20211201Staff 1-7 to Falls Water.pdf

TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.007 4
[phone]
IDAHO BAR NO. 11542
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF FALLS WATER CO.,
INC'S. APPLICATION FOR APPROVAL
TO AMEND CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY NO.236
cAsE NO. FLS-W-21-03
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,
Taylor Brooks, Deputy Attomey General, requests that Falls Water Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, DECEMBER 22, 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 identift the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO FALLS WATER
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I DECEMBER I,2021
RECEIVED
2021 DEC -1 PM 4:05
IDAHO PUBLIC
UTILITIES COMMISSION
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: Please provide a cost breakdown (using the same type of breakdown
provided in Exhibit No. 7 in response to Staff Production Request No. 7, Case No. FLS-W-19-02)
of the Company's recommended system upgrades discussed on page 3 of the Application.
REQUEST NO. 2: Please provide the Company's estimated construction schedule to
install the Company's recommended system upgrades discussed on page 3 of the Application.
REQUEST NO. 3: Please provide the Company's plan for each of the Honey Bee
Acres' water system assets that will be received as a result of this agreement (i.e., wells,
pumping equipment, main line, service lines, and water rights).
REQUEST NO. 4: Please explain who is currently operating the Honey Bee Acres'
water system and who will be operating the system until Honey Bee Acre customers are
connected to the Falls Water water system.
REQUEST NO. 5: Please provide any planned and necessary improvements to Honey
Bee Acres wells.
REQUEST NO. 6: In2018 and 2020, Honey Bee Acres water system tested positive for
coliform. Please provide the causes of the positive tests and a plan for how Falls Water will
prevent future contaminations and/or potential cross-contamination to its current water system.
REQUEST NO. 7: Please provide the proposed accounting treatment, including journal
entries, for the transfer of Honey Bee Estates to Falls Water Co. Inc.
FIRST PRODUCTION REQUEST
TO FALLS WATER 2 DECEMBER 1,2021
DATED at Boise, Idaho, this I't day of Deoember 2021.
i:umiso:prodreqlflsu4l.3tbme prcd req I
FIRST PRODUCTION REQUEST
TO FALLS WATER
General
3 DECEMBER L2A2t
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS lST DAY OF DECEMBER 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STATT' TO FALLS WATER COMPAIYY IN CASE NO.
FLS.W-21-03, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
K SCOTT BRUCE
FALLS WATER CO INC
2I8O N DEBORAH DR
IDAHO FALLS ID 83401
E-MAIL: scottl @fallswater.com
ERIC W NELSEN
SR REGULATORY ATTORNEY
NWNATURAL
250 SW TAYLOR ST
PORTLAND OR 97204
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE