20230807Staff 84-95 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
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF FALLS WATER
COMPANY'S APPLICATION FOR AUTHORITY TO INCREASE ITS RA TES AND CHARGES FOR WATER SERVICE
) ) CASE NO. FLS-W-23-01
)
) ) FIFTH PRODUCTION ) REQUEST OF THE
) COMMISSION STAFF TO ) FALLS WATER COMPANY
) ___________________
Staff of the Idaho Public Utilities Commission, by and through its attorney ofrecord,
Claire Sharp, Deputy Attorney General, requests that Falls Water Company ("Company")
provide the following documents and information as soon as possible, but no later than
MONDAY, AUGUST 28, 2023.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, 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
telephone number of the record holder.
FIFTH PRODUCTION REQUEST TO FALLS WATER COMPANY AUGUST 7, 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.84:In a letter provided by the Bonneville-Jefferson Ground Water
("District")to the Company,regarding Surface Water Coalition ("SWC")'s claim that Idaho
Ground Water Appropriators ("IGWA")breached the 2015 agreement in 2021,it stated that;
"Bonneville-Jefferson and counsel for IGWA have also appealed this [Final]Order [Regarding
Compliance with Approved Mitigation Plan]to the district court.SWC has,again,alleged a
breach of the Settlement Agreement by IGWA members...for alleged over-pumping during the
2022 irrigation season."Company's Response to Production Request No.36,Attachment 3 at 2.
Please answer the followingquestions:
a.Please provide a detailed description on the status of the appeal of the Idaho
Department of Water Resources ("IDWR")Director's Final Order Regarding
Compliance with Approved Mitigation Plan;and
b.Please provide the estimated timeline that the Company will know the results of
SWC's claim that IGWA breached the 2015 agreement again in 2022.
REQUESTNO.85:In the Company's Response to Production Request No.36 -
Attachment 3,it is stated that,"The District adjusted assessments this year to provide credit to
members for these reductions."Please explain how the District calculated any credits for Falls
Water's reduction in water production in previous years.Please provide a supporting worksheet
that breaks down the Company's total assessment and overuse charges by year,includingthe
total of credits received towards the overuse charges.
REQUESTNO.86:Please explain the Company's reasoning for purchasing additional
water rights in 2021 and 2023.Additionally,please provide a cost-benefit analysis for each
water right purchased since 2021 listed below:
a.Water Right:25-14482;
b.Water Right:25-14483;
c.Water Right:25-14516;and
d.Water Right:25-14517.
FIFTH PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 AUGUST 7,2023
REQUESTNO.87:Please provide all transactions and journal entries to the
Company's ground water mitigation deferral account in Excel format.Please included item
name,brief description,cost broken down by month and year for 2022 to date.
REQUESTNO.88:Please reconcile the expenses booked to the groundwater
mitigation deferral account with the Company's response to Production Request No.36 of
$105,739.61,No.37 of $145,718.14,and No.38 of $153,000,and Bruce Direct Testimony at 8
of $153,300.
REQUESTNO.89:Please provide a detailed description of each charge in the invoice
provided in the Company's response to Production Request No.36,Attachment 2.Also,please
provide the calculations the District used to calculate each charge in Excel format.
REQUESTNO.90:As a supplement to the response to Production Request No.89,
please reconcile the description of each charge to Company's response to Production Request
No.36,Attachment 1.
REQUESTNO.91:Please explain whether IDWR or the District sets the Company's
baseline for the 2015 Stipulated Mitigation Plan.
REQUESTNO.92:Please provide the Company's baseline in acre-feet for its
compliance for the 2015 Stipulated Mitigation Plan,includingthe most recent purchases of water
rights.
REQUESTNO.93:Please provide customer growth forecasts for each meter size and
by system (Falls Water,MorningView,and Taylor Mountain)over the next 5 years.In the
response,please provide current customer count for 2023 for meter size and system.Please
include all workpapers with formulas enabled.
FIFTH PRODUCTION REQUEST
TO FALLS WATER COMPANY 3 AUGUST 7,2023
REQUESTNO.94:Please provide total monthly water consumption forecasts for each
meter size and system for the next 5 years (Falls Water,Morning View,and TaylorMountain).
Please include all workpapers with formulas enabled.
REQUESTNO.95:Please provide total monthlywater production forecasts at each
well site for the next 5 years.Please include all workpapers with formulas enabled in similar
format as Company's response to Production Request No.37,Attachment 1,Tab "Production vs
Baseline Production".
DATED at Boise,Idaho,this day of August 2023.
Claire Sharp
Deputy AttorneyGeneral
i:umisc:prodreq/flsw23.lcstj prod req 5
FIFTH PRODUCTION REQUEST
TO FALLS WATER COMPANY 4 AUGUST 7,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7th DAY OF AUGUST 2023,
SERVED THE FOREGOING FIFTH 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 ATTORNEYGIVENSPURSLEYLLPNWNATURAL250SWTAYLORST.
601 W BANNOCK ST PORTLAND,OREGON 97204
BOISE ID 83702 E-MAIL:[e-mail]
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:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE