20240401Staff 22-26 to FLS.pdf

RECEt/IED
Nbnday,April 1,2024 2:34:07 PM
IDAHOPLHIC
UTILITIES C T\/MSRON
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
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 THE APPLICATION ) CASE NO. FLS-W-24-01
OF FALLS WATER CO.,INC. FOR )
APPROVAL OF A REPLACEMENT WELL )
FOR ITS MORNING VIEW SYSTEM ) SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO FALLS WATER CO., INC.
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Falls Water Co., Inc. ("Company")provide
the following documents and information as soon as possible, but no later than MONDAY,
APRIL 15, 2024.1
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, 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 telephone number of
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0314.
SECOND PRODUCTION REQUEST
TO FALLS WATER CO., INC. 1 APRIL 1, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
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.
REQUEST NO. 22: According to the Attachments 1, 2, and 3 in the Company's
response to Production Request No. 8, the total annual water production for the Morning View
system was 135.15 Acre-feet("AF") in 2023, which is a decrease from 146.14 AF in 2022 and
145.54 AF in 2021. Please explain why total annual water production decreased in 2023 from
2022 and 2021. Additionally, please explain if the Company expects the annual water
production to trend down from 2023 water production levels.
REQUEST NO. 23: The Company's response to Production Request No. 4 states: "The
SCADA system will be set up to alternate the run time on the two wells to ensure that the wells
are operational."
Please provide the total estimated cost of installing the SCADA system on both Well
Nos. 3 and 4. Additionally, please explain if the estimated costs of the SCADA system on Well
No. 4 are included in the Project's cost estimate.
REQUEST NO. 24: According to the "Morning View Water Company PER& Facility
Plan" (Attachment 1 to the Application) at 22: the Company"will screen the new well, so the use
of a sand separator is not anticipated."
Please explain and provide evidence for the need of a new sand separator for the proposed
Well No. 4, since Aspen Engineering's recommendation in the Company's Facility Plan was that
the sand separator is not necessary.
REQUEST NO. 25: In response to Staff s Production Request No. 19, the Company
listed several significant challenges it encountered regarding repairs of the existing Well Nos. 1
and 2 due to excessive accumulation of sand, mud, and rock. In this regard, please answer the
following:
SECOND PRODUCTION REQUEST
TO FALLS WATER CO., INC. 2 APRIL 1, 2024

a. Please explain the risk of excessive accumulation of sand,mud, and rock by
drilling the proposed Well No. 4 at the same location as existing Well Nos. 1 and
2;
b. If there is a risk,please explain how the Company will mitigate it; and
c. If there is a risk, please explain if there are alternative locations that should be
explored.
REQUEST NO. 26: Please provide detailed information including but not limited to
make, model, capacity, specifications, etc. for the new VFD that the Company is planning to
install for the anticipated 60 hp pump of the proposed Well No. 4.
DATED at Boise, Idaho, this I"day of April 2024.
IUA-
Chris Burdin
Deputy Attorney General
I:\UtiPity\U USC\PRDREQ\FLS-W-24-01 PR#2 docx
SECOND PRODUCTION REQUEST
TO FALLS WATER CO., INC. 3 APRIL 1, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE ON THIS DAY OF APRIL 2024,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO FALLS WATER CO, INC., IN CASE NO. FLS-W-24-01,
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: eric.nelsenaa,nwnatural.com
E-MAIL: prestoncarter(aa,givenspursley.com
morgangoodin(a� ivenspursley com
stephaniew ,givenspursley.com
K. SCOTT BRUCE
FALLS WATER CO., INC.
2180 NORTH DEBORAH DRIVE
IDAHO FALLS, ID 83401
E-MAIL: scottl(a,fallswater.com
P TRICIA JORD ,'SECRETARY
CERTIFICATE OF SERVICE