20230714FLS to Staff 8-9_44-45.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]
[16844112_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 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 FIRST 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 8
Company Witness Scott Bruce briefly described a new assessment management
software, "Elements software." Bruce Direct at 5. Please provide a cost-benefit analysis
for the new software. Please include a brief description of the current system
the Company utilizes and any alternatives that were considered.
Response:
The cost-benefit analysis is found in FLS-W-23-01 IPUC DR 8 Attachment 1. The
attached analysis illustrates the direct cost benefit. In addition, the operational benefits
are discussed in detail below.
While the cost savings do not offset the annual fees, the work-flow benefit derived from
using Elements gives the Company the ability to integrate the billing software and the
GIS asset management software it is currently using. The ability to better track asset
maintenance will allow the Company to schedule and track preventative maintenance
on the assets. It also will allow the Company to prepare replacement programs for its
assets.
Falls Water is currently using disparate and paper-based workflows for completing
common water and wastewater system tasks. This results in inefficient workflows for
the Company’s staff. The lack of integration between the current work order system
(UMS) and the Geographic Information System (GIS) results in varied or minimal data
reporting on the status of the Company’s assets.
Current system: UMS Service Orders
Currently the work orders are input in the Continental Utility Solutions, Inc. (CUSI) billing
software UMS. The work order system is inefficient because the service technicians
receive paper-work orders that must be completed by the technician and manually
returned to the office staff to be completed. To complete the work order in UMS, the
FLS-W-23-01
IPUC Staff DR 8
Page 1 of 2
office staff must enter multiple modules of the UMS software to complete items like
meter installs, radio transmitter installs, and replacements of these metering devices.
If an urgent work order response is necessary, the office staff must contact the
technicians by phone to give them the work order service address and the work to be
performed.
If the work order pertains to distribution assets (e.g., water mains, wells, valves,
hydrants), a work order cannot be created in UMS. This prevents accurate updates to
the ESRI GIS asset management system because no paper or electronic trail exists to
facilitate the data entry. Elements will update the GIS data when the work order is
closed in Elements.
Elements XS
Designed specifically for smart utilities and governments, Elements XS is an all-
inclusive browser-based solution that can be accessed from anywhere on any device.
Elements XS integrates seamlessly with ESRI’s ArcGIS platform as well as many other
enterprise applications to leverage an organization’s existing technology investments.
Elements XS is an all-inclusive application that allows any asset within any department
to be managed without purchasing separate modules, and the application works with
any standard web browser on any device, accessible via cloud or on premises
deployments. Elements XS users can further enhance the application by defining
unique workflow processes to streamline operations and fulfill the unique business
requirements of organizations both small and large. Elements XS provides robust tools
for asset management, work management, inventory control, project management, and
reporting analysis.
MaintainX
NW Natural Water's Corporate IT department considered and performed due diligence
on another asset/work management solution called MaintainX. That solution, however,
does not meet the security and operational requirements of the business. MaintainX
does not support key integrations with the Company's existing technology investments
such as Falls Water’s Customer Information System (UMS) and Geographic Information
System (ESRI). MaintainX is useful for the tabular tracking of assets, inventory, and
service orders, but does not support map-based and customer location-based
workflows. Given that the vast majority of Falls Water’s assets have a geographic or
customer location-based relationship, it is a crucial requirement that the asset and work
management system supports Geographic and Customer Information System
integrations.
FLS-W-23-01
IPUC Staff DR 8
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 9
For the Element Software in Exhibit 1, Column E. Please include the following:
a. Supporting documentation for the estimated cost.
b. All Fixed and Variable costs associated with the software.
c. Primary users of the software.
d. An explanation of how the software will benefit customers.
Response:
a. The Elements software License Agreement and Sales Agreement are in the
process of being executed. The Company will supplement this response with fully-
executed versions of the License Agreement and the Sales Agreement upon their
receipt.
b. The fixed and variable costs are as follows:
 Onboarding services - Fixed Cost - $34,500 (one-time cost)
 Annual Maintenance - Fixed Cost - $6,400/year (Estimated annual maintenance
fee for Falls Water, which is based on pro-rated share using customer count
from the invoiced amount of $17,500 as shown in FLS-W-23-01 IPUC DR 9
Attachment 1).
