20210615Staff 1-16 to FLS.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF FALLS WATER CO.,
INC'S. APPLICATION OF FOR APPROVAL OF
THREE CAPITAL PROJECTS: 1) CREATION
oF A NEW WATER SOURCE,2)
CONSTRUCTION OF A STORAGE TANK, AIID
3) CONSTRUCTION OF A WELLHOUSE
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. FLS-W-21-01
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,
Dayn Hardie, Deputy Attorney General, requests that Falls Water Company ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, JULY 6,2021.
This Production Request is to be considered as 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO FALLS WATER I JLINE I5,2O2I
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: On page 7 of the Application , frnalization of a water right purchase
is mentioned. Please provide details of the water right purchase including cost, size, and
estimated completion date.
REQUEST NO.2: The Schiess & Associates study recommends expanding water
rights. Please explain what actions the Company is taking to obtain additional water rights.
Please include any known cost, size, or estimated acquisition dates. September 2019 Study.
REQUEST NO. 3: Does the Company's recommended alternative-Well #11 plus
storage-require the Company to obtain additional water rights? If additional water rights are
required, please explain any necessary contingencies if the recommended plan is approved by the
Commission and additional water rights were not acquired.
REQUEST NO. 4: Please explain why the developer did not address runoff in the
Taylor Mountain subdivision and why the Company believes it is reasonable to assume the costs
of building a runoff containment solution? Application at 4.
REQUEST NO. 5: Could sizelcapacity for proposed Well #l I be increased from 1,500
GPM to 3,000 GPM to satisff DEQ requirements? Please explain why or why not. Application
at 4.
REQUEST NO. 6: Please explain why construction of Well #l I was paused. Describe
what is required to resume construction. Application at 5.
REQUEST NO. 7: Please explain how the Company has addressed cross-connection
control
FIRST PRODUCTION REQUEST
TO FALLS WATER 2 JUNE I5,2O2I
REQUEST NO. 8: Please explain how the Company has addressed removal of asbestos-
cement pipe. How much asbestos-cement pipe remains in the system? When will it be replaced?
What is the estimated cost?
REQUEST NO. 9: Can the Company's capacity and water rights issues be resolved
through acquisition of any or all the adjacent water systems? Please provide a table that shows
capacity and water rights for each of the systems listed in section 4.2.3 of the Schiess &
Associates Study.
REQUEST NO. l0: Please provide a copy of the Company's Curtailment Plan. If the
Company does not currently have a Curtailment Plan, please provide an explanation of when a
plan will be documented and implemented, how curtailment is currently managed, and how
customers are notified if curtailment is necessary.
REQUEST NO. 11: Please describe the process by which amounts are withdrawn from
the Plant Reserve Account created by Order No. 32663. Please include within your response a
recent accounting entry that includes the date posted, accounts posted, and both the debit and
credit amounts in the transaction.
REQUEST NO. 12: Please describe the process by which amounts are posted to the
Plant Reserve Account created by Order No. 32663. Please include within your response a
recent accounting entry that includes the date posted, accounts posted, and both the debit and
credit amounts in the transaction.
REQUEST NO. 13: Please provide a list of expenditures/withdrawals from the Plant
Reserve Account by year, inclusive of the years2017 through April30, 2021. Please include the
following within your response:
a. The type of expenditure;
b. The reason/justification for the expenditure/withdrawal;
c. Document/transaction/identification number for expenditureiwithdrawal;
d. Dollar amounts and account numbers where posted; and
e. Documentation supporting the expenditure/withdrawal such as an invoice
FIRST PRODUCTION REQUEST
TO FALLS WATER 3 JUNE I5,2O2I
REQUEST NO. 14: Please provide the underlying accounting detail (such as a trial
balance or general ledger) in the Plant Reserve Account for Calendar Years Ending 2019 and
2020.
REQUEST NO. 15: Please identiff how the Company plans to finance the three
proposed capital projects including all details that are currently available.
REQUEST NO. 16: Please provide the detailed source information (vendor bids, cost
estimates, calculations, etc.) associated with each Estimated Cost in Exhibits 2 and 3 of the
Company's Application. Please include within your response the dollar amount for each activity
by vendor, specifically identifring activities performed by the Company and any affiliated
companies or individuals.
DATED at Boise, Idaho, this $b day ofJune 2021.
Deputy Attomey General
i:umisc:prodreq/fl sw2 l. I dhksk prod req I
FIRST PRODUCTION REQUEST
TO FALLS WATER 4 JUNE 15,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I5TH DAY OF JUNE 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO FALLS WATER COMPAIYY, IN CASE NO.
FLS-W-2I-01, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
PRESTON CARTER
60I W BANNOCK ST
BOISE ID 83702
E-MAIL : prestoncarter@ qivenspursley.com
harmonywri ght@ givenspursley. com
K SCOTT BRUCE
FALLS WATER CO INC
2I8O N DEBORAH DR
IDAHO FALLS ID 8340I
E-MAIL: scottl @fallswater.com
ERIC W NELSEN
SR REGULATORY ATTORNEY
NWNATURAL
220 NW 2ND AVE
PORTLAND OR 97209
E-MAIL : [e-mail]
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SECRETAR/----
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CERTIFICATE OF SERVICE