20230707FLS to Staff 1-3_5-7_11-12_14-18_21_23-25_27_30-36_38_41-43_47-48.pdf

FALLS WATER CO., INC.’S RESPONSES TO FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 1 OF 2
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[16800551_1.docx]

Attorneys for Falls Water Co., Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF FALLS WATER CO., INC. FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE
IN THE STATE OF IDAHO

Case No. FLS-W-23-01

FALLS WATER CO., INC.’S RESPONSE TO
THE FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF

Falls Water Co., Inc., (“Falls Water,” “Applicant,” or “Company”) in response to the
First Production Request of the Commission Staff to Falls Water Co., Inc. dated June 16, 2023,
submits the following responses. Responsive documents are available for download using the
link provided in the accompanying email. Confidential responses and documents are subject to
the protective agreement in this case, and are available for download using a password-protected
link that will be provided separately by email. The password will be provided in a third email.
DATED July 7, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
2023 JULY 7, 2023 4:11PM
IDAHO PUBLIC
UTILITIES COMMISSION
FALLS WATER CO., INC.’S RESPONSES TO FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on July 7, 2023, I caused to be served a true and correct copy of the
foregoing document to the person(s) listed below by the method indicated:
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-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 1
Please provide a copy of the Company's Chart of Accounts and any related instruction
material.
Response:
The Company’s Chart of Accounts can be found in FLS-W-23-01 IPUC DR 1
Attachment 1.
FLS-W-23-01
IPUC Staff DR 1
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 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
depreciable life.
Response:
The schedule of all additions and retirements to Plant in Service from 2021 is included
in FLS-W-23-01 IPUC DR 2 Attachment 1.
FLS-W-23-01
IPUC Staff DR 2
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 3
Please provide all journal entries related to additions and retirements to Plant in Service
since the beginning of 2021.
Response:
The journal entries related to additions and retirements to Plant in Service are provided
in FLS-W-23-01 IPUC DR 3 Attachment 1.
FLS-W-23-01
IPUC Staff DR 3
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates and
Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 5
Please provide the following information for the backup generator and transfer switch
included in the application and on Exhibit No. l .
a. The make, model, power rating, equipment cost, and installation costs of this generator.
b. The date on which the generator became 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).
Response:
a. The details for the generator set and automatic transfer switch found on Item No. 1 on
the table below are described in detail in the generator contract found in FLS-W-23-01
IPUC DR 5 Attachment 1 and the data sheets found in FLS-W-23-01 IPUC DR 5
Attachments 2 - 3.
The details for the installation costs found on Item No. 2 on the table below can be found
in FLS-W-23-01 IPUC DR 5 Attachment 4.
In addition to the cost of the generator and installation, costs will be incurred for a twelve
foot by twenty-five-foot concrete pad to set the generator and miscellaneous costs to
complete the installation.
Item No Description Amount
1 Generator & Automatic Transfer Switch $102,785
2 Installation of Wiring to Transfer Switch and from
Transfer Switch to Main Electrical Panels
$23,500
3 Concrete Pad for Generator and Miscellaneous Costs $23,715
Total Costs for Generator $150,000
b. The in-service date for the generator is anticipated to be November 2023. This is based
on the lead time for the generator at 29-31 weeks, which corresponds with delivery
between October 16 and November 3, 2023.
FLS-W-23-01
IPUC Staff DR 5
Page 1 of 2
c. There are no reports of tests or inspections conducted by the DEQ regarding the status
of the generator. The latest sanitary survey dated September 2020 is found at FLS-W-
23-01 IPUC DR 5 Attachment 5. There is currently no generator at the site with three
wells and, therefore, backup generation is needed to provide reliable service in the event
of power outages.
FLS-W-23-01
IPUC Staff DR 5
Page 2 of 2
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 6
Please provide the depreciable life for all assets in Account 334 Meters, as well as all
documentation and justification for how that length of life was determined.
