20230616Staff 1-48 to FLS.pdf

CLAIRE SHARP D
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 6 Ã M 9 2
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
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 )COMPANY'S APPLICATION FOR )CASE NO.FLS-W-23-01
AUTHORITY TO INCREASE ITS RATES )AND CHARGES FOR WATER SERVICE )
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF TO
)FALLS WATER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy AttorneyGeneral,requests that Falls Water Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
THURSDAY,JULY 7,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,additional documents that it,or any person
acting on its behalf,may later obtain that will augment the documents or informationproduced.
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
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 1 JUNE 16,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please provide a copy of the Company's Chart of Accounts and any
related instruction material.
REQUESTNO.2:Please provide a schedule of all additions and retirements to Plant in
Service from the beginning of 2021,including installation date,account,installed cost,and
estimated depreciablelife.
REQUESTNO.3:Please provide all journal entries related to additions and retirements
to Plant in Service since the beginning of 2021.
REQUESTNO.4:For the Plant in Service additions shown in Columns B through M of
Exhibit 1,please provide the following:
a.The date or expected date when the addition was completed and used and useful in
the System.
b.Invoices,receipts,labor records,and other materials supporting the project costs.
REQUESTNO.5:Please provide the followinginformation for the backup generator
and transfer switch included in the application and on Exhibit No.1.
a.The make,model,power rating,equipment cost,and installation costs of this
generator.
b.The date on which the generatorbecame or will become fully operational.
c.Reports of any tests or inspections conducted by the DEQ indicating the status of the
generator (e.g.results of the Company's latest DEQ Sanitary Survey).
REQUESTNO.6:Please provide the depreciablelife for all assets in Account 334
Meters,as well as all documentation and justification for how that length of life was determined.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 JUNE 16,2023
REQUESTNO.7:Please provide the Idaho Department of Water Resource's unique
identifier (e.g.Well Tag/D-Tag Number)for each of the Company's wells.
REQUESTNO.8:Company Witness Scott Bruce briefly described a new assessment
management software,"Elements software."Bruce Direct at 5.Please provide a cost-benefit
analysis for the new software.Please include a brief description of the current system the
Company utilizes and any alternatives that were considered.
REQUESTNO.9:For the Element Software in Exhibit 1,Column E.Please include
the following:
a.Supporting documentation for the estimated cost.
b.All Fixed and Variable costs associated with the software.
c.Primary users of the software.
d.An explanation of how the software will benefit customers.
REQUESTNO.10:Please provide a list of all contractors used in 2021,2022,and 2023
to date.Please include with this response the contract amount,project name,project location,
and completion date.
REQUESTNO.11:Please list all the Company's long-term debt issuances.Please
include dates of issuance and expiration,amounts,premiums or discounts,interest rates,dates of
pre-payment,and payment schedules for each issuance.
REQUESTNO.12:Please provide the runningbalance and all deposits and
withdrawals from the special plant reserve fund (Order No.32663)from the beginning of 2021
to date.
REQUESTNO.13:Please describe how all overheads (includingbut not limited to
materials,labor,supplies,vehicles,etc.)are allocated among plant and expense accounts.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 3 JUNE 16,2023
REQUESTNO.14:Please provide a list of all property that the Company leases to
others and all property that the Company leases from others.Please provide copies of all lease
contracts.
REQUESTNO.15:Please summarize all benefits and retirement plans provided to any
classification of Company employees.Please also include any changes that have occurred to
benefits/accruals during the past five years.
REQUESTNO.16:Please provide copies of the Company's electrical and natural gas
bills for 2022.
REQUESTNO.17:Please provide invoices for the Company's chemical expenses for
2020,2021 and 2022.
REQUESTNO.18:Please provide copies of the Company's insurance policy coverage
and any invoices or receipts supporting the Company's insurance expense for 2022 and pro
forma "Insurance Expense Charge from NWN."
REQUESTNO.19:Please provide supporting documentation for rate case expense for
this case.
REQUESTNO.20:Please provide an itemized list of the services and costs provided
by NWN Water.Please include the calculations of shared services in Excel format with formulas
mtact.
REQUESTNO.21:Please provide a copy of the Company's property tax bills for 2022.
REQUESTNO.22:Please provide a copy of the Company's federal and state income
taxes for 2022.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 4 JUNE 16,2023
REQUESTNO.23:Please explain the Company's provisions for deferred federal and
state income taxes.Please provide any associated schedules,analyses,or descriptions of the
Company's deferred income taxes.
REQUESTNO.24:Please provide a list of any events in 2022 to the current date,such
as unplanned outages,storm damage or use of a diesel generator,that required repairs and/or
increased expenses.
REQUESTNO.25:Please provide a list of "out-of-period adjustments"and
"extraordinary items"for the years 2021-2023 to date.
REQUESTNO.26:Please list any prepaid items for 2022 and 2023 showing amounts
posted,vendor names,explanations,and accounts to which these items were booked.Please
include within your response any significant changes to prepaid items occurring or planned to
occur.
REQUESTNO.27:Please provide the Company's practice for determining
uncollectible accounts and its policy for customer account deposits and terminations.
REQUESTNO.28:Please provide all Company bank statements for 2022 to date.
REQUESTNO.29:Please provide statements for all company credit cards from 2022
to date.
REQUESTNO.30:Please explain the difference in Account 601.5 Field Labor,as filed
in the Application (Exhibit2,Column A)and the amount reported in the Company's 2022
annual report for the same Account.
