20230725FLS to Staff 55-56_59_62_65-66_68_73.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]
[16861728_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 25, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
2023 JULY 25, 2023 4:21PM
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 25, 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 55
Please provide a thorough and complete description of the system. This should include any
deficiencies known that need to be addressed to maintain system integrity and efficiency
(e.g., to remove iron or other chemical deposits) and to support growth, as well as any
changes/investments that the Company plans to implement to address deficiencies relative to
items included below. Include the costs and benefits for any investments or increases in
expense.
Response:
The Company’s Drinking Water Capital Facilities Plan can be found at FLS-W-23-01 IPUC
DR 32. In the plan, the system deficiencies are found in Table 4 under Section 2.6 on pages
19 and 20. The plan provides a list of proposed projects and what deficiencies the projects
will correct as found in Section 3.5 Tables 7, 8, 9, and 10.
The Company has completed some of the projects found in the tables of the Facilities Plan
referenced above. The table below lists projects completed and planned:
ID Project Description 2019 Cost
Estimate
Project
Completed
Completed
Cost
Planned
Date
A-1 Ryan Anderson Development
Well
$771,700 8/1/2022 $1,096,000 N/A
A-2 Crowley Road from 1st Street
to John Adams Pkwy (8”
Extension)
$319,000 8/31/20 $188,732.6
8
N/A
A-3 Lincoln Road from 4743 E to
Wood River Road (12”
Extension)
$70,500 5/26/21 $21,597.32 N/A
A-4 Replace 6” Pipe in Fall River
Road with 8” Pipe
$72,900 10/5/21 $35,743.76 N/A
A-5 Replace 6” Pipe in Edwards
Drive with 8” Pipe
$183,300 N/A N/A 2024
A-6 Harding Lane from Kit Lane to
1st Street (8” Extension)
$95,900 Estimated
7/31/2023
Estimated
$23,095.18
N/A
FLS-W-23-01
IPUC Staff DR 55
Page 1 of 3
ID Project Description 2019 Cost
Estimate
Project
Completed
Completed
Cost
Planned
Date
A-7 25th East and Iona Road
Waterline Extensions
$1,233,800 6/30/20 $986,971.6
2
N/A
A-8 Ammon Road From Pearce
Drive to Greenwillow Drive
(12” Extension)
$147,800 Line already
exists
N/A N/A
A-9 Ammon Road From
Greenwillow Drive to O’Bryant
Street (10” Extension)
$187,200 N/A N/A 2024
A-
10
Replace 6” Pipe in Dixie
Street with 10” Pipe
$42,600 N/A N/A 2024
A-11 Replace 8” Pipe East of Well
2 with 12” Pipe
$37,400 N/A N/A 2025
A-
12
First Street from Robison
Drive to Wheatfield Lane (10”
Extension)
$245,100 N/A N/A 2026
A-
13
First Street from Ammon
Road to Nassau Drive (10”
Extension)
$278,800 N/A N/A 2026
A-
14
Fallsbrook asbestos cement
pipes – Lakewood Street and
Upland Street
$411,900 N/A N/A 2027
A-
15
Fallsbrook asbestos cement
pipes –Jensen Drive
$141,900 N/A N/A 2026
A-
16
Fallsbrook asbestos cement
pipes –Contour Avenue
$454,800 N/A N/A 2025
A-
17
Fallsbrook asbestos cement
pipes –Crawford Street
$131,100 N/A N/A 2025
A-
18
Fallsbrook asbestos cement
pipes –North Adams Drive
$166,500 N/A N/A 2027
A-
19
Fallsbrook asbestos cement
pipes –Mobile Drive
$67,400 N/A N/A 2026
A-
20
Increase the volumetric water
right capacity by at least 535
acre-feet and the diversion
rate by 3,170 gpm
$1,230,500 Have
acquired
383.4 AF
and 915.61
gpm
N/A Ongoing
A-
21
Reconfigure the SCADA
system control of pump start
and stop triggers
$34,500 N/A N/A 2023
B-1 New 2.0 MG Storage Tank $2,517,200 N/A N/A 2023
B-2 New Booster Pump Station
with 5,500 gpm capacity
$426,700 N/A N/A 2023
B-3 New Tank Pipeline Upgrades $367,800 N/A N/A 2023
FLS-W-23-01
IPUC Staff DR 55
Page 2 of 3
The Company does not have revised costs for the planned future projects. Most of the
planned projects, with the exceptions of the Ryan Anderson Development Well (Well 11) and
the 2.0 MG storage tank and booster pump station, do not increase operations and
maintenance expenses. The electrical power bills for Well 11 have been provided in the FLS-
W-23-01 IPUC DR 60 response. The booster pump station will have increased power costs
for the two vertical turbine pumps that will pump storage water into the distribution system.
