20221130Staff 1-8 to Falls Water.pdf

CHRIS BURDTN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03t4
IDAHO BAR NO. 9810
IN THE MATTER OF FALLS WATER CO.,
INC.'S APPLICATION FOR DEFERRAL OF
CERTAIN COSTS
, i'-CItVED
, r 11 itili 30 Pi{ 2: 3 1
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. FLS.W.22-OI
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO FALLS WATER
Staff of the ldaho Public Utilities Commission, by and through its attomey of record,
Chris Burdin, Deputy Attorney General, requests that Falls Water ("Company") provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
DECEMBER 21, 2022.
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 behall 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 I NOVEMBER30,2022
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: The Company requests a deferral of costs associated with
groundwater mitigation to include mitigation fees for 2022, and possibly "other costs."
Application at 4.
a. Please provide all known and expected costs associated with "mitigation fees for
2022" to date in Excel format with formulas enabled.
b. Please explain what "other costs" may be included in the request. Application at 4
REQUEST NO. 2: The Company describes efforts to reduce the water production
demand from its customers.
a. Please explain what methods have been used to communicate with customers for
conservation efforts, i.e., flyers, advertisements, etc.
b. Please describe what additional methods or practices the Company has considered, if
any, besides the initial efforts urging customers to conserve water.
c. Please provide the costs associated with water conservation communications and
methods in a worksheet with formulas enabled.
REQUEST NO.3: The Company describes how the Surface Water Coalition ("SWC")
and Idaho Ground Water Appropriators ("IGWA") Stipulated Mitigation Plan 2016 ("Stipulated
Mitigation Plan in 2016") contains a requirement to reduce annual water pumping by
approximately 240,000 acre-feet. As part of that plan, the District, in which the Company is
located, is required to reduce annual water pumping by 18,000 acre-feet.
a. Please describe the baseline production level that the District, and by extension, the
Company must adhere to as calculated for 2014.
b. Please quantifr the amount that the Company is required to reduce in acre-feet as part
of the District.
FIRST PRODUCTION REQUEST
TO FALLS WATER 2 NOVEMBER30,2022
REQUEST NO. 4: Please provide the following information for each of the customer
classes (residential, commercial, and multifamily) by meter size (5/8" & 314", 1", 1.5",2", arrd
4") for each year from 2010-2022:
a. Average number of metered customers.
b. New connections.
c. Average monthly gallons used.
d. Sum of the total gallons used.
REQUEST NO. 5: The Company states "conservation measures have worked to some
degree: Falls Water pumped less water in2022 than in 2021." Application at 4. Please provide
Company workpapers supporting this statement for 2021 and2022 in Excel format with
formulas intact. Please explain if all months were included in the calculation for 2022.
REQUEST NO.6: Please describe and explain how much each of the customer classes
by meter size are required to reduce their water consumption to meet the Stipulated Mitigation
Plan 2016 in2023. Please also describe how the Company plans to communicate this
information and the cost of incurred Mitigation Fees to its customers.
REQUEST NO. 7: The Stipulated Mitigation Plan 2016 contains benchmarks for 2020
ground water levels.
a. Please provide the 2015 ground water level that is used as the baseline stabilization
level for the IGWA plan as described on page 3 of Exhibit B to the Stipulated
Mitigation Plan 2016.
b. Please provide the 2020 ground water levels.
c. Please confirm if the 2020 stabilization level as calculated with the 2015 ground
water levels was met.
d. Please quantiff the Company's contribution to meeting or failing to meet IGWA
benchmarks.
REQUEST NO. 8: tn Idaho Department of Water Resources Docket No. CM-MP-2016-
001, IGWA, of which the District is a member, was found to be in breach of the Stipulated
FIRST PRODUCTION REQUEST
TO FALLS WATER J NOVEMBER30,2022
Mitigation Plan 2016. Please e{plain the impact that this breach has on the Company and
describe the steps that the Cornpany will take to help the District meet its requirement.
DATED at Boise, Idaho, ldrirs glhay of,November 2A22.
Chris Burdin
Deputy Attorney General
i:umbcprodre{flsw22. lcbkl prod nq I
FIRST PRODUCTION REQLIEST
TO FALLS WATER 4 NOVEMBER30,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3IST DAY OF NOVEMBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO FALLS WATER COMPAIYY, IN CASE NO.
FLS-W.22.0I, BY E-MAILING A COPY TTIEREOF, TO THE FOLLOWING:
PRESTON N CARTER
MORGAN D GOODIN
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 83702
E-MAIL : [e-mail]
[e-mail]
stephaniew@ eivenspgrsley.com
SECRETAR
CERTIFICATE OF SERVICE