20200723Staff 1-40 to Falls Water.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail:
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BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF FALLS WATER
COMPANY'S APPLICATION TO INCREASE
ITS RATES AND CHARGES FOR WATER
SERVICE
CASE NO. FLS-W.20.03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
FALLS WATER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Falls Water Company (Company) provide
the following documents and information as soon as possible, or by THURSDAY'
AUGUST 13,2020.
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 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 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
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1 JULY 23,2020
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 schedule of all additions and retirements to Plant in
Service since the beginning of 2012, including installation date, account, installed cost, and
estimated depreciable life, that were not included in the *2020 Depr" tab of the 2020 Rate Case
Exhibits.
REQUEST NO.2: Please provide all journal entries related to additions and retirements to
Plant in Service since the beginning of 2012.
REQUEST NO.3: Please provide the running balance and all deposits and withdrawals
from the special plant reserve fund since its inception in Order No. 32663 in Case No.
FLS-W-12-01
REQUEST NO. 4: Please provide a copy of the Company's Chart of Accounts and any
related instruction material.
REQUEST NO. 5: For the Plant in Service additions shown in Columns B through I of
Exhibit 1, please provide the following:
a. The date or expected date when the addition was completed and used and useful in
the sYstem.
b. Invoices, receipts, labor records, and other materials supporting the project costs
listed on pages 2 to 4 of the Application.
REQUEST NO. 6: What are the SCADA functions in the rate base addition shown in
Exhibit 1, Column G?
FIRST PRODUCTION REQUEST
TO FALLS WATER 2 ruLY 23,2020
REQUEST NO. 7: In Final Order No. 33863, the Commission ordered the Company to
"...notifr the Commission when on-site power is installed at the well and the cost of any such
installation." Please provide the following information:
a. The make, model, power rating, equipment cost, and installation costs of this
generator.
b. The date on which the generator became fully operational.
c. Reports of any tests or inspections conducted by the DEQ indicating the status of the
generator (e.g. results of the Company's latest DEQ Sanitary Survey).
REQUEST NO. 8: Please list any additions to rate base or expenses in20l9 that are
related to abandoned projects (such as expenses for engineering and preliminary work for a project
that is stopped before it is completed).
REQUEST NO. 9: Please provide the depreciable life for all assets in Account 334 -
Meters, as well as all documentation and justification for how that length of life was determined.
REQUEST NO. 10: Please summarize all benefits and retirement plans provided to any
classification of Company employees. Please also include any changes that have occurred to
benefits/accruals during the past five years.
REQUEST NO. 11: Please provide the source of the'oldaho Falls wage at years of service
by employee" data used in the "Payroll2020" tab of the 2020 Rate Case Exhibits.
REQUEST NO. 12: Please provide copies of the Company's electrical and natural gas bills
for 2019.
REQUEST NO. 13: Please provide copies of the Company's insurance policy coverage
and any invoices or receipts supporting the Company's insurance expense for 2019 and pro forma
o'Insurance Expense Charge from NWN."
REQUEST NO. 14: Does the Company expect to have any rate case expense for this case?
FIRST PRODUCTION REQUEST
TO FALLS WATER J ruLY 23,2020
REQUEST NO. 15: Please provide the invoice and receipt for the $3 charge per
connection IDWH Fee paid to the Idaho Department of Environmental Quality for 2019.
REQUEST NO. 16: Please provide an itemized list of the services and costs provided by
NW Natural Water as shown in Exhibit 2, Column D. Please provide the calculations of shared
services with NW Natural Water in Excel format with formulas intact. Please include a description
of the Massachusetts method and why it was chosen.
REQUEST NO. 17: Please describe the "non-recurring non-utility income" removed from
net income in Exhibit 2, Column B.
REQUEST NO. 18: Please provide a copy of the Company's property tax bills for 2019
REQUEST NO. 19: Please explain the Company's proposed $15,872 increase in property
taxes in Exhibit 2, Column E.
REQUEST NO.20: Please provide a copy of the Company's federal and state income
taxes for 2019.
REQUEST NO. 21: Please explain the Company's provisions for deferred federal and state
income taxes. Please provide any associated schedules, analyses, or descriptions of the Company's
deferred income taxes.