Response:
The attached spreadsheet, FLS-W-23-01 IPUC DR 6 Attachment 1, includes the
depreciation tables for all meters in the system (e.g., residential meters, commercial
meters, radio transmitters (MXU), wellhouse flow meters, replacement meter registers).
The meters and radio transmitters installed prior to 2012 were all given a ten-year life.
Once Sensus IPERL meters and radio transmitters became the standard install from
2012 to present, a twenty-five-year life has been used.
Data sheets for the IPERL meters and 520M Sensus MXU radio transmitters are
attached as FLS-W-23-01 IPUC DR 6 Attachments 1-2. In the data sheets, FLS-W-23-
01 IPUC DR 6 Attachment 2 and FLS-W-23-01 IPUC DR 6 Attachment 3, the
manufacturer states that the battery life for the meter is a twenty-year life. The
Company worked with Staff back in 2012 to establish the depreciable life for the meters
and MXUs for 25-years. The Commission adopted the 25-year life in the Company’s
2012 rate case: “Based on our review of the record and the parties’ agreement on
salvage value and useful life, we find that it is reasonable and appropriate for the
Commission to use the parties’ assumption of a zero salvage value and 25-year
depreciable life when calculating meter project depreciation. We find it reasonable to
require the Company to track meter maintenance and replacement as suggested by
Staff so the Company can better document useful life of the meters.” Case No. FLS-W-
12-01, Order No. 32663 (dated October 12, 2012), p. 6.
The hydrant meters use a ten-year depreciable life because of their mobility and risk of
damage by contractors.
FLS-W-23-01
IPUC Staff DR 6
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 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.
Response:
The well tag/ID-tag numbers for the Falls Water, Taylor Mountain, and Morningview
systems are listed below.
Falls Water’s Wells:7100030
Well #1 – E0007128
Well #2 – E0007131
Well #4 – E0007130
Well #5 – E0007132
Well #6 – E0007129
Well #8 – E0008065
Well #9 – D0048514
Well #10 – D0073750
Well #11 – D00841000
Taylor Mountain’s Wells:7100023
Well #1 – E0007186
Well #2 – E0007187
Morningview’s Wells:
Well #1 – E0006772
FLS-W-23-01
IPUC Staff DR 7
Page 1 of 2
Well #2 – E0006771
Well #3 – D0062972
FLS-W-23-01
IPUC Staff DR 7
Page 2 of 2
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 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.
Response:
The list of all the Company’s long-term debt is below and the schedule for payments
and details is provided in FLS-W-23-01 IPUC DR 11 Attachments 1 – 4.
Loan
Description
Date of
Issuance
Date of
Expiration
Amount Premiu
m /
Discou
nt
Interest
Rate
Date of
Prepayme
nt
Payment
Schedule
MV - Loan #
DW-1302A 2/7/2017 2/7/2047 $462,970 NA 1.25% NA FLS-W-23-01
IPUC DR 11
Attachment 1
DW-9923 6/2/2005 12/15/2025 $274,376 NA 3.25% NA FLS-W-23-01
IPUC DR 11
Attachment 2
DW-9931 6/18/2009 6/19/2029 $1,200,000 NA 3.25% NA FLS-W-23-01
IPUC DR 11
Attachment 3
FLS-W-23-01
IPUC Staff DR 11
Page 1 of 2
Zions Bank
Loan No
1010000682
011
4/29/2022 4/29/2037 $684,815 NA 3.49% NA FLS-W-23-01
IPUC DR 11
Attachment 4
FLS-W-23-01
IPUC Staff DR 11
Page 2 of 2
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 12
Please provide the running balance and all deposits and withdrawals from the special
plant reserve fund (Order No. 32663) from the beginning of 2021 to date.
Response:
The transaction detail for the special plant reserve fund (Order No. 32663) is provided in
FLS-W-23-01 IPUC DR 12 Attachment 1.
FLS-W-23-01
IPUC Staff DR 12
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 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.
