20230828Staff 96-102 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 )CASE NO.FLS-W-23-01
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR WATER SERVICE )
)SIXTH PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF TO
)FALLS WATER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy AttorneyGeneral,requests that Falls Water Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
MONDAY,SEPTEMBER 18,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
SIXTH PRODUCTION REQUEST
TO FALLS WATER COMPANY 1 AUGUST 28,2023
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.96:Please provide a detailed explanation of the job responsibilities for
the seasonal employee.Please include in your response the actual duration of employment for
the seasonal employee and whether the position was filled in 2021,2022 and 2023.
REQUESTNO.97:Please provide the most recent Wage and Salary Study conducted
by Falls Water.
REQUESTNO.98:Please explain the Company's methodology for capitalizing labor
costs.
REQUESTNO.99:Please update all pro forma plant adjustments included in the
Application to actual costs of each project.
REQUESTNO.100:Please describe the typical scope of work conducted and initially
funded by the Company to connect/hookup a new customer in the:
a.Taylor Mountain ("TM")system;
b.Morning View ("MV")system;and
c.Falls Water ("FW")system.
REQUESTNO.101:Please provide the followinginformation and relevant
documentation showing the actual cost incurred by the Company to install new
hookups/connections.
a.Itemized bills or invoices (includingmaterials,components,and
labor)for the TM system from 2020 to date;
b.Itemized bills or invoices (includingmaterials,components,and labor)
for the MV system from 2020 to date;and
c.Itemized bills or invoices (includingmaterials,components,and labor)for the FW
system from 2022 to date.
SIXTH PRODUCTION REQUEST
TO FALLS WATER COMPANY 2 AUGUST 28,2023
REQUESTNO.102:Please explain why the Company has not included any applicable
"Hookup Charges"for MV customers when a new service is connected to the system for the first
time.Also,please explain how the Company recovers the cost related to new MV customer
hookups.
DATED at Boise,Idaho,this of August 2023.
,Claire Sharp
OG Deputy Attorn y General
i:umise:prodreq/flsw23.lcstj prod req 6
SIXTH PRODUCTION REQUEST
TO FALLS WATER COMPANY 3 AUGUST 28,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF AUGUST 2023,
SERVED THE FOREGOING SIXTH 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 ATTORNEY
GIVENS PURSLEY LLP NW NATURAL 250 SW TAYLOR ST.
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:scottl fallswater.com
SECRETARY
CERTIFICATE OF SERVICE