20230711FLS to Staff 36.pdf

FALLS WATER CO., INC.’S FIRST SUPPLEMENTAL RESPONSE 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]
[16833075_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 FIRST
SUPPLEMENTAL 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 supplemental response to Production Request No. 36. Responsive
documents are available for download using the link provided in the accompanying email.
DATED July 11, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
Tuesday, July 11, 2023 3:06:12 PM
IDAHO PUBLIC
UTILITIES COMMISSION
FALLS WATER CO., INC.’S FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on July 11, 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 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:
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
Supplemental Response:
The Company provided the letter documenting the estimated special assessment as
FLS-W-23-01 IPUC DR 36 Attachment 1. This letter dated July 3, 2023 signed by Brad
Buttars, Manager, BJGWD is now supplemented with the actual invoice in FLS-W-23-01
IPUC DR 36 Attachment 2. Additionally, the Company received another letter to clarify
the current circumstances from the Bonneville-Jefferson Ground Water District that is
provided in FLS-W-23-01 IPUC DR 36 Attachment 3 for further context.
FLS-W-23-01
IPUC Staff DR 36 - First Supplement
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