 Professional Services - Variable Cost - $120/hour
c. All Falls Water Company employees are users of the software.
d. The benefits to customers include the following:
Faster service delivery and increased customer satisfaction: Elements XS
integrates with our existing technology investments, Customer Information/Billing
System (UMS) & Geographic Information System (ESRI). These system
integrations enable streamlined and efficient workflows, eliminating the need to
FLS-W-23-01
IPUC Staff DR 9
Page 1 of 2
jump between multiple systems to track down information and complete
tasks/workflows. Elements XS’ GIS and Utility Billing system integrations enable
a highly efficient workforce, resulting in faster service delivery and increased
customer satisfaction. With less time spent working in disparate systems,
searching for information, and manual data entry, staff members will be able to
respond to service requests quicker, and complete more work each day.
Shorter outage times and disruption of service: The geospatial location of
utility assets stored in Falls Water’s GIS database will be accessible directly in
the Elements XS mapping interface. The spatial awareness of utility
infrastructure allows field staff to quickly locate assets and retrieve valuable
information on those assets. For example, in the event of a water mainline
break, less time will be spent locating the proper valves to isolate the break,
resulting in quicker repairs and water service restoration.
Greater customer communication: Elements XS enables increased
operational awareness and access to historical data on assets and customer
locations. The ability to quickly retrieve this data from anywhere on any device
promotes informed, data driven customer communication. Admin staff members
will be well informed on what’s happening in the field and have access to
historical work or current work being performed at customer locations. For
example, if a customer called the office inquiring about why a Falls Water field
staff member was performing work on their water meter, the customer service
representative can quickly launch the customer location in the Elements system,
view detailed history of work at that location, and relay relevant information back
to the customer.
Enhanced analysis and business metrics for capital improvement
projects: The ability to track and monitor lifecycles of the Company’s assets in
Elements XS will allow Falls Water to identify business risk and make data
driven decisions on capital improvement projects. Customers will be confident
knowing that rate impacts resulting from capital improvement projects will be
supported by analysis and metrics captured in the Company’s asset
management system.
Safe and reliable service delivery: Elements XS will enable Falls Water to
better manage the Company’s preventative maintenance programs and
streamline preventative maintenance tasks, thus reducing risk to the water
system while ensuring reliable service to customers.
FLS-W-23-01
IPUC Staff DR 9
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:
Jeremy Aird
Director of Accounting and Finance, NW Natural Water
(503)-610-7927
Request No.: FLS-W-23-01 IPUC DR 44
Please provide Capital and Operations & Maintenance ("O&M") informational
technology and services ("IT&S") expenses for NW Natural Water from 20202022
allocated to the Company. Please explain how NW Natural Water allocates Capital
and O&M IT&S expenses to its subsidiaries and please provide supporting worksheets.
Response:
Please see FLS-W-23-01 IPUC DR 44 Attachment 1 for a summary of all Internal IT
charges from 2020 through 2022. We have primarily used IT contractors during most of
this period. In Q3 '22 we moved to hire our two main contractors as full time FTEs to
retain their knowledge and experience with each of the water subsidiary’s IT
Infrastructure and needs. The contractors have time written to projects, some are
directly to the benefit of specific IT infrastructure of a water sub and some is for shared
IT infrastructure. Where it is specifically identified, we directly charge those costs to the
appropriate benefitting entity. Where it is common infrastructure or support, it is
allocated out using the Massachusetts method. The attached file shows the detailed
calculations of the total costs and how they were directly identified for Falls Water’s
benefit and the amounts that are an allocation of shared infrastructure.
The costs are allocated into 3 different categories as follows:
1. Traditional PP&E - for costs that are identified as a capital asset. Examples
would be hardware installations or software rights purchases and setup.
2. Cloud Computing Arrangements - these can be classified as either a LT Prepaid
or Capital asset. If it does not qualify for capitalization as traditional software, we
then record as a LT Prepaid and amortize it over the estimated useful life of the
associated expenditure.
3. Support - Some of the work is simply support, things such as calls to help
fix/maintain IT Infrastructure. If it does not add additional functionality to the IT
infrastructure, it is generally considered maintenance or O&M cost.
FLS-W-23-01
IPUC Staff DR 44
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 45
Please provide Capital and O&M IT&S expenses for the Company from 2020-2022 and
please provide supporting worksheets.
Response:
Please see FLS-W-23-01 IPUC DR 45 Attachment 1 for the requested information. It
shows the O&M and Capital and split the amounts between Externally procured or
Internally provided. Additionally, it shows the amount of costs charged out to the
unregulated Taylor Mountain wastewater system managed by the Falls Water team.
FLS-W-23-01
IPUC Staff DR 45
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