20200827Staff 41-50 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
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 FALLS WATER )
COMPANY'S APPLICATION TO INCREASE )CASE NO.FLS-W-20-03
ITS RATES AND CHARGES FOR WATER )
SERVICE )SECOND PRODUCTION
)REQUESTOF 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 AttorneyGeneral,request that Falls Water Company (Company)provide
the followingdocuments and information as soon as possible,or by THURSDAY,
SEPTEMBER 17,2020.
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.
SECOND PRODUCTION REQUEST
TO FALLS WATER 1 AUGUST 27,2020
RECEIVED
2020 August 27 PM 5:50
IDAHO PUBLIC
UTILITIES COMMISSION
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.41:Please provide a list of all rental properties and lease expenses.Please
include copies of all leases and provide the contractual monthlyexpenses.
REQUESTNO.42:Please provide the fixed asset re-valuation summary completed after
the sale to Northwest Natural Water Company on September 14,2018.Please include with your
response all workpapers and supporting documentation.
REQUESTNO.43:Please explain the Company's policy for awarding bonuseslincentive
payments to Staff and the criteria to receive the bonuses.Please explain how this bonuslincentive
policy benefits customers.
REQUESTNO.44:Please provide an invoice and description of the Company's $159
advertising expense in 2019.
REQUESTNO.45:Please provide the followingfor Well Number 10:
a.copies of all related contracts and invoices;
b.an explanation for the purpose of each contract/invoice;and
c.Invoices for the Funds Transfer found in account 343 -Tools and Equipment.
REQUESTNO.46:Please provide copies of all related contracts and invoices for Lincoln
Road Phase I and Lincoln Road Phase 2.
REQUESTNO.47:Please provide copies of all Company Credit Card Statements for
2018.
SECOND PRODUCTIONREQUEST
TO FALLS WATER 2 AUGUST 27,2020
REQUESTNO.48:Please provide copies of invoices for purchases larger than $4,000
found in the followingaccounts for 2019:
a.311 -Pumping Equipment;
b.340 -Office Furniture and Fixtures;
c.343 -Tools and Equipment;and
d.345 -Power Operated Equipment.
REQUESTNO.49:Please provide the bill of sale for the followingvehicles and explain
the reason for each sale:
a.20 12 Ford Pickup -$44,450.00;and
b.2007 Cadillac Escalade -$10,484.44.
REQUESTNO.50:Please provide the bill of sale for the purchase of the following
vehicles and explain the reason for each purchase:
a.2007 Peterbilt Dump Truck -$41,024.34;
b.Equipment Hauling Trailer -$15,000.00;and
c.2019 Chevy 2500 -$42,981.10.
DATED at Boise,Idaho,this 2 day of August 2020.
Edward J.w ll
Deputy AttorneyGeneral
i.umisc pmdreqlnsw203ejmc pod req2
SECOND PRODUCTION REQUEST
TO FALLS WATER 3 AUGUST 27,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF AUGUST 2020,
SERVED THE FOREGOINGSECOND PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOFALLSWATERCOMPANYINCASENO.FLS-W-20-03,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
K SCOTT BRUCE ERIC W NELSEN
FALLS WATER CO INC SR REGULATORYATTORNEY
2180 N DEBORAH DR NW NATURAL
IDAHO FALLS ID 83401 220 NW 2*AVE
E-MAIL:scottl @fallswater.com PORTLAND OR 97209
E-MAIL:[e-mail]
SECRE ÀRY
CERTIFICATEOF SERVICE