Response:
Falls Water leases property to others at 685 N Eden Dr and 697 N Eden Dr in Idaho
Falls, Idaho. The leases can be found at FLS-W-23-01 IPUC DR 14 Attachments 1 and
3.
The tenant has been notified that the lease will not be continued after April 30, 2023.
The tenant is a property management company and owns the mobile homes on both
lots. The property management company is trying to sell them. We have agreed
verbally to allow the tenant to use the lots while trying to sell them until August 31, 2023.
The tenant is to remove the mobile homes no later than August 31, 2023. Rent will
continue to be collected monthly until the homes are removed. Please see the attached
lease contract FLS-W-23-01 IPUC DR 14 Attachments 1 and 3 and notice to cancel the
lease contracts in FLS-W-23-01 IPUC DR 14 Attachments 2 and 4.
Falls Water leases a well and water rights from Lincoln Land Company located at 2877
E Lincoln Road, Idaho Falls, Idaho. Please see the attached leases for the water rights
and well in FLS-W-23-01 IPUC DR 14 Attachments 5 and 6, respectively.
Falls Water leased its office space from Brent Johnson until it was purchased on April 1,
2022. The lease had ended in September 2021 and the Company was on a month-to-
month lease of $5,000 per month through the sales close. No lease agreement is
available for the month-to-month period. A copy of the last lease agreement is included
in FLS-W-23-01 IPUC DR 14 Attachment 7.
FLS-W-23-01
IPUC Staff DR 14
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 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.
Response:
Falls Water was acquired by NW Natural in 2018. In 2018 and 2019, the employee
benefits available to any classification of employees were:
 401(k) retirement that the employee became eligible for after 1 year.
 Health Insurance
 Dental Insurance
 Vision Insurance
 Vacation Pay
 Sick Pay (10 Days)
 Paid Holidays (12 Paid Holidays – No Floating Holidays)
In 2020, the benefits were:
 401(k) retirement that the employee became eligible for after 1 year.
 Health Insurance
 Dental Insurance
 Vision Insurance
 Paid Time Off (Vacation and Sick were combined and fewer days were given
than the total of the prior vacation and sick)
 Paid Holidays – Changed to listing below less Veterans Day and Martin Luther
King Day
FLS-W-23-01
IPUC Staff DR 15
Page 1 of 3
In 2021, the employee benefits expanded. The benefits were:
 401(k) retirement plan
 Health Insurance (Employee paid 20% of Premium/Employer paid 80% of
premium)
 Dental Insurance (Employee paid 20% of Premium/Employer paid 80% of
premium)
 Vision Insurance (Employee paid 20% of Premium/Employer paid 80% of
premium)
 Paid Time Off
 Life insurance (100% Company paid)
 Voluntary Life Insurance (100% Employee Paid)
 Long-Term Disability (100% Company paid)
 Short-Term Disability (100% Company paid)
 Paid Holidays – Changed to listing below less Veterans Day and Martin Luther
King Day
In 2022, the employee benefits were:
 401(k) retirement plan
 Health Insurance (Employee paid 20% of Premium/Employer paid 80% of
premium)
 Dental Insurance (Employee paid 20% of Premium/Employer paid 80% of
premium)
 Vision Insurance (Employee paid 20% of Premium/Employer paid 80% of
premium)
 Paid Time Off
 Life insurance (100% Company paid)
 Voluntary Life Insurance (100% Employee Paid)
 Long-Term Disability (100% Company paid)
 Short-Term Disability (100% Company paid)
 Employee Stock Purchase (100% Employee Paid)
 Paid Holidays as listed below
In 2023, the employee benefits remained unchanged from 2022.
Company Observed (Paid) Holidays
Full-time employees will be eligible for the following Observed Holidays. Part-time
employees, those who work less than 30 hours per week, will receive pro-rated holiday
pay.
 New Year’s Day
 Memorial Day
 Independence Day
 Labor Day
FLS-W-23-01
IPUC Staff DR 15
Page 2 of 3
 Thanksgiving Day
 Day after Thanksgiving Day
 Christmas Day
 Veterans Day
 Martin Luther King Day
Floating Holidays
Full-Time employees are also entitled to four (4) floating days per calendar year.
