20230824FLS to Staff 75.pdf

FALLS WATER CO., INC.’S RESPONSE 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]
[16914132_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 RESPONSE 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 response. Production Response 75 includes Attachments 1-35, except 17
which was intentionally omitted due to a duplication error. Responsive documents are available
for download using the link provided in the accompanying email.
DATED August 24, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
2023 August 24, PM 3:02
IDAHO PUBLIC
UTILITIES COMMISSION
FALLS WATER CO., INC.’S RESPONSE TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on August 24, 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 75
Please provide the supporting documentation including all invoices and contracts for the
Capitalized purchases included in the attached spreadsheet: Staff attachment A FLS W
23 01. Please include any cost benefit analysis used by the Company justifying the
purchase, a description of the item, upgrades, or service purchases, and how the
purchase benefits the customers.
Response:
FLS-W-23-01 IPUC DR 75 Attachment 1 includes references to the FLS-W-23-01 IPUC
DR 75 Attachments 2 – 34 for invoices and contracts for the referenced items in Column
(H). Column (I) provides a description of the assets and Column (J) provides a
description of customer benefits.
The FLS-W-23-01 IPUC DR 75 Attachment 21 shows IT Additions that are centrally
procured costs for IT services provided by internal labor and third-party contractors.
These invoices are summarized in FLS-W-23-01 IPUC DR 75 Attachment 35. The
employees and contractors time-track when working on a specific water subsidiary
issue, however some of the IT infrastructure being put into place is shared by all water
subsidiaries. When that is the case, we apply the Massachusetts Methodology to
allocate shared system costs. The centrally procured IT additions are largely related to
Cybersecurity and Standardization Program described below.
Program Description:
The Falls Water Cybersecurity and Technology Standardization Program provides a
more secure and compliant common technology operating environment by
implementing a combination of new and/or upgraded computing technologies. The
Program also identifies the requirements necessary to best implement cyber security
standards and to deploy current operating systems, networks, and applications into the
Salmon Valley Water computing environment while building the necessary infrastructure
FLS-W-23-01
IPUC Staff DR 75
Page 1 of 3
to deploy and support current and properly licensed hardware systems and software
applications. The Program will also help to ensure legacy systems meet compliance
standards through appropriate control of the computing environment and
desktop/mobile application distribution standards and procedures.
Program Scope:
 Computer Hardware and Peripherals
 Customer Information Systems (CUSI SW)
 Network Hardware
 Network Software
 Internal and/or External Facing Websites and associated Web Applications
Strategic Alignment and Customer Benefits:
 Program Goal Planned Benefits
 High Customer Value
 Standardization of technologies to improve overall availability, reliability, and
performance; thus, improving efficiency and cybersecurity readiness.
 Financial Performance
 An improved technology environment will provide a more consistent and
compliant technology operating environment, reducing licensing costs, support
issues, and increasing productivity among end-users. These improvements will
result in cost avoidance due to system outages and lost time while improving the
overall total cost of ownership of the technology environment.
 Engaged, Valued Workforce
 An improved technology operating environment will improve the overall end-user
and external customer computing experience and will provide the ability to
control and maintain system configurations.
 Technology Obsolescence
 The program will deliver technology resources required for new business
applications, unified communications, and information security. Vendor support
for legacy technologies has either expired or is anticipated to be depreciated
after 2022.
Additional Benefits:
 Brings Falls Water up to date with the most current, secure, and reliable cloud
computing platform.
FLS-W-23-01
IPUC Staff DR 75
Page 2 of 3
 Adds new functionality to be leveraged for system security controls, end-user and
customer support efficiency.
 Increases the security of computing systems and data by managing applications,
access, and privileges.
FLS-W-23-01
IPUC Staff DR 75
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