No information was available to estimate the increased electrical costs of the demand charge
and commodity charges. The storage tank will require sand to be cleaned out every few
years. The Company does not have a cost estimate available at this time.
FLS-W-23-01
IPUC Staff DR 55
Page 3 of 3
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 56
Please provide up-to-date and separate geo-spatial system maps that outline all
contiguous water utility systems operated by Falls Water in the State of Idaho. The map
should include the location and elevation of major equipment including wells, distribution
piping, storage tanks, booster pumps, shut-off valves, meters, fire hydrants, water
treatment equipment, etc. Please include the following information by breaking them
down for Falls Water ("FW"), Taylor Mountain ("TM"), and Morning view ("MV")
customer systems.
a) The depth, width, length, capacity, construction materials of each well (including
backup wells, if any), and length of time in service.
b) The make, model, type, and rating of each well pump motor, and length of time in
service.
c) The make, model, capacity, and limit switch settings of each pressurized storage
tank, and length of time in service.
d) The make, model, capacity, and limit switch settings of each unpressurized
storage tank/reservoir, length of time in service.
e) The make, model, and rating of each booster pump and motor, and length of time
in service.
f) The make, model, and capacity of all water treatment equipment, and length of
time in service.
g) The year, make, model, and capacity for backup generation supporting the well
pumps, and length of time in service. Indicate if the generation has an Automatic
Transfer Switch (ATS) or if it must be manually started.
h) The distribution piping line size and materials specified in the installation, and
length of time in service.
FLS-W-23-01
IPUC Staff DR 56
Page 1 of 2
NOTE: Please provide this map in an electronic format (.pdf) which can be scaled,
enlarged to identify all aspects of the system.
Response:
The information for each system requested in a – h is found if FLS-W-23-01 IPUC DR
56 Attachment 1.
The maps for the Morningview, Falls Water, Taylor Mountain systems can be found in
FLS-W-23-01 IPUC DR 56 Attachment 2 – 4.
FLS-W-23-01
IPUC Staff DR 56
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 59
Please provide information related to the capacity and sizing of the system and the
ability of the system to meet historical and future system peak demand. Information
would include not only capacity/constraints of/in the system, but also consumption and
consumption at peak periods.
Response:
The Falls Water 2019 Drinking Water Capital Facilities Plan submitted as FLS-W-23-01
IPUC DR 32 Attachment 1 – 2 provides the information on the capacity and sizing of the
system and ability to meet historical and future peak demand.
There is not currently available a facility plan for Taylor Mountain. The testimony of
Company witness Bruce provides details of the status and timing for a facilities plan on
page 6 lines 9 - 11.
The 2012 Morning View facilities plan submitted as FLS-W-23-01 IPUC DR 32
Attachment 3 provides the latest information on capacity, sizing and ability to meet
historical and future demand. The testimony of Company witness Bruce provides details
of the status and timing for an updated facilities plan on page 6 lines 12- 14.
FLS-W-23-01
IPUC Staff DR 59
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 62
Please provide the monthly metered total customer demands/water usage data
(gallons) over the past 5 years. Please provide a breakdown for FW, TM, and MV
customer systems.
Response:
The monthly metered demand for the three systems is provided in the attachments
listed below.
 Data for the Falls Water system are provided in FLS-W-23-01 IPUC DR 62
Attachment 1. The data reflect the period from January 2018 to June 2023.
 Data for the Taylor Mountain system are provided in FLS-W-23-01 IPUC DR 62
Attachment 2. The demand data were not included the billing system for August
and September 2020 for Taylor Mountain. However, the data are available from
October 2020 to June 2023. The Company was converting to the UMS Billing
system when Taylor Mountain was acquired, and the UMS system was used to
bill them in August and September 2020 but the data are not available.
Data for the Morning View system are provided in FLS-W-23-01 IPUC DR 62
Attachment 3. The customer demand data are available from February 2021 to
June 2023.
FLS-W-23-01
IPUC Staff DR 62
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 65
Please provide the Idaho Division of Environmental Quality Sanitary Survey for the past
3 years.