REQUEST NO.22: Please describe how all overheads (including but not limited to
materials, supplies, vehicles, etc.) are allocated among plant and expense accounts.
REQUEST NO. 23: Please provide a list of any events in2019, such as unplanned outages,
storm damage or use of a diesel generator, that required repairs and/or increased expenses.
REQUEST NO.24: Please provide a list of "out-of-period adjustments" and" extraordinary
items" for the years2}l7 -2020 to date.
FIRST PRODUCTION REQUEST
TO FALLS WATER 4 ruLY 23,2020
REQUEST NO. 25: Please list any prepaid items for 2018 and20l9 showing amounts
posted, vendor names, explanations, and accounts to which these items were booked. Please
include within your response any significant changes to prepaid items occurring or planned to occur
in20l9 arrd2020.
REQUEST NO.26: Please provide all Company bank statements for 2019.
REQUEST NO. 27: Please provide a list of all contractors used in 2017,2018, and 2019.
Please include with this response the contract amount, project ntlme, project location, and
completion date.
REQUEST NO.28: Please provide statements for any company credit cards that include
spending during any part of 2019.
REQUEST NO. 29: Please provide a list of all property that the Company leases to others
and all property that the Company leases from others. Please provide copies of all lease contracts.
REQUEST NO.30: Please list all the Company's long-term debt issuances. Please
include: dates of issuance and expiration, amounts, premiums or discounts, interest rates, dates of
pre-payment, and payment schedules for each issuance.
REQUEST NO.31: Please provide the Company's practice for determining uncollectible
accounts and its policy for customer account deposits and terminations.
REQUEST NO.32: Please provide a current hydraulic model of the Company's water
system.
REQUEST NO.33: Please provide the most recent version of the Company's Drinking
Water Facilities Capital Plan.
FIRST PRODUCTION REQUEST
TO FALLS WATER 5 ruLY 23,2020
REQUEST NO.34: Please provide a copy of the Company's policy for water main
extensions.
REQUEST NO.35: Please provide the following for each meter size for each month from
January 2017 through December 2019
a. Number of Billed Customer Charges
b. Gallons of water provided to customers at no charge as part of the Minimum Charge
c. Gallons sold to customers in excess of the maximum gallons allowed in the
Minimum Charge.
REQUEST NO.36: Please explain why the Company is proposing a larger 38.89%
increase to its commodity charge than the 5.63% to its base charge.
REQUEST NO.37: Please confirm that all projects listed on Exhibit I are complete.
REQUEST NO.38: Column Q of the "Avg Mnthly Bill - Current Rates" tab of the 2020
Rate Case Exhibits shows the average monthly bill for each customer type (Residential,
Commercial, and Multi Family) and meter size. For some customer types, meter sizes, and months,
the average bill is smaller than the monthly basic charge. Please explain this discrepancy in the
following instances:
a. December: Residential5/8" and3l4" Meters
b. January through April, November and December: Residential 1" Meters
c. January through April: Commercial2" Meters.
REQUEST NO.39: For each of the Company's wells, please provide the quantity (gallons)
pumped for each month between January 2017 and December 2019.
REQUEST NO. 40: Please provide the Idaho Department of Water Resources unique
identifier (e.g. Well Tag/D-Tag Number) for each of the Company's wells.
FIRST PRODUCTION REQUEST
TO FALLS WATER 6 ruLY 23,2020
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DATED at Boise,Idatro, tfri, 23 day of July 2020.
Edward
Deputy
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FIRST PRODUCTION REQUEST
TO FALLS WATER
General
7 ruLY 23,2020
CERTIFICATE OF SBRVICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF JULY 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUBST OF Tr{E COMMTSSION STAFF
TO FALLS WATER COMPANY IN CASE NO. FLS-W-2O-03, BY E-MAILING A
COPY TIIEREOF, TO THE FOLLOWING:
K SCOTT BRUCE
FALLS WATER CO INC
2180 N DEBORAH DR
IDAHO FALLS ID 83401
E-MAIL: scott 1 @fallswater.com
ERIC W NELSEN
SR REGI.]LATORY ATTORNEY
NW NATURAL
220 NW 2M AVE
PORTLAND OR 97209
E-MAIL: eric.nelsen@ nwnatural.com
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CERTIFICATE OF SERVICE