20230724FLS to Staff 57_64_69_71_72.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]
[16858460_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.
DATED July 24, 2023.
GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
Monday, July 24, 2023 3:55:02 PM
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 24, 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 57
For each well used by the water system, please provide the following:
a) The Idaho Department of Water Resources Well Tag Number (D-Tag Number)
currently on-file with IDWR.
b) Location (Township, Range, Section, and Tract)
Response:
Well ID Numbers for Falls Water Wells at all Systems:
Falls Water’s Wells:7100030
Well #1 – E0007128 - T2N R38E SEC14 NE1/4 SW1/4
Well #2 – E0007131 - T2N R38E SEC14 NE1/4 SW1/4
Well #4 – E0007130 - T2N R38E SEC14 NE1/4 SW1/4
Well #5 – E0007132 - T2N R38E SEC11 NW1/4 NW1/4
Well #6 – E0007129 - T2N R38E SEC14 NE1/4 SW1/4
Well #8 – E0008065 - T2N R38E SEC10 NE1/4 SW1/4
Well #9 – D0048514 - T2N R38 E SEC10 SE1/4 NE1/4
Well #10 – D0073750 - T2N R38E SEC2 NW1/4 NW1/4
Well #11 – D00841000 - T2N R38E SEC9 NE1/4-NW1/4
FLS-W-23-01
IPUC Staff DR 57
Page 1 of 2
Taylor Mountain’s Wells: 7100023
Well #1 – E0007186 – T1N R38E SEC21 SE1/4 SW1/4
Well #2 – E0007187 - T1N R38E SEC28 NE1/4 SW1/4
Morning View’s Wells: 7260063
Well #1 – E0006772 - T4N R39E SEC30 NW1/4 NE1/4
Well #2 – E0006771 - T4N R39E SEC30 NW1/4 NE1/4
Well #3 – D0062972 - T4N R39E SEC30 NW1/4 NE1/4
FLS-W-23-01
IPUC Staff DR 57
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 64
Please provide annual data over the past 5 years including total amount of water
production (gallons), the total amount of Pure Chlorine used (in pounds), and total
expense for Chlorine purchase (including Sales Tax) for each well. Please provide a
breakdown for FW, TM, and MV customer systems. Also please specify whether a solid
or liquid form of Chlorine was used for each system.
Response:
FLS-W-23-01 IPUC DR 64 Attachment 1 represents the Chlorine purchases for the
Falls Water system; FLS-W-23-01 IPUC DR 64 Attachment 2 shows pounds of pure
chlorine per well for each well in Falls Water’s system that is chlorinated (Wells 2, 4, 5,
8, and 9, were chlorinated from 2018 through 2022; Well 10 was chlorinated starting in
2020).
The Morning View water system and Taylor Mountain water systems are not
chlorinated.
The cost of chlorine spreadsheet shows the chlorine purchased during the past five
years. It does not allocate the purchases by well as it is purchased in bulk.
FLS-W-23-01
IPUC Staff DR 64
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 69
Please provide information on what is being done with the 2006 service pickup that is
being replaced by the purchase of the 2015 Ford F-250 in Bruce's direct testimony page
5, line 15.
Response:
The 2006 Ford F-250 was sold for $1,500 on April 17, 2023. The truck was having
numerous mechanical issues. Repairs had been made on the truck on December 10,
2021, for $1,267 and August 25, 2022 for $3,983. The truck had 174,073 miles and
was seventeen years old. The interior was in bad condition with tears in the upholstery.
The $1,500 was not included as a pro forma adjustment in the rate case filing.
FLS-W-23-01
IPUC Staff DR 69
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 71
Please provide the ending balance of the Special Plant Reserve Fund as of December
31, 2022. Also provide an update of the balance to current date.
Response:
The ending balance of the plant reserve for December 31, 2022 and to date can be
found in FLS-W-23-01 IPUC DR 12 Attachment 1.
FLS-W-23-01
IPUC Staff DR 71
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 72
In Order No. 34925, the Commission ordered the Company to use $ 100,000 of the
special plant reserve fund as a CIAC. Please provide information as to where this is
listed in this rate case.
Response:
The item was not shown separately in the rate case application. The Company did
apply $100,000 of CIAC from the special plant reserve fund to a looping project on
Crowley Road (45th East) connecting the mainline in East First Street to the mainline in
John Adams Parkway and Cochise Drive to the south of First Street. The entire project
value is $188,733. $100,000 of the project was completed with the CIAC funds and
$88,733 was completed with Company funds.
FLS-W-23-01
IPUC Staff DR 72
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