20230714FLS to Staff 49_51-52_58_60-61_70.pdf

FALLS WATER CO., INC.’S RESPONSES TO SECOND 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]
[16812436_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 RESPONSES
TO SECOND 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 23, 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 14, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
2023 JULY 14, 2023 4:18PM
IDAHO PUBLIC
UTILITIES COMMISSION
FALLS WATER CO., INC.’S RESPONSES TO SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on July 14, 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 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.
Response:
The Company creates its list of capital expenditure projects annually for the capital
budget. These projects originate from the prioritized list of projects in the Capital
Facilities Plan for each water system. The capital budget is submitted to corporate
management for approval. In this way, the Company invests in projects that have been
prioritized in the plan to be most effective in improving the system to benefit the
customers.
The Capital Facilities Plan provides alternatives when an alternative project is possible.
For example, if a supply deficiency is identified, the source of supply could be
supplemented by either building another well or by building a storage tank and booster
pump station. The storage tank option would also alleviate 10 - 15-pound pressure
variations in the isolated areas of the water system caused by delays from well pumps
starts and stops in response to system pressures.
Smaller projects, such as service lines and meter barrel replacements, and short
looping projects (less than 400 feet), and some wellhouses, that the Company staff
have the skills and equipment to undertake are performed in-house. Large projects,
such as drilling new wells and long looping projects (over 400 feet), that the Company
does not have the proper equipment or expertise to perform are typically bid out when
they estimated to cost over $150,000, or a negotiated price is reached with a trusted
contractor if below that threshold. The Company closely monitors projects’ adherence to
budget and timeline when contracted out.
FLS-W-23-01
IPUC Staff DR 49
Page 1 of 2
The Company currently does not have written documentation of its policies and
procedures documenting the process.
FLS-W-23-01
IPUC Staff DR 49
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 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.
Response:
The Company will act as general contractor on projects it has the equipment, labor, and
expertise to complete using its existing staff. Subcontractors may be brought in to
expedite some phases of the project. For example, the Company used its staff to build
the last three wellhouses (Well 10, Well 11, and the wellhouse at Taylor Mountain’s Well
2). In each case, the concrete, framing, electrical, and external siding and roofing were
subcontracted.
The Company staff will perform the work on small looping projects that will not affect
service to customers. Staff will also perform service line replacements, fire hydrant
repairs/replacements, and other small dig ups. These projects are best performed by
our staff to get the jobs done as quickly and efficiently as possible.
Large projects, that require equipment not owned by the Company or that would disrupt
traffic flows longer than needed, will be bid out to the third-party contractors. This
minimizes the disruption of public roads and provides the customers with upgrades to
the system in a timely manner.
FLS-W-23-01
IPUC Staff DR 51
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 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.
Response:
The Company will receive bids on materials from its suppliers to get the best price on
smaller projects that its staff is capable of completing. When jobs are completed by
Company staff, mobilization and equipment costs otherwise charged by third-party
contractors are costs not incurred for the project.
The Company receives bids on larger projects to assure that the lowest cost/risk is
used.
FLS-W-23-01
IPUC Staff DR 52
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 58
Please provide the specified material requirements and construction details used in the
installation of the distribution system piping.
Response:
The material requirements and construction details used in the installation of distribution
system piping can be found in the Supplement to the Idaho Standards for Public Works
Construction, which is provided as FLS-W-23-01 IPUC DR 58 Attachment 1.
FLS-W-23-01
IPUC Staff DR 58
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 60
Please provide the monthly power 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.
Response:
The monthly power bills are provided in folders labeled ELECTRIC and GAS for electric
and gas invoices received at each of the Company’s facilities for Falls Water, Taylor
Mountain, Morningview, Field Offices, and Main Office sites.
FLS-W-23-01
IPUC Staff DR 60
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 61
Please provide the monthly metered amount of water (gallons) pumped from each well
over the past 5 years. Please provide a breakdown for FW, TM, and MV customer
systems.
Response:
The monthly metered amount pumped from each well over the past five years (or since
acquisition) is provided in FLS-W-23-01 IPUC DR 61 Attachments 1 – 3 for the Falls
Water, Taylor Mountain (since August 3, 2020), and Morningview systems (since
January 1, 2021), respectively. The volumes are provided through June 2023.
FLS-W-23-01
IPUC Staff DR 61
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 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.
Response:
We have two types of Prepaid balances on the Falls Water balance sheet as follows:
1. Prepaid Insurance - our renewals for insurance coverages span 12 months. We
recognize this a current prepaid asset and amortize it on a straight-line basis
over the 12-month period.
2. LT Prepaid - our cloud computing arrangements are recognized as a LT Prepaid
and amortized over an estimated useful life of three years.
In addition to amortizing the prepaid balances we also amortize our CIAC liabilities. The
amortization period would be consistent with the underlying asset that the CIAC was
going to fund and would be amortized as an offset to depreciation expense.
The Company does not have a written policy on amortizing assets.
FLS-W-23-01
IPUC Staff DR 70
Page 1 of 1