20230817FLS to Staff 80.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]
[16899465_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 17, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
Thursday, August 17, 2023 4:10:07 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 17, 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 80
Please provide all documents, contracts, and invoices that show why the following
projects were over budget and give a brief explanation for each.
a. Crowley Road Loop case 20-3 exh 1 rate base had $178,000 but in this case
FLS-W-23-01 the 2023 Rate Case Model spreadsheet tab exh 1 B 2022 Depr
shows a total of $ 188,732.68.
b. Lincoln road Phase 3 10" Main Move case 20-3 exh I rate base had $125,000
but in this case FLS-W-23-01 the 2023 Rate Case Model spreadsheet tab exh
1 B 2022 Depr shows a total of $133,138.30.
c. Hitt Road & Iona Road Looping case 20-3 exh 1 rate base had $975,000 but
in this case FLS-W-23-01 the 2023 Rate Case Model spreadsheet tab exh 1
B 2022 Depr shows a total of $986,971.62.
Response:
As requested all documents, invoices, and contracts are attached to this response.
a. The project is one of the projects listed in the Company’s Physical
Facilities Plan. The purpose of the project was to remove dead end lines and
improve fire flow. Bonneville County was installing a round-about at the
intersection of Crowley Road and First Street and the Company wanted to
take advantage of the opportunity by avoiding road repair costs which the
County’s project would cover. A convenience store was being planned for the
southwest corner of the intersection and the County had not procured an
easement from the property owner. The Company obtained an easement for
its water lines to move its project forward while the county worked to get its
own easements. Some of the additional costs in construction occurred at the
intersection of Cochise Drive and Crowley Road. The pipelines were not as
close to Crowley Road as thought. The original engineering estimate in the
Facilities Plan for the project was $319,000. Crowley Road Loop’s actual
FLS-W-23-01
IPUC Staff DR 80
Page 1 of 2
costs of $188,732.68 versus the estimated project costs in case 20-3 Exhibit
1 of $178,000.00. The differences are reconciled in the FLS-W-23-01 IPUC
DR 80 Attachment 1, and are summarized in the table below:
Variance of Actual Bid Cost Higher that Engineering Construction
Estimate
$8,215.00
Variance of Actual Installed Costs Higher than the Original Bid $3,602.75
Variance of Engineering Costs being less than the Engineering
Contract
($3,050.00)
Legal and Recording Costs to obtain an Easement 668.50
Additional Materials Supplied by Falls Water Co to Stub in a Main
line to a property (Hall Property)
$1,296.43
Total Variance $10,732.68
The related documents are found in FLS-W-23-01 IPUC DR 80 Attachments 2 –
6.
b. Lincoln Road Phase 3 10” Main Move was required by Bonneville County
as part of their project to widen Lincoln Road. The differences are reconciled
in FLS-W-23-01 IPUC DR 80 Attachment 7, and are summarized in the table
below:
Construction Change Orders and Actual Units Installed versus
Bid
$6,368.34
Engineering Costs (No Contract done at Time & Materials) $1,196.00
Reconnection of Service line at 3900 Lincoln Road (done by
Company Staff)
$573.96
Total Variance $8,138.30
The related documents are found in FLS-W-23-01 IPUC DR 80 Attachments 8 –
9.
c. The Hitt Road and Iona Road Looping project was done to improve water
flow from Well 11. The project was listed in case 20-3 exh 1 for $975,000 and
final project costs were $986,971.62 an over run of $11,971.62. The over run
was due to the owner of AK Signs on Iona Road being unsatisfied with the
asphalt patch across the parking area frontage. We had to repave the parking
area at a cost of $12,000. The differences are reconciled in FLS-W-23-01
IPUC DR 80 Attachment 10.
The related documents are found in FLS-W-23-01 IPUC DR 80 Attachments 11 –
14.
FLS-W-23-01
IPUC Staff DR 80
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