20230706Staff 74-80 to FLS.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
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
Attorney for 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 )
)THIRD 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 27,2023.
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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 1 JULY 6,2023
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.74:Please provide the Company's capitalization policy.Please ensure
it explains when the Company categorizes an expense as a capital expenditure versus an expense.
REQUESTNO.75:Please provide the supporting documentationincludingall invoices
and contracts for the Capitalized purchases included in the attached spreadsheet:Staff attachment
A FLS W 23 01.Please include any cost benefit analysis used by the Company justifyingthe
purchase,a description of the item,upgrades,or service purchases,and how the purchase
benefits the customers.
REQUESTNO.76:Please explain why the depreciation years are different for like
items and how the length of time is determined for the items listed in Column G on the
spreadsheet mentioned in above production request.
REQUESTNO.77:In Staff attachment A FLS W 23 01 lines 29,30,&31,please
explain why Well 10 had a Chlorinator rebuilt on 3/31/20 in the amount of $2,509.35 and then 2
new chlorinator pumps were purchased in August and September for $479.23 and $556.22
respectively.
REQUESTNO.78:On Staff attachment A FLS W 23 01 lines 19 &20 please explain
why Well 4 had a replacement motor and other work done for $30,079.72 and then on 7/31/20
spent $3,142.67 on a pump replacement.Please provide invoices for these expenses.
REQUESTNO.79:Please provide the bill of sale for the purchase of the following
vehicles and explain the reason for each purchase.
a.2021 C&B Trailer $4,990.25 purchased 3/4/21.
b.2020 Ford F250 Pickup $56,503.03 purchased 1/6/21.
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 JULY 6,2023
REQUESTNO.80:Please provide all documents,contracts,and invoices that show
why the followingprojects were over budget and give a brief explanation for each.
a.Crowley Road Loop case 20-3 exh l rate base had $178,000 but in this case
FLS-W-23-01 the 2023 Rate Case Model spreadsheet tab exh 1 B 2022 Depr
shows a total of $188,732.68.
b.Lincoln road Phase 3 10"Main Move case 20-3 exh 1 rate base had $125,000
but in this case FLS-W-23-01 the 2023 Rate Case Model spreadsheet tab exh 1
B 2022 Depr shows a total of $133,138.30.
c.Hitt Road &Iona Road Looping case 20-3 exh 1 rate base had $975,000 but in
this case FLS-W-23-01 the 2023 Rate Case Model spreadsheet tab exh 1 B 2022
Depr shows a total of $986,971.62.
DATED at Boise,Idaho,this 6th day of July 2023.
Claire Sharp
Deputy AttorneyGeneral
i:umisc:prodreq/flsw23.lcstjttem edits prod req 3
THIRD PRODUCTION REQUEST
TO FALLS WATER COMPANY 3 JULY 6,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF JULY 2023,SERVED
THE FOREGOING THIRD 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:scottl fallswater.com
SECRE ARY
CERTIFICATE OF SERVICE