REQUESTNO.31:Please provide a current hydraulicmodel of the Company's water
system.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 5 JUNE 16,2023
REQUESTNO.32:Please provide the most recent version of the Company's Drinking
Water Facilities Capital Plan.
REQUESTNO.33:Please provide a copy of the Company's policy for water main
extensions.
REQUESTNO.34:Please provide the followingfor each meter size for each month
from January 2021 throughDecember 2022.
a.Number of Billed Customer Charges.
b.Gallons of water provided to customers at no charge as part of the Minimum Charge.
c.Gallons sold to customers in excess of the maximum gallons allowed in the Minimum
Charge.
REQUESTNO.35:For each of the Company's wells,please provide the quantity
(gallons)pumped for each month between January 2021 and December 2022.
REQUESTNO.36:Please provide the total 2022 actual special assessment fee that the
Company was assessed for and any supporting documentation (i.e.,letter,invoice).
REQUESTNO.37:Please provide a supporting worksheet with formulas intact that
includes a brief description of each item and actual spend in the deferral account for 2022 (i.e.,
special assessments fee and other costs associated with groundwater mitigation).
REQUESTNO.38:Please provide supporting documentation and worksheets with
formulas enabled that support the pro forma adjustment for the estimated deferral expense for a
2023 special assessment fee.
REQUESTNO.39:For each water right expense below,please provide any relevant
supporting documentation (i.e.,contracts,historical data,etc.)of the water rights,includingthe
expected amount of water production (broken out by month)and/or any
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 6 JUNE 16,2023
documentation/calculations supporting the additional acre feet production for each expense to the
Company's existing baseline (3,732 acre-feet):
a.May 28,2021:of $388,000 (Referenced in Bruce Direct at 2)
b.February 16,2023:50 acres for $350,450 (Referenced in Bruce Direct at 4)
c.November 30,2023:60 acres for $363,550 (Referenced in Bruce Direct at 4)
REQUESTNO.40:Please provide the Company's current available water production
level that includes the Company's most recent completed purchases of water rights.Please
provide a supporting worksheet.
REQUESTNO.41:In Final Order No.35706,the Company was ordered to update the
Commission when the Bonneville-Jefferson Groundwater District ("District")determined how
the breach of the Stipulated Mitigation Plan will impact the Company.Please provide the
followinginformation:
a.Please provide an update on the status of the breach implication to the Company.
b.If the breach implication is known,please describe the impact to the Company
and the Company's required actions.Please provide any supporting
documentation.
REQUESTNO.42:Please clarify if the Company intended to include new purchased
water rights expected on November 30,2023,to the adjustment to Account No.610 -Purchased
Water.Bruce Direct at 8.If not,please explain why the expected purchase's water production
would not be considered as a reduction to the District's special assessment fees.
REQUESTNO.43:Please provide the cost allocation manual of NW Natural Water for
its subsidiaries.
REQUESTNO.44:Please provide Capital and Operations &Maintenance ("O&M")
informational technology and services ("IT&S")expenses for NW Natural Water from 2020-
2022 allocated to the Company.Please explain how NW Natural Water allocates Capital and
O&M IT&S expenses to its subsidiaries and please provide supporting worksheets.
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 7 JUNE 16,2023
REQUESTNO.45:Please provide Capital and O&M IT&S expenses for the Company
from 2020-2022 and please provide supporting worksheets.
REQUESTNO.46:Please explain why the Company chose not to hire a staff
accountant followingthe prior accountant leaving the Company.Please provide a cost-benefit
analysis that includes the estimated salary of a staff accountant and the cost of a contract
accountant used to assist with month-end close.
REQUESTNO.47:Please explain the rationale for the Company to purchase the John
Deere riding lawnmower in 2020.Bruce Attachment 1-B at 7.
REQUESTNO.48:Please provide the followingfor each rate class listed in
Attachment 3 of the Application for each month from January 2022 through December 2022.
Data should be in excel format with formulas enabled.
a.Number of Billed Customers.
b.Average gallons used per Billed Customer.
c.Average gallons used per Billed Customer at no charge as part of the Minimum
charge.
d.Average gallons used per Billed Customer in excess of the Maximum gallons
allowed in the Minimum charge.
DATED at Boise,Idaho,this 16"'day of June 2023.
Claire Sharp
Deputy AttorneyGeneral
i:umise:prodreq/fisw23.lcstj prod req l
FIRST PRODUCTION REQUEST
TO FALLS WATER COMPANY 8 JUNE 16,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF JUNE 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO FALLS WATER COMPANY,INC,IN CASE NO.
FLS-W-23-01,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
PRESTON N CARTER ERIC W.NELSEN
MORGAN D GOODIN SENIOR REGULATORY ATTORNEY
GIVENS PURSLEY LLP NW NATURAL 250 SW TAYLOR ST.
601 W BANNOCK ST PORTLAND,OREGON 97204
BOISE ID 83702 E-MAIL:eric.nelsen nwnatural.com
E-MAIL:[e-mail]
[e-mail]
[e-mail]
K.SCOTT BRUCE
FALLS WATER CO.,INC.
2180 NORTH DEBORAH DRIVE
IDAHO FALLS,ID 83401
E-MAIL:scott1 fallswater.com
SECRETARY
CERTIFICATE OF SERVICE