20230728FLS to Staff 63.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]
[16867527_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 28, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
2023 JULY 28, 2023 4:41PM
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 28, 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 63
Please provide an estimate of total unaccounted water losses due to leaks, wasted
water, etc. by month over the past 5 years. Include a breakdown for FW, TM, and MV
customer systems. Please explain how these losses are estimated.
Response:
The monthly water losses 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 63
Attachment 1. The data reflect the period from January 2018 to June 2023. The
levels of losses included for Falls Water are due to a variety of factors that the
Company is working to address.
o Construction – the Company requires contractors installing new
subdivision mains to use a hydrant meter to capture water use when doing
the work. At times contractors will use the hydrant meters when Company
employees are on site to check up on them, but likely meters are not
always being used by the contractors.
o During the summer, it is not uncommon to see small landscaping
companies hook up to a hydrant without a meter when they are doing
hydroseeding or lawn care. This is a persistent problem because the City
of Idaho Falls does not currently require contractors to have a hydrant
meter to get water from their fire hydrants.
o The system has leaks, and the Company works to repair them in a timely
manner when they surface.
Data for the Morning View system are provided in FLS-W-23-01 IPUC DR 63
Attachment 2. The customer demand data are available from February 2021 to
June 2023.
FLS-W-23-01
IPUC Staff DR 63
Page 1 of 2
o Morning View has a significant level of leaks, however, frequently, the
leaks are not surfacing. The Company is working to schedule time to
conduct leak detection on Morning View and hopes to find and repair any
leaks.
 Data for the Taylor Mountain system are provided in FLS-W-23-01 IPUC DR 63
Attachment 3. 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.
o Taylor Mountain has a significant level of leaks. There are likely some
number of customers that have additional, unmetered services about
which the Company is not aware and needs to investigate.
FLS-W-23-01
IPUC Staff DR 63
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