Floating days must be used within the calendar year, as they do not carry over.
Full time employee in their first year of employee will be eligible for floating days during
the calendar year as follows:
Hire Date Days
January 1 through March 31 4
April 1 through June 30 3
July 1 through September 20 2
October 1 through November 1
December 1 through December 31 0
Paid Time Off (PTO) [Combined Vacation and Sick]
 Full Time Employees are eligible to accrue PTO as follows (part-time employees
will have a prorated accrual):
Length of Continuous Service from
Anniversary Date
Annual
Accrual
Date of Hire, but less than 5 years 15 days
At least 5 years but less than 10 years 20 days
At least 10 years but less than 20 years 25 days
Greater than 20 years 30 days
FLS-W-23-01
IPUC Staff DR 15
Page 3 of 3
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 16
Please provide copies of the Company's electrical and natural gas bills for 2022.
Response:
The electric and natural gas bills for 2022 are provided in separate folders for FLS-W-
23-01 IPUC DR 16 Attachments 1 – 12.
FLS-W-23-01
IPUC Staff DR 16
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 17
Please provide invoices for the Company's chemical expenses for 2020, 2021 and
2022.
Response:
The invoices for the Company’s chemical expenses for the three years 2020 – 2022 are
located in folders FLS-W-23-01 IPUC DR 17 Attachments 1 – 3, respectively.
FLS-W-23-01
IPUC Staff DR 17
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Jeremy Aird
Director of Accounting and Finance, NW Natural Water
(503)-610-7927
Request No.: FLS-W-23-01 IPUC DR 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. "
Response:
Please see FLS-W-23-01 IPUC DR 18 Attachments 1-3 (Excel spreadsheets) for the
data supporting the proforma insurance expenses. The proforma expense is based on
our most current insurance premium renewals that run from October 15, 2022 through
October 15, 2023. Although we expect a further increase in costs for the upcoming
October 2023-2024 renewal, based on experience and expected inflation in the
markets, we have not incorporated any such further increase in our pro forma
adjustments.
Insurance premiums are procured by the Risk & Land Management team of NW
Natural. Purchasing the policies as a larger group allows for the water companies to get
better rates. Some of the invoices have the detail to be able to directly identify costs for
each water company; where this level of detail is not available, we use the
Massachusetts Methodology. This method factors annual revenues, net plant assets,
and headcount/labor to calculate the allocation factor. FLS-W-23-01 IPUC DR 18
Attachments 1-3 identify the invoices and how they were eventually allocated to Falls
Water and the other Water subsidiaries. The invoices are provided as FLS-W-23-01
IPUC DR 18 Attachment 4 (PDF document).
FLS-W-23-01
IPUC Staff DR 18
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 21
Please provide a copy of the Company's property tax bills for 2022.
Response:
The Company’s property tax bills for 2022 are provided in FLS-W-23-01 IPUC DR 21
Attachments 1 – 3 for property taxes paid to Progressive Irrigation District, Bonneville
County, and Jefferson County.
The property tax bills for the second half of 2021 are also provided in FLS-W-23-01
IPUC DR 21 Attachments 4 – 6 for reference.
FLS-W-23-01
IPUC Staff DR 21
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Sean Borgerson
Tax Director, NW Natural
(503)-701-5598
Request No.: FLS-W-23-01 IPUC DR 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.
Response:
The federal and state deferred income tax balances, along with calculations, analysis,
and descriptions, are included in the revenue requirement model at tab <Exh.
1_(C)_Deferred Income Tax>. The detail provided supports the deferred income tax
figures included in the calculation of rate base at tab <Exhibit 1 (Rate Base)>.
Accumulated deferred income taxes (ADIT) generally represents the cumulative
difference between total income tax expense and income taxes paid (total income tax
expense = current income taxes + deferred income taxes). Prior to the last general rate
case (Case FLS-W-20-03), income tax expense included in ratemaking only allowed for
recovery of current income tax expense. As a result, ADIT balances prior to the last
general rate case were not recovered in ratemaking and were not included in rate base.
