS WATER 3 DECEMBER 20,2019
REQUESTNO.12:Were the customers with wells in the proposed service territory
notified of the expansion of the CPCN?
a.If so,please provide a copy of the notice.
REQUESTNO.13:Has Falls Water informed the Area 14 customer of the proposed
transfer?
a.If so,please provide a copy of the notice.
b.If not,please explain why Falls Water did not notify this customer.
Dated at Boise,Idaho,this lo day of December 2019.
Matt Hunter
Deputy AttorneyGeneral
i/utilitylumisc/production requests/flswl9.2mhbe prod req l
FIRST PRODUCTION REQUEST
TO FALLS WATER 4 DECEMBER 20,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20\'H DAY OF DECEMBER 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO FALLS WATER COMPANY IN CASE NO.
FLS-W-19-02,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
K SCOTT BRUCE ERIC W NELSEN
FALLS WATER CO INC SR REGULATORY ATTORNEY
2180 N DEBORAH DR NW NATURAL
IDAHO FALLS ID 83401 220 NW 2ND AVE
E-MAIL:scott l @fallswater.com PORTLAND OR 97209
E-MAIL:cric.nelsen nwnatural.com
SECRETARY/
CERTIFICATE OF SERVICE