20230623Staff 49-73 to FLS.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 3:30POBOX83720
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 )
)SECOND 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
FRIDAY,JULY 14,2023.
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 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 identify the name,job title,location,and
telephonenumber of the record holder.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY l JUNE 23,2023
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.49:Please generally describe the Company's methodology for
developing,managing,executing,and completing capital projects or investments in a least cost
manner.Please provide a copy of all Company policies and procedures documenting the
process.
REQUESTNO.50:Please provide a list of all capital projects/investmentsthat the
Company is requesting recovery of in this case.Within this list,please provide the following
information:
a.Project in-service date.
b.Work order or project number.
c.Project title.
d.Project description.
e.Project budgeted cost,and corresponding date.
f.Project actual cost.
g.Total Company capital investment.
h.Was an analysis of need completed?
i.Was a Cost/Benefit analysis completed?
j.Was the project primarily completed using contractor(s)?Please explain.
k.If contractors were used,was a Request for Proposal issued for the project?
1.Were Company Resources used to primarily complete the project?Please explain.
REQUESTNO.51:Please describe the Company's process in determining whether to
contract or self-perform system installation of water supply piping,distribution piping,
and/or fire hydrants.
REQUESTNO.52:Please explain how the Company assures the cost of installation for
transmission plant,distribution plant,and fire hydrants are at least cost to the Company's
ratepayers.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 JUNE 23,2023
REQUESTNO.53:For "Exhibit 2 (A)Payroll for 2022,"please provide supporting
documents (invoices,receipts,excel workpapers,etc.)for the followingEmployee Benefits with
formulas intact:
a.Employee 401(k)Match.
i)Please also include the Company's methodology for determining 401(k)
match rate and include the actual 401(k)expense for 2022.
b.Health,Dental and Vision Insurance.
i)Please include an explanation and supporting documentation for the
increase in insurance costs since the last General Rate Case.
c.Employer Paid Life Insurance,Short-term Disability,and Long-term Disability.
d.RSU Benefit.
i)Please provide an explanation of the benefit Customers receive from the
RSU.
e.Clothing Allowances.
i)Please include the actual Clothing Allowance Expense for 2022.
f.401 (k)Plan Fees.
REQUESTNO.54:Please explain the Company's methodology for determining
employee bonuses.Please include supporting documents in excel format with formulas intact.
Please include an explanation for the two Employee Bonuses found in the Company's Rate Case
Model in Exhibit 2 (A),Columns D and Column J.
REQUESTNO.55:Please provide a thorough and complete description of the system.
This should include any deficiencies known that need to be addressed to maintain system
integrity and efficiency (e.g.,to remove iron or other chemical deposits)and to support growth,
as well as any changes/investments that the Company plans to implement to address deficiencies
relative to items included below.Include the costs and benefits for any investments or increases
in expense.
REQUESTNO.56:Please provide up-to-date and separate geo-spatial system maps
that outline all contiguous water utility systems operated by Falls Water in the State of Idaho.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 3 JUNE 23,2023
The map should include the location and elevation of major equipment includingwells,
distribution piping,storage tanks,booster pumps,shut-off valves,meters,fire hydrants,water
treatment equipment,etc.Please include the followinginformation by breaking them down for
Falls Water ("FW"),Taylor Mountain ("TM"),and Morningview ("MV")customer systems.
a.The depth,width,length,capacity,construction materials of each well (including
backup wells,if any),and length of time in service.
b.The make,model,type,and rating of each well pump motor,and length of time in
service.
c.The make,model,capacity,and limit switch settings of each pressurized storage
tank,and length of time in service.
d.The make,model,capacity,and limit switch settings of each unpressurized
storage tank/reservoir,length of time in service.
e.The make,model,and rating of each booster pump and motor,and length of time
in service.
f.The make,model,and capacity of all water treatment equipment,and length of
time in service.
g.The year,make,model,and capacity for backup generation supporting the well
pumps,and length of time in service.Indicate if the generation has an Automatic
Transfer Switch (ATS)or if it must be manuallystarted.
h.The distribution piping line size and materials specified in the installation,and
length of time in service.