Beginning with the last general rate case, income tax expense included in ratemaking
did provide for total income tax expense (both current and deferred). The ADIT activity
since the last rate case (i.e., the change in deferred taxes) is detailed in the revenue
requirement model and included in the determination of rate base in this filing.
FLS-W-23-01
IPUC Staff DR 23
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 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.
Response:
None of the unplanned outages in 2022 to the current date resulted in repairs made by
the Company or increased expenses. The Company did not have any storm damage or
diesel generator use due to power outages in 2022 to the current date.
FLS-W-23-01
IPUC Staff DR 24
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 25
Please provide a list of "out-of-period adjustments" and "extraordinary items" for the
years 2021-2023 to date.
Response:
The “out of period adjustments” and “extraordinary items” for 2021 – 2023 to date are
provided in FLS-W-23-01 IPUC DR 25 Attachment 1.
FLS-W-23-01
IPUC Staff DR 25
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 27
Please provide the Company's practice for determining uncollectible accounts and its
policy for customer account deposits and terminations.
Response:
The rate of uncollectible accounts in 2022 was 0.523% of operating revenues. The
Company’s practice for determining uncollectible accounts and its policy for customer
account deposits and terminations comply with IDAPA 31.21.01 (Utility Customer
Relations Rules) and its tariff. The Company does not currently require customer
deposits. When a customer terminates with a balance owing, the Company contacts
the customer if the balance becomes 60 days past due. At 90 days past due, the
customer account is written off as a bad debt and sent to a collection agency.
FLS-W-23-01
IPUC Staff DR 27
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 30
Please explain the difference in Account 601.5 Field Labor, as filed in the Application
(Exhibit 2, Column A) and the amount reported in the Company's 2022 annual report for
the same Account.
Response:
In the Company’s 2022 annual report, the amount of $311,326 is the sum of the
amounts shown in Exhibit 2, Column A of the Application for Account 601.5 – Field
Labor, $368,625 and Account 602- Payroll Expense Contra Account, ($57,299).
Account 602 is the account for field labor that is capitalized on capital projects. The total
labor cost in the Exhibit 2, Column A ties to the Annual Report but it just broken out
slightly differently in the rate case presentation.
FLS-W-23-01
IPUC Staff DR 30
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 31
Please provide a current hydraulic model of the Company's water system.
Response:
The hydraulic model file for the Falls Water system is available at FLS-W-23-01 IPUC
DR 31 Attachment 1. The model is created in EPANet 2.2, a public domain modeling
software from the U.S. Environmental Protection Agency. The attachment is only
viewable in EPANet, which is available to download for free at
https://www.epa.gov/water-research/epanet. If Staff has any issues with viewing the
attachment and/or wants to meet with the Company to review the model, please contact
the Company’s General Manager.
The Taylor Mountain and Morningview water systems do not have current hydraulic
models. The models are to be created as part of the Capital Facilities Plans being
completed in 2023.
FLS-W-23-01
IPUC Staff DR 31
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 32
Please provide the most recent version of the Company's Drinking Water Facilities
Capital Plan.
Response:
The most recent Drinking Water Facilities Capital Plans for Falls Water (2019) and
Morning View (2012) systems are attached as FLS-W-23-01 IPUC DR 32 Attachments
1 – 3. There is not a Drinking Water Facilities Capital Plan for Taylor Mountain but both
Morning View and Taylor Mountain are completing plans this year.
FLS-W-23-01
IPUC Staff DR 32
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Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 33
Please provide a copy of the Company's policy for water main extensions.
Response:
The Company’s policy for water main extensions can be found in FLW-W-23-01 IPUC
DR 33 Attachment 1, which is the published tariff for Falls Water Co., Inc. The main
extension policy is in Appendix A of the tariff, beginning on page 20 of the attachment.
