20230713FLS to Staff 4_10_13_37_40_.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]
[16841513_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 13, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
2023 JULY 13, 2023 4:45PM
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 13, 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 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.
Response:
a. The dates when the plant additions were placed in service, or are expected to be
placed in service, can be found in columns (N) and (O) of FLS-W-23-01 IPUC DR 4
Attachment 1.
b. Supporting documentation for columns (B) through (M) of Exhibit 1 are found at
FLS-W-23-01 IPUC DR 4 Attachment 2. Columns (C) and (D) include actual
invoiced costs and estimates in separate tabs in FLS-W-23-01 IPUC DR 4
Attachment 1.
FLS-W-23-01
IPUC Staff DR 4
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 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.
Response:
The list of contractors with contract amount, related project and location, and completion
date is found in FLS-W-23-01 IPUC DR 10 Attachment 1.
FLS-W-23-01
IPUC Staff DR 10
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 13
Please describe how all overheads (including but not limited to materials, labor,
supplies, vehicles, etc.) are allocated among plant and expense accounts.
Response:
There are two different types of overheads:
1. Falls Water Overheads – Applicable to overheads such as administrative labor
and shared office supplies and costs; we allocate these overhead expenses to
Morningview and Taylor Mountain as their respective percentage of total
connections. Capitalized projects for each system are done for each system.
Field servicemen’s time is allocated to each system for the actual time worked at
each system.
2. Corporate Overheads – There are several types of corporate overhead costs that
are allocated to Falls Water.
a. Northwest Natural Gas Company employees working for NW Natural
Water Company, LLC (“NW Natural Water”) – the shared services model
allows us to access utility industry experts without the commitment of a
full-time employee. Please refer to the Company’s response to FLS-W-
23-01 IPUC DR 20 for a full list of functions and costs. These costs to
date have all been expensed as O&M, but if the employees were engaged
in a capital project we would capitalize these costs.
b. NW Natural Water employees – there are currently eight such employees
serving the functions of Accounting & Finance, Human Resources, and IT.
These employees are fully dedicated to NW Natural Water and its
subsidiaries. The Accounting & Finance and Human Resources
employees’ time is charged out using the Massachusetts model and are
expensed O&M. The IT employees do time write and are charged out to
FLS-W-23-01
IPUC Staff DR 13
Page 1 of 2
the NW Natural Water subsidiaries based on their time spent and cost as
identified to a capital project or O&M project. There are some projects or
time that benefit all NW Natural Water subsidiaries, and such projects or
time would then be charged out based on the Massachusetts model. The
costs hit one of three categories:
i. Capital – costs classified as PP&E where appropriate – example
would be labor costs associated with installing new hardware.
ii. Long Term Prepaids – costs of Cloud Computing arrangements are
not classified as PP&E, but as LT Prepaids and amortized to O&M
expense over a three-year life.
iii. O&M – costs related to maintenance and support for the IT
function.
c. NW Natural Water external 3rd party costs – Costs are incurred at the NW
Natural Water level; please see the Company’s response to FLS-W-23-01
IPUC DR 20 for full details. The largest such cost is the audit. These are
costs incurred for the benefit of all NW Natural Water subsidiaries and are
allocated via the Massachusetts methodology.
FLS-W-23-01
IPUC Staff DR 13
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 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).
Response:
The details of the amounts accrued in 2022 related to the groundwater mitigation are
found in FLS-W-23-01 IPUC DR 37 Attachment 1. The accrual for estimated
assessments were the only costs booked to the deferral account for 2022.
FLS-W-23-01
IPUC Staff DR 37
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 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.
Response:
The Company’s available water production level is constrained by several factors. First,
the well capacity; second, the available water rights; and third the constraints of the
baseline for the mitigation. The supporting worksheet FLS-W-23-01 IPUC DR 40
Attachment 1 includes the water rights and description in Columns (A) through (G),
priority date in Column (H), diversion rate in Column (I), volumes in Column (J), date
acquired in Column (N), and estimated proportion of baseline and estimated addition to
the baseline in Columns (O) and (P).
First, the capacity of the wells in the Falls Water system is roughly 13,100 gallons per
minute (shown in table on Column (T)). The Taylor Mountain and Morning View
systems’ wells add an additional 413 and 1,050 gallons per minute of capacity to the
system, respectively.
Second, the Falls Water system owns approximately 5,353.40 acre-feet of water rights
and has leased rights to an additional 97.07 acre-feet of water rights. The owned and
leased water rights correspond with 1.776 billion gallons of water. The Taylor Mountain
and Morning View systems’ water rights add an additional 149.1 acre-feet and 288.8
acre-feet, respectively, for a total of 5,888.37 acre-feet of water rights. This corresponds
with 48.6 and 94.1 million gallons of water rights, respectively, for a total of 1.919 billion
gallons of water rights, annually. The owned and leased water rights are found in
Column (J) of the attached file.
Finally, the baseline currently allows 3,732 acre-feet of production. This corresponds to
less than 70% of the water rights owned or leased by the Company that were used in
the baseline calculation. The additional purchases of 175.4 acre-feet of water rights
FLS-W-23-01
IPUC Staff DR 40
Page 1 of 2
have an estimated impact on the baseline of 113.24 acre-feet, which would increase the
baseline to 3,845.24. This is reflected in Columns (O) and (P).
The Column (P) is an estimate based on that water right’s percentage of the total water
right owned or leased by the Company during the 2015 agreement’s baseline years of
2010 to 2014. The Company’s water rights are not assigned to a specific well. The
rights have all wells in the water system listed as diversion points. It is therefore not
possible to determine with any exactness what amount of the water rights’ volume is
attributable to Bonneville-Jefferson Ground Water District’s baseline calculation. The
calculation was based on well productions during the base years.
Water rights 25-7086, 25-14516, and 25-14517 were acquired after the baseline years.
The volume listed in column (P) is the amount of the water right that increases the
baseline number. Water rights 25-14482 and 25-14483 should also increase the
baseline number, but the amount of the increase has not been verified by the Ground
Water District. The Company will provide the additional amount once the information is
made available.
FLS-W-23-01
IPUC Staff DR 40
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