20230830FLS to Staff 89_90_92_95.pdf

FALLS WATER CO., INC.’S RESPONSE TO FIFTH 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]
[16922294_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
FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF

Falls Water Co., Inc., (“Falls Water,” “Applicant,” or “Company”) in response to the
Fifth Production Request of the Commission Staff to Falls Water Co., Inc. dated August 7, 2023,
submits the following response. Responsive documents are available for download using the link
provided in the accompanying email.
DATED August 30, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
Wednesday, August 30, 2023 11:52:57 AM
IDAHO PUBLIC
UTILITIES COMMISSION
FALLS WATER CO., INC.’S RESPONSE TO FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on August 30, 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 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.
Response:
Production Request No. 36, Attachment 2 is the 2023 assessment invoice from
Bonneville-Jefferson Groundwater District. The invoice has three components:
1. Base Assessment is the fee for the District’s administrative expenses each year.
The fee is assessed based on the acres each member has within the District.
The District calculates an estimated total acreage for water rights not showing an
acreage amount in the water right based on the diversion rate (cfs) of the water
right times the District’s average cfs per acre of 0.01872281 to estimate acres.
The Company’s total acres and estimated acres for this portion of the
assessment is 1,817.11 acres. The assessment rate per acre is $7.00. The total
base assessment is $12,719.78 and is found in FLS-W-23-01 IPUC DR 89
Attachment 1, in column ‘N’ of the “2023 Assessment Calculations” tab.
2. Mitigation Assessment is based on the District’s mitigation needs to meet
estimated water shortfall for the current irrigation season. The mitigation needs
are based on the mitigation needs that the District is obligated to share in from
Idaho Groundwater Appropriator (IGWA) agreements and on ensuring that any
potential curtailments for the District’s patrons baseline production is met so the
patrons can pump. In 2023, the District anticipated needing 13,425 acre-feet of
mitigation to ensure its patrons were not curtailed under IDWR’s methodology
order Docket No. CM-DC-2010-001 issued April 21, 2023 and to meet other
mitigation obligations. The calculation is made by multiplying the tier average
dollar per acre costs of the mitigation water costs by the Company’s individual
water right acreage/estimated acreage (which provides a weighted adjustment
FLS-W-23-01
IPUC Staff DR 89
Page 1 of 2
for the water rights priority date). FLS-W-23-01 IPUC DR 89 Attachment 1
indicates the calculation in column ‘R’ of the “2023 Assessment Calculations” tab.
The total mitigation assessment is $35,633.41.
3. The “2021-2022 Over/Under Pumping Charge/Credit” invoice line item is for the
prior year’s over production above the Company’s baseline production set by the
2015 Agreement between the Surface Water Coalition (SWC) and the Idaho
Groundwater Appropriators (IGWA). The invoice submitted as “Production
Request No. 36, Attachment 2” is incorrect as noted in the FLS-W-23-01 IPUC
DR 88 response. The water rights purchased in 2021, 25-14482 and 25-14483,
were not included in the calculation of the baseline acre-feet in the original
invoice. The added water rights increased the baseline production number by
84.3 acre-feet reducing the original invoiced $105,739.61 to $99,782.67. FLS-W-
23-01 IPUC DR 89 Attachment 1 shows the calculation in column ‘I’ of the “2021-
2022 Overage” tab.
FLS-W-23-01
IPUC Staff DR 89
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:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 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.
Response:
Please see the Company’s response to FLS-W-23-01 IPUC DR 89.
FLS-W-23-01
IPUC Staff DR 90
Page 1 of 1
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 92
Please provide the Company's baseline in acre-feet for its compliance for the 2015
Stipulated Mitigation Plan, including the most recent purchases of water rights.
Response:
The baseline in acre-feet is 3955.4 and the details including the most recent water rights
purchases can be found in FLS-W-23-01 IPUC DR 92 Attachment 1.
FLS-W-23-01
IPUC Staff DR 92
Page 1 of 1
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 95
Please provide total monthly water 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".
Response:
The projected monthly water production for each well site for the next five years can be
found in FLS-W-23-01 IPUC DR 95 Attachment 1.
FLS-W-23-01
IPUC Staff DR 95
Page 1 of 1