FLS-W-23-01
IPUC Staff DR 33
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Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Adam Rue
Rates and Regulatory Water Program Manager, NW Natural
(626)-203-1733
Request No.: FLS-W-23-01 IPUC DR 34
Please provide the following for each meter size for each month from January 2021
through December 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.
Response:
The information requested for each of the items below is provided in FLS-W-23-01
IPUC DR 34 Attachment 1.
a. The number of billed customers is found in FLS-W-23-01 IPUC DR 34 Attachment
1, tab titled “Response to DR-34” in Columns (B), (I), and (T) for Falls Water, Taylor
Mountain and Morning View systems, for each rate class.
b. The total gallons provided at no charge as a part of the Minimum Charge is found in
FLS-W-23-01 IPUC DR 34 Attachment 1, tab titled “Response to DR-34” in Column
(E) for each rate class for the Falls Water system. The rate design for Taylor
Mountain system includes four tiers; the first tier has no charge associated with it
and can be found in Column (O). The Morning View system first tier has a
volumetric rate and can be found in Column (X).
c. The total gallons sold in excess of the gallons provided in the Minimum Charge is
provided in FLS-W-23-01 IPUC DR 34 Attachment 1, tab titled “Response to DR-34”
in Column (G) for each rate class. The Taylor Mountain system includes four tiers
that can be found in columns (O) through (R). The Morning View system tiered rates
can be found in Columns (X) and (Y).
FLS-W-23-01
IPUC Staff DR 34
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Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 35
For each of the Company's wells, please provide the quantity (gallons) pumped for each
month between January 2021 and December 2022.
Response:
The Company’s well logs for January 2021 – December 2022 are provided in FLS-W-
23-01 IPUC DR 35 Attachments 1 – 6.
FLS-W-23-01
IPUC Staff DR 35
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Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 36
Please provide the total 2022 actual special assessment fee that the Company was
assessed for and any supporting documentation (i.e., letter, invoice).
Response:
Attachment FLS-W-23-01 IPUC DR 36 Attachment 1 is the currently available
documentation in the form of a letter from the Bonneville Jefferson Ground Water
District with the pending assessment amount (subject to final Board approval). As stated
in the letter, the invoice is expected by July 1, 2023 for 2022 usage.
As shown in the letter, there are several components to Falls Water’s assessment:
Base Assessment: $12,719.78
Mitigation Assessment: $35,633.41
Total 2023 Assessment: $48,353.19
2022 Overuse Charges: $105,739.61
Total Assessment and Overuse Charges: $154,092.80
FLS-W-23-01
IPUC Staff DR 36
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Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 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.
Response:
The worksheet with the formulas enabled to support the proforma adjustment for the
Special Assessment fee can be found in FLS-W-23-01 IPUC DR 38 Attachment 1 on
Exh_2_(H) Amortization tab on line numbered 12. This is based on the amount accrued
as of 12/31/2022 of $153,000 in addition to the estimated assessment for 2023 of
$122,000, for a total of $275,000, which is amortized over a 2-year period for a
$137,500 revenue requirement impact.
These costs are combined with the Rate Case Amortization to provide the Account No.
666 – Rate Case Amortization line in Exhibit 2 – Proforma Results of Operations.
FLS-W-23-01
IPUC Staff DR 38
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Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 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 following
information:
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.
Response:
a. As referenced in FLS-W-23-01 IPUC DR 36 Attachment 1, the status of the breach
and the impact on the Company is that negotiations among the parties have been
unsuccessful to date. The Surface Water Coalition filed a breach in April 2023 and
the Bonneville Jefferson Ground Water District is actively working to mitigate this
claim by leasing water. The associated costs translate to assessment for the
Company.
b. As referenced in FLS-W-23-01 IPUC DR 36 Attachment 1, the implications of the
breach to the Company include the current and future assessment costs. Both the
Company and the Bonneville Jefferson Ground Water District are actively working
to mitigate the financial impact of the assessment by acquiring and leasing water
rights.
