20201007Staff 51-60 to Falls Water.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-O3t4
IDAHO BAR NO. 10446
riri;f-tvE'*
?*?.* *';1 -1 96 2: 31
' ' tt:' ,*
,- :, i , ,;r.. ,.ii n:i;l\Hs-'8t+
Street Address for Express Mail:
II33L W 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 FALLS WATER
COMPANY'S APPLICATION TO INCREASE
ITS RATES AND CHARGES FOR WATER
SERVICE
CASE NO. FLS.W.2O.O3
THIRD 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 WEDNESDAY,
ocToBER 28, 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.
THIRD PRODUCTION REQUEST
TO FALLS WATER OCTOBER 7 ,2020
)
)
)
)
)
)
)
)
1
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. 51: Exhibit 2 (Proforma of Ops) shows $6,984 in Training Expenses
booked to Account 675.1in2Ol9. The training expenses for 2018 and2017 were $1,018 and $654,
respectively. Please provide documentation and the Company's rationale for the 586Vo increase.
REQUEST NO.52: In Response to Production Request Nos. 5 and 37, please provide
updated costs on projects listed in Exhibit 1, Column B.
REQUEST NO.53: In Response to Production Request No. 16, please provide the Cost
Allocation Manual filed with the OPUC and WUTC.
REQUEST NO.54: In Response to Production Request No. 16, Attachment l, Row 19 and
Row 21, please provide a detailed cost breakdown of each amount in Column E. Also, include with
your response the workpapers calculating the benefits to Falls Water Company ratepayers.
REQUEST NO.55: Please provide cost savings that Falls Water has realized through 2019
for Shared Services paid to NW Natural. Please provide workpapers with formulas intact detailing
the savings amount and include a list of any positions that have been eliminated as a result.
REQUEST NO.56: Please provide any additional cost savings that Falls Water will realize
during the year 2020 for Shared Services with NW Natural. Please provide workpapers with
formula intact detailing the savings amount and include a list of any positions that will be
eliminated as a result.
REQUEST NO.57: Please provide the yearly percentage pay rate increase by employee
and position since the last general rate case in 2015. Please provide an excel spreadsheet with
formulas intact.
THIRD PRODUCTION REQUEST
TO FALLS WATER OCTOBER 7 ,20202
REQUEST NO.58: Please explain why the amounts booked to Account 675.9 -2012
MXU Proj Mtr Reader Lbr are not booked to Account I27.1 - MXU Project Depr Savings as
ordered in Order No. 32663, page 11.
REQUEST NO.59: Please provide any supporting documentation for the Company's
requested lO.SVo requested return on equity.
REQUEST NO. 60: Please provide the fee schedule for the Xpress Bill Pay Transactions.
Also include a copy of the contract with Xpress Bill Pay.
DATED at Boise, Idaho, this 7ft day of October 2020
s>r(
Edward Je
Deputy Attorney General
i:umisc:prodreq/fl sw20.3ejtnc prod req3
THIRD PRODUCTION REQUEST
TO FALLS WATER 3 OCTOBER ] ,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF OCTOBER 2020,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMI\ISSION STAFF TO FALLS WATER COMPANY IN CASE NO. FLS-W-20-03,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
K SCOTT BRUCE
FALLS WATER CO INC
2180 N DEBORAH DR
IDAHO FALLS ID 83401
E-MAIL: scottl @fallswater.com
ERIC W NELSEN
SR REGULATORY ATTORNEY
NW NATURAL
220 NW 2ND AVE
PORTLAND OR 97209
E-MAIL: eric.nelsen @ nwnatural.com
Y
CERTIFICATE OF SERVICE