20230802FLS to Staff 79.pdf

FALLS WATER CO., INC.’S RESPONSES TO THIRD 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]
[16871914_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 THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF

Falls Water Co., Inc., (“Falls Water,” “Applicant,” or “Company”) in response to the
Third 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 August 2, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
Wednesday, August 2, 2023 4:21:47 PM
IDAHO PUBLIC
UTILITIES COMMISSION
FALLS WATER CO., INC.’S RESPONSES TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on August 2, 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 79
Please provide the bill of sale for the purchase of the following vehicles and explain the
reason for each purchase.
a. 2021 Trailer $4,990.25 purchased 3/4/21.
b. 2020 Ford F250 Pickup $56,503.03 purchased 1/6/21.
Response:
The purchase documents for the 2021 C&B trailer are provided as FLS-W-23-01 IPUC
DR 79 Attachment 1. The trailer was purchased to transport trench boxes, piping,
equipment, and materials to utility projects performed by the Company.
The purchase documents for the 2020 Ford F250 pickup is provided as FLS-W-23-01
IPUC DR 79 Attachment 2. In December 2019, the Company hired a service technician
and assigned him the use of a 1999 Ford F350 flatbed pickup truck (this truck’s purpose
was to haul waste material from jobsites to the dump). The Company did not purchase a
service vehicle in 2020 to be assigned to this employee. In 2021, the 2020 Ford F250
was purchased to provide the service technician a suitable service truck that could be
outfitted for having the tools and parts on the truck to perform maintenance on the water
system. The 1999 Ford F350 was returned to the task of hauling construction waste
because the flatbed has a hydraulic lift and the sides of the flatbed have four-foot wire
mesh to contain the material. While the truck was used by the service technician on a
regular basis, no permanent toolboxes could be mounted on the flatbed because the
truck was still needed to haul construction waste.
FLS-W-23-01
IPUC Staff DR 79
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