20230731FLS to Staff 78.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]
[16869816_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 July 6, 2023,
submits the following responses. Responsive documents are available for download using the
link provided in the accompanying email.
DATED July 31, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
Monday, July 31, 2023 4:43:18 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 31, 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 78
On Staff attachment A FLS W 23 01 lines 19 & 20 please explain why Well 4 had a
replacement motor and other work done for $30,079.72 and then on 7/31/20 spent $3,
142.67 on a pump replacement. Please provide invoices for these expenses.
Response:
The invoices can be found in FLS-W-23-01 IPUC DR 78 Attachment 1-2. The two
invoices relate to the same project: Attachment 1 is for the $3,142.67 for the pump
replacement; Attachment 2 includes the $12,645.80 and $17,433.92, which total the
$30,079.72.
When the pump on Well 4 stopped working, American Pump Co. replaced the pump
with a pump the Company had in inventory. Upon the pump being replaced, Cutting
Edge Electric, Inc. had to rerun wiring and operation tested the pump. In closing out the
project, the Cutting Edge Electric invoice was not received in a timely manner and it was
put into the fixed asset account on a separate line. The total cost of the project was
$33,222.39.
FLS-W-23-01
IPUC Staff DR 78
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