FLS-W-23-01
IPUC Staff DR 41
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Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 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.
Response:
The Company intends to include the savings that will come from the November 30,
2023, water right purchase to Account No. 610 – Purchased Water, but such savings
are not known or measurable at this time.
It is difficult to determine the volumes of the impact at this time as it is dependent on
assessment and determination of the Idaho Department of Water Resources (IDWR or
Department).
The transfer application has an estimate of the acre feet of water that the IDWR may
grant in the transfer based upon the high production year of the parent water right in
2013, but the ultimate allotment will not be known until granted. The application shows
2.97 acre-feet per acre. The purchase agreements state the acres purchased are 50.5,
not the 60 acres that was estimated at the time the rate case was filed.
Additionally, due to IDWR procedural changes, the Department no longer will allow the
irrigation water right to be moved to a municipal provider as an irrigation right. They will
change the use to municipal, and with that change of use, the volume of the water right
will likely be decreased. The Company is not aware of what the Department’s final
numbers will be until the application is reviewed and approved. Therefore, it is uncertain
what savings will be available to pass on to the customers. The Company will provide
this information to the Commission once it has received the final order from IDWR.
The final order by IDWR may take 2-3 months to be issued and, therefore, the Company
requests the ability to continue to track the impact of the District’s assessment and offsetting
impact of water rights acquisitions in the Deferral Account established in FLS-W-22-01.
FLS-W-23-01
IPUC Staff DR 42
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Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Jeremy Aird
Director of Accounting and Finance, NW Natural Water
(503)-610-7927
Request No.: FLS-W-23-01 IPUC DR 43
Please provide the cost allocation manual of NW Natural Water for its subsidiaries.
Response:
Please see FLS-W-23-01 IPUC DR 43 Attachment 1 as requested, which covers NW
Natural Water and its subsidiaries.
FLS-W-23-01
IPUC Staff DR 43
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Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 47
Please explain the rationale for the Company to purchase the John Deere riding
lawnmower in 2020. Bruce Attachment I-B at 7.
Response:
The John Deere riding lawnmower was purchased in 2020 to replace a Craftsman riding
lawnmower. The mower is used to mow the well lots and is used with a spray tank
trailer to address noxious weeds on the Company’s properties.
FLS-W-23-01
IPUC Staff DR 47
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Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Adam Rue
Rates and Regulatory Water Program Manager, NW Natural
(626)-203-1733
Request No.: FLS-W-23-01 IPUC DR 48
Please provide the following for 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
Response:
The information requested for each of the items below is provided in FLS-W-23-01
IPUC DR 34 Attachment 1. As indicated on the attachment, the Falls Water data is
provided in thousand gallons and the Taylor Mountain and Morning View are provided in
gallons.
a. The number of billed customers is found in FLS-W-23-01 IPUC DR 34 Attachment
1, in Column (B), (I), and (T) by rate class for the Falls Water, Taylor Mountain, and
Morning View systems, respectively.
b. The average gallons used per billed customer by rate class can be found in FLS-W-
23-01 IPUC DR 34 Attachment 1 in Column (E), (N), and (W) by rate class for the
Falls Water, Taylor Mountain, and Morning View systems, respectively.
c. The average gallons used per billed customer at no charge as a part of the
minimum charge can be found in FLS-W-23-01 IPUC DR 34 Attachment 1 in
Column (C) for the Falls Water system. The first tier for the Taylor Mountain system
has no volumetric rate and can be found in Column (J). The Morning View system
does not have a “no charge” volumetric amount.
FLS-W-23-01
IPUC Staff DR 48
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d. The average gallons per billed customer in excess of the maximum gallons allowed
in the minimum charge can be found in FLS-W-23-01 IPUC DR 34 Attachment 1 in
Column (D) for the Falls Water system. The four-tiered average volumes for the
Taylor Mountain system can be found in Columns (J) through (M). The two-tiered
volumes for the Morning View system can be found in Columns (U) and (V).
FLS-W-23-01
IPUC Staff DR 48
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