20230921FLS to Staff 99.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]
[16954230_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.
DATED September 21, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Morgan D. Goodin
Attorneys for Falls Water Co., Inc.
RECEIVED
Thursday, September 21, 2023 4:01:26 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 21, 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 99
Please update all pro forma plant adjustments included in the Application to actual costs
of each project.
Response:
The plant adjustments in Exhibit 1 of the Direct Testimony of Scott Bruce, Columns (B)
through (L), are described below.
 Column (B) of $714,000 in Exhibit 1 for Account No. 303 – Land & Land Rights.
The amount can be adjusted to $350,449.75 due to the water right transfer that
had been anticipated to close later this year is no longer viable and the transfer
application will be withdrawn.
 Column (C) of $150,000 in Exhibit 1 for Account No. 310 - Generators. The
installation of the generator at the main well field is still scheduled to be delivered
and installed in October 2023. The Automatic transfer switch for the generator at
Well 10 is also still scheduled to be delivered and installed in October 2023. The
Company final actual cost will be available in October 2023.
 Column (D) of $610,871 in line 7 for Account No. 331- Water Mains in Exhibit 1.
Through August 31, 2023, the completed cost of the water line
replacements/repairs is $544,618.08. The Company will provide total project cost
when the project is complete in October 2023.
 Column (D) of $20,000 In line 9 for Account No. 335 - Hydrant replacements in
Exhibit 1. The fire hydrant replacements are still being completed. The
Company will provide actual costs in October 2023 when the work in progress on
open jobs is complete.
 Column (E) of $40,000 in Exhibit 1 for Account No. 340 – Office Equipment. The
implementation of the Elements software is currently being done. It will be
FLS-W-23-01
IPUC Staff DR 99
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complete and usable in October 2023. The Company will provide the actual
implementation costs in October 2023.
 Column (F) of $55,500 in Exhibit 1 for Account No. 341 – Transportation
Equipment. The actual cost of the vehicles purchased in the items is $59,757.88.
 Column (G) of $30,600 in Exhibit 1 for Account No. 339 – Other Plant and
Equipment. The actual cost for the Well 10 fencing project is $30,600.
 Column (H) of $300,000 in Exhibit 1 for Account No. 304 – Well Structures and
Improvements. The actual cost of the Taylor Mountain Well 2 wellhouse is
$302,055.67.
 Column (I) of $43,800 in Exhibit 1 for Account No. 339 – Other Plant and
Equipment. The actual cost for the Morning View Wells 1 and 2 fencing project is
$46,928.46.
 Column (J) of $31,600 in Exhibit 1 for Account No. 348 – Other Intangible Plant.
The study will be complete by mid-October 2023 and the work is under a fixed
contract price of $31,600.
 Column (K) of $17,000 in Exhibit 1 for Account No. 348. The study will be
complete by mid-October 2023 and the work is under a fixed contract price of
$17,000.
 Column (L) of $15,886 in Exhibit 1 for Account No. 311 – Pumps & Accessories.
The actual cost for the Well 6 pump replacement is $15,885.87.
The Company will provide updated costs for projects that are not yet completed as
those projects come online and are closed to plant
FLS-W-23-01
IPUC Staff DR 99
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