20230119Falls Water to Staff 9-11.pdf

RESPONSES TO SECOND PRODUCTION REQUEST PAGE 1 OF 2
Preston N. Carter, ISB No. 8462
Danielle M. Strollo, ISB No. 11496
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Falls Water Co., Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF FALLS WATER CO., INC.’S APPLICATION FOR DEFERRAL OF CERTAIN COSTS

CASE NO. FLS-W-22-01
FALLS WATER COMPANY’S RESPONSES TO
THE SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF
Falls Water Co., Inc. (“Falls Water” or “Company”) submits the following responses to the
Second Production Request of the Commission Staff to Falls Water dated January 5, 2023.
DATED January 19, 2023.
GIVENS PURSLEY LLP

By Preston Carter Givens Pursley, LLP Attorneys for Falls Water Co., Inc.

RECEIVED
Thursday, January 19, 2023 2:17:56 PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO SECOND PRODUCTION REQUEST PAGE 2 OF 2
CERTIFICATE OF SERVICE
I certify that on January 19, 2023, a true and correct copy of the foregoing was served upon
all parties of record in this proceeding via electronic mail as indicated below:

Commission Staff Via Electronic Mail
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]

Preston N. Carter

Rates & Regulatory Affairs
FLS-W-22-01
Falls Water Company Application for Deferral of Certain Costs
Data Request Response

Request No.: FLS-W-22-01 IPUC DR 9
9. Please describe the individual water production baselines for each of the following
companies under the Stipulated Mitigation Plan 2016:
- Taylor Mountain
- MorningView
- 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.

Response:
The production baseline for Taylor Mountain is 150.616-acre feet. Morning View’s
production base line is 202.81-acre feet. Both systems have been added to Falls
Water’s baseline after their acquisitions.
Honey Bee Acres has not yet been added to the baseline. The baseline for Honey Bee
acres is 19.44-acre feet, which we anticipate will be added to the 3,732.2 for Falls
(including Taylor Mountain and Morning View).
FLS-W-22-01
IPUC DR 9
Page 1 of 1
Prepared by: Scott Bruce

Rates & Regulatory Affairs
FLS-W-22-01
Falls Water Company Application for Deferral of Certain Costs
Data Request Response

Request No.: FLS-W-22-01 IPUC DR 10
10. Please explain how the Company determines costs considered "other costs" or
"long-term costs." Please include a list of account numbers and descriptions for
both "other costs" and "long-term costs."

Response:
The primary costs identified to address the measures to implement the mitigation
measures related to Falls Water’s pumping of groundwater rights pursuant to its water
rights are booked to account 668.1 Water District Fees.
Potential “other costs” would include leased or purchased water to supplement water
supplies. Purchased water costs are booked to account 610 - Purchased Water. Legal
costs for the contracts to lease the water are booked in account 631.3 – Attorney.
Costs for third-party assistance to find water rights to rent/lease are booked in account
631.1 – Engineering.
“Long-term costs” would include acquisition of water rights that would be recorded to
plant in service or conservation investments to reduce demand. These costs would be
recorded in account 303 – Land & Land Rights.
The intent of referencing “other costs” was to allow for activities that may occur at a
lower cost than the fees to benefit both customers and the Company, if a suitable
alternative is identified.
FLS-W-22-01
IPUC DR 10
Page 1 of 1
Prepared by: Scott Bruce

Rates & Regulatory Affairs
FLS-W-22-01
Falls Water Company Application for Deferral of Certain Costs
Data Request Response

Request No.: FLS-W-22-01 IPUC DR 11
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.

Response:
Legal fees of $1,485 relating to mitigation options and trying to find water rights to lease,
have been incurred in 2022. These expenses are found in account 631.3 – Attorney.
Please see FLS-W-22-01 IPUC DR 11 Attachment 1.
The Company has accrued for the anticipated water district fees and anticipates being
invoiced in early 2023.
FLS-W-22-01
IPUC DR 11
Page 1 of 1
Prepared by: Scott Bruce