NOTE:Please provide this map in an electronic format (.pdf)which can be
scaled,enlarged to identify all aspects of the system.
REQUESTNO.57:For each well used by the water system,please provide the
following:
a.The Idaho Department of Water Resources Well Tag Number (D-Tag Number)
currentlyon-file with IDWR.
b.Location (Township,Range,Section,and Tract)
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 4 JUNE 23,2023
REQUESTNO.58:Please provide the specified material requirements and construction
details used in the installation of the distribution system piping.
REQUESTNO.59:Please provide informationrelated to the capacity and sizing of the
system and the ability of the system to meet historical and future system peak demand.
Information would include not only capacity/constraints of/in the system,but also consumption
and consumption at peak periods.
REQUESTNO.60:Please provide the monthlypower bills over the past 5 years
indicating the amount of electricity (kWh)used by each well and booster pump.Please provide
a breakdown for FW,TM,and MV customer systems.
REQUESTNO.61:Please provide the monthlymetered amount of water (gallons)
pumped from each well over the past 5 years.Please provide a breakdown for FW,TM,and MV
customer systems.
REQUESTNO.62:Please provide the monthlymetered total customer demands/water
usage data (gallons)over the past 5 years.Please provide a breakdown for FW,TM,and MV
customer systems.
REQUESTNO.63:Please provide an estimate of total unaccounted water losses due to
leaks,wasted water,etc.by month over the past 5 years.Include a breakdown for FW,TM,and
MV customer systems.Please explain how these losses are estimated.
REQUESTNO.64:Please provide annual data over the past 5 years including total
amount of water production (gallons),the total amount of Pure Chlorine used (in pounds),and
total expense for Chlorine purchase (includingSales Tax)for each well.Please provide a
breakdown for FW,TM,and MV customer systems.Also please specify whether a solid or
liquid form of Chlorine was used for each system.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 5 JUNE 23,2023
REQUESTNO.65:Please provide the Idaho Division of Environmental Quality
Sanitary Survey for the past 3 years.
REQUESTNO.66:Please provide the average hourly pressure data in the main
distribution line (averaged over 7 days in each week for each hour)in each month over the past 3
years.
REQUESTNO.67:Please provide all documents/contracts/invoicesthat support the
a.Water right 25-14483 $116,531.50 purchased 5/28/21.
b.Water right 25-14482 $271,418.75purchased 5/28/21.
c.2220 N Deborah Dr -Vacant lot $122,000 purchased 4/29/22.
d.2180 N Deborah Dr -office/warehouse land $145,228purchased 4/29/22.
REQUESTNO.68:Please provide all documents/invoices to support the purchase of
the followingand include any cost benefit analysis used by the Company justifyingthe
purchases:
a.2015 Chevy Silverado $28,634.00 purchased 8/5/22.
b.Brown flatbed $1,165.98 purchased 8/30/22.
c.Industrial shelving $9,529.71 purchased 9/17/22.
REQUESTNO.69:Please provide information on what is being done with the 2006
service pickup that is being replaced by the purchase of the 2015 Ford F-250 in Bruce's direct
testimony page 5,line 15.
REQUESTNO.70:Please provide a copy of the Company's policy on amortizing
assets.Please explain what the procedure is on determining what should be amortized and for
how long.
REQUESTNO.71:Please provide the ending balance of the Special Plant Reserve
Fund as of December 31,2022.Also provide an update of the balance to current date.
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 6 JUNE 23,2023
REQUESTNO.72:In Order No.34925,the Commission ordered the Company to use
$100,000 of the special plant reserve fund as a CIAC.Please provide informationas to where
this is listed in this rate case.
REQUESTNO.73:Please explain how the CIAC for each account is calculated in
Bruce's Exhibit No.1-B,pages 1-7.
DATED at Boise,Idaho,this 23 day of June 2023.
Claire Sharp à
Deputy AttorneyGeneral
Technical Staff:Ty Johnson
SECOND PRODUCTION REQUEST
TO FALLS WATER COMPANY 7 JUNE 23,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF JUNE 2023,
SERVED THE FOREGOING SECOND 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:[e-mail]
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:[e-mail]
SECRETAR
CERTIFICATE OF SERVICE