20230105Staff 9-11 to Falls Water.pdf

CHRIS BURDIN O
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 C
BOISE,IDAHO 83720-0074 SS N
[phone]
IDAHO BAR NO.98 10
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF FALLS WATER CO.,)INC.'S APPLICATION FOR DEFERRAL OF )CASE NO.FLS-W-22-01
CERTAIN COSTS )
)SECOND PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO FALLS WATER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy Attorney General,requests that Falls Water ("Company")provide the
followingdocuments and information as soon as possible,but no later than THURSDAY,
JANUARY 19,2023.'
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 telephonenumber of
i Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff s
attorney at [phone].
SECOND PRODUCTION REQUEST
TO FALLS WATER ,1 JANUARY 5,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
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.
REQUESTNO.9:Please describe the individual water production baselines for each of the
followingcompanies under the Stipulated Mitigation Plan 2016:
-Taylor Mountain
-Morning View
-Honey Bee Acres
a.Please explain if those baselines were added to Falls Water's Stipulated Mitigation Plan
2016 baseline when each company was acquired.If not added,please explain why not.
REQUESTNO.10:Please explain how the Company determines costs considered "other
costs"or "long-termcosts."Please include a list of account numbers and descriptions for both
"other costs"and "long-termcosts."
REQUESTNO.11:Please provide a worksheet,in electronic format with formulas
enabled,of all "other costs"that have been incurred in efforts to mitigate the special assessment
for the year 2022.Please include the account number,description,quantity,unit of measure,and
cost of each item and totals.
DATED at Boise,Idaho,this day of January 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umisc:prodreq/flsw22.lcbkl prod req 2
SECOND PRODUCTION REQUEST
TO FALLS WATER 2 JANUARY 5,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF JANUARY 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO FALLS WATER COMPANY,IN CASE NO.
FLS-W-22-01,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
PRESTON N CARTER
MORGAN D GOODIN
GIVENS PURSLEY LLP
60 lW BANNOCK ST
BOISE ID 83702
E-MAIL:[e-mail]
morgangoodinocivenspurslev.com
[e-mail]
SECRETÃ Y
CERTIFICATE OF SERVICE