20230915AVU to Staff 96-98_100_102.pdf

FALLS WATER CO., INC.’S RESPONSES TO THE SIXTH 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]
[16944936_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 THE SIXTH PRODUCTION REQUEST OF
THE COMMISSION STAFF

Falls Water Co., Inc., (“Falls Water,” “Applicant,” or “Company”) in response to the
Sixth Production Request of the Commission Staff to Falls Water Co., Inc. dated August 28,
2023, submits the following responses. 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 September 15, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Morgan D. Goodin
Attorneys for Falls Water Co., Inc.
RECEIVED
Friday, September 15, 2023 1:32:43 PM
IDAHO PUBLIC
UTILITIES COMMISSION
FALLS WATER CO., INC.’S RESPONSES TO THE SIXTH PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on September 15, 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]
_________________________________________
Morgan D. Goodin
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 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.
Response:
The seasonal employee has the following duties:
 Inspects every water meter yearly for overgrown grass around meter lid, leaks in
meter pit, broken ring/lids, etc.
 Searches out meter lids or shut-off valves, raising meter lids to grade and
landscaping projects.
 Well lot and building grounds keeper – lawn mowing, weed eating, cleans up
garbage,
 Performs as a crew member, assisting skilled Water Distribution Operators in
installing, renewing, maintaining, and repairing water services and main lines.
 Operates a variety of hand tools and small power equipment, such as a jack
hammer, compressor, compaction machine, tapping machine, pipe saw, chain
saw; cleans tools and equipment to ensure proper working condition.
The seasonal employee position is expected to last from May 1st through October 31st
each year. The Company began searching to fill the position in March of 2023. The
opening was filled on June 12, 2023. The position proved to be more difficult to fill than
expected. Many of the applicants would either not respond to requests for job interviews
and many that did set up interviews failed to show up for the interview. The applicant
hired was a high school graduate that had just graduated. He worked through the
summer and left on September 1, 2023. He had another commitment after that date.
FLS-W-23-01
IPUC Staff DR 96
Page 1 of 2
Ideally the Company would want someone who is able to work from May through
October on an annual basis. The applicant pool, this year, did not work out that way.
The Company had not sought anyone prior to 2023 to fill this position.
FLS-W-23-01
IPUC Staff DR 96
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 97
Please provide the most recent Wage and Salary Study conducted by Falls Water.
Response:
The Company uses a variety of sources to determine market rate for salaries. The most
recent AWWA salary survey is 2021, which informed the wages and salaries for the
Company employees. The Salary Survey based on the AWWA salary survey, escalated
by 3% annually to 2023 is provided as Confidential FLS-W-23-01 IPUC DR 97
Attachment 1.
Additionally, the Company reviews neighboring entities within the local market for
similar positions. The City of Idaho Falls Grade and Step with Job Titles 2020-2021 is
provided as FLS-W-23-01 IPUC DR 97 Attachment 2 and the Grade and Step 2022-
2023 is provided as FLS-W-23-01 IPUC DR 97 Attachment 3. The data are published
on the City website and the Company believe they provide an important comparator due
to the proximity and comparable jobs.
Finally, the Bureau of Labor Statistics publishes data of similar job titles by geographic
area. This is another valuable data point for comparable jobs. The most recent BLS
data salaries for comparable positions in Idaho is provided as FLS-W-23-01 IPUC DR
97 Attachment 4.
FLS-W-23-01
IPUC Staff DR 97
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:
Jeremy Aird
Director of Accounting and Finance, NW Natural Water
(503)-610-7927
Request No.: FLS-W-23-01 IPUC DR 98
Please explain the Company's methodology for capitalizing labor costs.
Response:
Please refer to FLS-W-23-01 IPUC DR 74 for the discussion of Falls Water’s
capitalization policy. The same application would apply to labor hours worked related to
a capital project. The costs capitalized would include labor plus an estimate for payroll
taxes and workers compensation costs related to the hours worked on the capital
project.
FLS-W-23-01
IPUC Staff DR 98
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 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.
Response:
The Company funded work and materials is consistent among the three systems. The
cost to connect/hookup a new customer in all of the water systems currently owned by
the Company includes:
The installation of a meter
A radio transmitter at each new customer site
Labor cost of $50.00 per installation site
The developer installs the service line and meter barrel on each lot as the main line
infrastructure is installed for the development.
The home builder is responsible to connect the stub out from the meter barrel to the
new home.
FLS-W-23-01
IPUC Staff DR 100
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 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.
Response:
The Morning View water system did not have a tariffed “Hookup Charge” at the time the
system was acquired by the Company (FLS-W-20-04). At the time the Company
acquired the system, it had 21 vacant lots out of 147 buildable lots; the system had 10
vacant lots in May 2023 when FLS-W-23-01 was filed. The Company, by asking to
combine the tariffs for the three systems, expects to have all three systems using the
same Hookup Charge tariff. (See Case No. FLS-W-23-01 Application Attachment 1
Proposed Tariff – Clean and Attachment 2 Proposed Tariff – Redline.) For this reason, a
separate hook-up fee for Morning View was not requested. However, if Staff
recommends, and the Commission approves, a non-consolidated tariff, the Company
would support a Hookup Charge for all the systems, including Morning View.
The Company has installed meters in new construction connections and put the meters
into its rate base due to the lack of a hook-up tariff. These meters are being
depreciated using a 35-year straight line method as shown in Attachment G of Staff
Comments in Case No. MNV-W-19-01.
FLS-W-23-01
IPUC Staff DR 102
Page 1 of 1