20200407Application.pdf

RECEIVED
2020 April TPM2:03
IDAHO PUBLIC
ATILITIES COMMISSION
PrestonN. Carter (ISB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise,lD 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarter@ givenspursley. com
I5076086_4.docx [3988-9]
Attorneys for Falls l(ater Company, Inc.
BEFORE THE IDAHO PI]BLIC UTILITIES COMIVIISSION
Arpr,rclrroN oF Far-m Wlrnn
CouruxY,Ixc. To Durun Cosrs
AssocnrrD WrrH COVID-l9 Punr,rc
Ifplr,rn Euoncrxcv
Falls Water Company, Inc. ("Falls Water" or "Company") files this application to defer
costs associated with the COVID-19 public health emergency pursuant to the Idaho Public
Utility Commission ("Commission") Rules of Procedure 52 and Idaho Code 5 6l-524.In support
of this Application, Falls Water states the following.
Please serve all notices and communications with regard to this Application upon:
IN THE MATTER OF THE
APPLICATION OF FALLS WATER
COMPAI.IY, [NC. FOR COVID- 1 9
COST DEFERRALS
Case No. FLS-W-2O-QL
Eric W. Nelsen
Senior Regulatory Attorney
NW Natural
220 NW 2nd Ave.
Portland, Oregon 97209
Telephone: [phone]
Eric.Nelsen@nwnatural. com
Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise,lD 83702
Telephone: [phone]
Facsimile: [phone]
prestonc arter@ givenspursley. com
kendrah@givenspursley. com
Blcxcnouxo
l. Falls Water is a regulated water utility that provides water service to
approximately 18,500 customers through 5,607 connections near Idaho Falls, Idaho
AppLrcATroN oF FALLs WATER CoupeNv - I
2. Falls Water is a wholly owned subsidiary of NW Natural Water Company, LLC.
3. On March 13,2020,Idaho Governor Brad Little issued a proclamation declaring a
state of emergency and providing directives to combat the spread of COVID-19, to provide
essential services, and to limit exposure.
4. On March 25,2020, Governor Little issued an additional proclamation declaring
"a condition of extreme peril" in the State of ldaho due to the increasing presence of COVID-I9.
5. Governor Little's "extreme emergency" proclamation was accompanied by a
statewide order to self-isolate, which directed all individuals living in the State of Idaho to self-
isolate at their place of residence, subject to certain exceptions for individuals that provide or
receive essential services or that engage in essential activities.
6. The Commission has taken actions in response to COVID-I9, including
suspension of in-person hearings and otherwise limiting procedures that would result in in-
person contact. ,See Order NO. 34602 (March 18, 2020).
Rneunsr FoR DEFERRAL
7. The continuing spread of COVID-19 and associated proclamations and orders has
resulted in widespread economic disruption across the State of ldaho, the Pacific Northwest, the
United States and internationally.
8. Falls Water recognizes the extent to which its customers rely on the essential
services that it provides and remains committed to using its best efforts to provide these essential
servlces.
9. Falls Water also recognizes the economic hardship that the public health
emergency and accompanying orders has created for its customers. Falls Water is committed to
APPLICATION OF FALLS W.a.Tsn COI\,IpAI.IY - 2
assisting its customers through these difficult times, including suspending disconnections for
nonpayment, and suspending late fees, during the COMD-I9 emergency.
10. [n addition, Falls Water is actively participating in discussions regarding mutual
assistance for small water companies in Idaho to assist in responding to the public health
emergency. Falls Water's efforts include entering into the IdWarn agreement, a statewide water
and wastewater agency response network to facilitate coordination in preparing and responding
to intemrptions in service.
I l. Falls Water anticipates that the public health emergency, associated orders, and
economic disruption will cause it to incur unusual and unexpected costs. Anticipated costs
include expenses associated with the suspension of disconnections and late payments, anticipated
write-offexpenses associated with uncollectible accounts receivable, potential direct expenses
for additional personal protective equipment (PPE) and additional expenses that the Company is
currently unable to predict.
12. Due to the unpredictable and unprecedented nature of the public health
emergency, these costs are not currently recovered in rates and are outside normal business risk.
13. Accordingly, deferred accounting treatnent for these costs is appropriate and
reasonable.
14. Falls Water recognizes that the increased costs may be offset by certain reduced
costs caused by the public health emergency, and that decreased costs will be taken into account
in any future proceeding.
15. Falls Water does not request that the Commission make a determination of
prudency, or to determine whether these costs are recoverable, at this time. Falls Water
understands that these issues will be determined in a future proceeding.
AppLlcATroN oF FALLS WArnn Couperw - 3
Rrquosr ron Moorrrno PnocnDLrRE
16. Falls Water believes a hearing is not necessary to consider the issues presented in
this Application and respectfully requests that it be processed by modified procedure, using
written submissions rather than a hearing, under the Commission's Rules of Procedure 201
through 210.
Coxcr,usroN AND Rrqunsr non Rnlrsr
Falls Water respectfully requests that the Commission enter an order:
l. Authorizing this matter to be processed by modified procedure;
2. Authorizing Falls Water to separately account for, and to defer, costs associated
with the public health emergency posed by COVID-I9, with the amount, prudence, and recovery
of these costs to be determined in a future proceeding; and
3. Any other relief that the Commission deems just and reasonable.
DATED: April7,2020.
GTVENS PURSLEY LLP
,P ----:='. * N. a_{
Preston N. Carter
Givens Pursley LLP
Attornqts for Falls Water Company, Inc.
APPLICATIoN oFFALLS WATER CouTeNy - 4