20230727Staff 81-83 to FLS .pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF FALLS WATER )
COMPANY'S APPLICATION FOR )CASE NO.FLS-W-23-01
AUTHORITY TO INCREASE ITS RATES )AND CHARGES FOR WATER SERVICE )
)FOURTH PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF TO
)FALLS WATER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy Attorney General,requests that Falls Water Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
THURSDAY,AUGUST 17,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,additional documents that it,or any person
acting on its behalf,may later obtain that will augment the documents or information produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephone number of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FOURTH PRODUCTION REQUEST
TO FALLS WATER COMPANY l JULY 27,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.81:Please provide each individual customer's water usage data for
each system and meter size by month from January 2021 through December 2022.If available,
please provide the response in excel format and in a similar format to response to Production
Request No.34,Attachment 1.
REQUESTNO.82:From the file "CONFIDENTIAL FINAL_2023 Rate Case Model
-Falls Water"tab titled "Exhibit 5 Rate Design"Please answer the following:
a.Please explain the rationale and/or criteria the Company used to determine the block level
volumes for the proposed combined rate classes.Please provide any associated
workpapers in excel format with all formulas intact and enabled.
b.Please provide the model and rationale used to determine the proposed excess charge for
combined rate classes "second block"and "third block".Please provide in excel format
with all formulas intact and enabled.
REQUESTNO.83:Morning View Water's Rate Cases MNV-W-16-01 &MNV-W-19-
01,Orders #33658 &#34542,lists a combined plant-in-service amount of $478,487.Please
reconcile Falls Water's book asset detail with order #33658 &34542.See "Staff Attachment B
FLS W 23 01".
DATED at Boise,Idaho,this 27th day of July 2023.
Deputy AttorneyGeneral
i:umise:prodreq/fisw23.lestj prod req 4
FOURTH PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 JULY 27,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF JULY 2023,
SERVED THE FOREGOING FOURTH PRODUCTION REQUESTOF THE
COMMISSION STAFF TO FALLS WATER COMPANY,INC,IN CASE NO.
FLS-W-23-01,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
PRESTON N CARTER ERIC W.NELSEN
MORGAN D GOODIN SENIOR REGULATORY ATTORNEY
GIVENS PURSLEY LLP NW NATURAL 250 SW TAYLOR ST.
601 W BANNOCK ST PORTLAND,OREGON 97204
BOISE ID 83702 E-MAIL:eric.nelsen nwnatural.com
E-MAIL:[e-mail]
[e-mail]
[e-mail]
K.SCOTT BRUCE
FALLS WATER CO.,INC.
2180 NORTH DEBORAH DRIVE
IDAHO FALLS,ID 83401
E-MAIL:scottl fallswater.com
SECRETARY
CERTIFICATE OF SERVICE