20230811FLS to Staff 81-83_Conf CL.pdf

FALLS WATER CO., INC.’S RESPONSES TO FOURTH 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]
[16888371_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 FOURTH PRODUCTION REQUEST OF
THE COMMISSION STAFF

Falls Water Co., Inc., (“Falls Water,” “Applicant,” or “Company”) in response to the
Fourth Production Request of the Commission Staff to Falls Water Co., Inc. dated July 27, 2023,
submits the following responses. Responsive documents are available for download using the
link provided in the accompanying email. Confidential responses and documents are subject to
the protective agreement in this case, and are available for download using a password-protected
link that will be provided separately by email. The password will be provided in a third email.
DATED August 11, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
Friday, August 11, 2023 3:03:11 PM
IDAHO PUBLIC
UTILITIES COMMISSION
FALLS WATER CO., INC.’S RESPONSES TO FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on August 11, 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

601 W. Bannock Street
PO Box 2720
Boise, ID 83701
Main: 208-388-1200
www.givenspursley.com
Preston N. Carter
Direct: 208-388-1222 [e-mail]

August 11, 2023

VIA EMAIL
Ms. Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074

Re: Falls Water Co., Inc. – Case No. FLS-W-23-01

Dear Ms. Noriyuki:

Falls Water Co., Inc.’s (“Falls Water”) Confidential Responses to the Fourth Production
Request of the Commission Staff are attached to the email accompanying this letter.

Pursuant to the confidentiality agreement in this case and Idaho PUC Rules of Procedure,
IDAPA31.01.01.067, 31.01.01.233, and 31.02.01.005.07, the enclosed information is
confidential, proprietary and trade secret information of Falls Water and is protected by law from
public inspection, examination or copying, pursuant to Idaho Code Sections 74-106, 107, and 48-
801 et seq. Falls Water therefore requests that the enclosed information be protected from
inspection, examination or copying by any person other than the Commissioners and PUC Staff.
In accordance with IPUC Rule 67.02.a, the attached responses are marked “Confidential” and
submitted on yellow paper. Confidential responsive documents are available for download from
a password-protected sharefile site, the address to which is provided in the accompanying email.
The password will be provided through a separate email.

Thank you for your cooperation. Please feel free to contact me if you have questions
regarding this request.

Sincerely,

Preston N. Carter

Enclosures
cc: Eric Nelsen, Senior Regulatory Attorney, NW Natural
16888430_1.DOCX
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:
Adam Rue
Rates and Regulatory Water Program Manager, NW Natural
(626)-203-1733
Request No.: FLS-W-23-01 IPUC DR 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.
Response:
a. The Company based the block levels on the assumptions below. The workpapers
can be found in the referenced file and tab titled “Exhibit 5 Rate Design” and the
billing data provided in Confidential FLS-W-23-01 IPUC DR 81 Attachment 1.
a. The Falls Water system contains the majority of the system so the impact to
that large group of customers was prioritized but impacts to Morning View
and Taylor Mountain were considered.
b. The average usage in winter months was used as a basis for first block for
the 5/8” and ¾” meters. The 8,000 gallons represents typical, or average,
usage for indoor, winter usage.
c. The larger meter sizes were prorated based on the existing structure (e.g.,
12,000 5/8” and 1.42 x 5/8 inch for 1” customer first block of 17,000, which
corresponds with the 8,000 and 11,000 first block in the proposed rates).
b. The second block is based on two times the first block. This represented a
reasonable incremental level of usage, while recognizing the constrained water
supply conditions. The third block provides an incentive for reduced consumption,
as well as an allocation of the incremental cost related to mitigation to the
FLS-W-23-01
IPUC Staff DR 82
Page 1 of 2
customers’ usage that is more extensively contributing to the water supply issues.
This provides an allocation of the higher cost and an incentive to reduce
consumption.
FLS-W-23-01
IPUC Staff DR 82
Page 2 of 2
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:
Jeremy Aird
Director of Accounting and Finance, NW Natural Water
(503)-610-7927
Request No.: FLS-W-23-01 IPUC DR 83
MorningView 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"
Response:
Please see attached excel file FLS-W-23-01 IPUC DR 83 Attachment 1. You will see
the Day 1 Net Book Values of the assets acquired, and this net book value is what was
recorded as our Book Value for Falls Water. It is customary under GAAP accounting to
record the NBV when acquiring an entity, netting the accumulated depreciation against
the gross balance. There is a small variance of $567, related to meters.
FLS-W-23-01
IPUC Staff DR 83
Page 1 of 1