Response:
The latest surveys for Fall Water, Morning View, and Taylor Mountain are provided as
FLS-W-23-01 IPUC DR 65 Attachment 1 – 4.
 FLS-W-23-01 IPUC DR 65 Attachment 1 is the Falls Water Sanitary Survey from
2020.
 FLS-W-23-01 IPUC DR 65 Attachment 2 is the Morning View Sanitary Survey
from 2021.
 FLS-W-23-01 IPUC DR 65 Attachment 3 - 4 is the latest Taylor Mountain survey
from 2019. FLS-W-23-01 IPUC 65 Attachment 3 contains the deficiencies and
FLS-W-23-01 IPUC DR 65 Attachment 4 contains the photo log.
FLS-W-23-01
IPUC Staff DR 65
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 66
Please provide the average hourly pressure data in the main distribution line (averaged
over 7 days in each week for each hour) in each month over the past 3 years.
Response:
The average hourly pressure data in the main distribution line for the past three years is
found at FLS-W-23-01 IPUC DR 66 Attachments 1 – 3. The attached files have the
pressure data from the Company’s SCADA systems. Falls Water system has data for
each wellsite. Well 2 has the data for the well field which includes wells 2, 4, and 6. All
other wells are shown individually.
Pressure data are available from August 9, 2021 for Wells 1 and 2 and from August 10,
2021 for Well 3 for the Morning View water system.
Pressure data are available from August 11, 2021 for Well 1 and from August 10, 2021
for Well 2 for Taylor Mountain water system.
FLS-W-23-01
IPUC Staff DR 66
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 68
Please provide all documents/invoices to support the purchase of the following and
include any cost benefit analysis used by the Company justifying the purchases:
a. 2015 Chevy Silverado $28,634.00 purchased 8/5/22.
b. Brown flatbed $1,165.98 purchased 8/30/22.
c. Industrial shelving $9,529.71 purchased 9/17/22.
Response:
a. The 2015 Chevy Silverado flatbed truck was purchased on August 5, 2022, for
$28,634 to replace the 2007 GMC Sierra utility bed pickup to provide utility
service in the field. The 2007 GMC Sierra was sold for $5,500 on September 9,
2022. The invoices for the Chevy Silverado can be found in FLS-W-23-01 IPUC
DR 68 Attachment 1.
b. Toolboxes were purchased and installed on the 2015 Chevy Silverado to carry
tools and small inventory parts on the service truck. The toolboxes cost
$1,165.98. The invoices for the toolbox can be found in FLS-W-23-01 IPUC DR
68 Attachment 2.
c. The Company has increased its on-hand inventory because of the pandemic
induced supply-chain issues. This resulted in a need to safely store the
inventory. The industrial shelves were purchased to better utilize vertical space
in the warehouse. The shelves have a 6,800-pound capacity per shelf. They
provided safe storage for any inventory the Company maintains. The invoices for
the industrial shelving can be found in FLS-W-23-01 IPUC DR 68 Attachment 3.
FLS-W-23-01
IPUC Staff DR 68
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 73
Please explain how the CIAC for each account is calculated in Bruce's Exhibit No. I-B,
pages 1-7.
Response:
The CIAC for each account represented in Bruce’s Exhibit No. I-B represents
contribution made by developers or customers in aid of construction. The funds
collected are contributed to the utility and the amounts recorded into the CIAC account
are based on the amounts contributed spent by the Company on those projects. The
funds collected by developers or customer are used to finance CIAC related
investments. The CIAC amounts are an offset, or reduction, to rate base and lower the
revenue requirement.
The funds collected in CIAC are used to finance investments shown in Bruce’s Exhibit
No. I-B as summarized in the table below.
Account Description Amount
303 Land & Land Rights - CIAC $435,942.05
304 Well Structures & Improvements -
CIAC
$320,147.87
307 Wells - CIAC $85,585.43
311 Pumps - CIAC $159,163.47
FLS-W-23-01
IPUC Staff DR 73
Page 1 of 2
320 Seperators / Purification Systems -
CIAC
$17,174.55
331 Lines - CIAC $403,432.98
334 Meters - CIAC $827,913.57
335 Hydrants - CIAC $17,334.63
341 Transportation Equipment - CIAC $31,450.11
345 Power Operated Equipment - CIAC $86,701.18
Total $2,384,845.84
FLS-W-23-01
IPUC Staff DR 73
Page 2 of 2