20240315FLS to Staff 1-21.pdf

FALLS WATER CO., INC.’S RESPONSES TO STAFF’S FIRST PRODUCTION REQUEST PAGE 1 OF 2
18258097.1)
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Falls Water Co., Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF FALLS WATER CO., INC. FOR
APPROVAL OF A REPLACEMENT WELL
FOR ITS MORNING VIEW SYSTEM
Case No. FLS-W-24-01

FALLS WATER CO., INC.’S RESPONSES TO
THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF
Falls Water Co., Inc. (“Falls Water” or “Company”), in response to the First Production
Request of the Commission Staff to Intermountain Gas Company dated February 26, 2024,
submits the following responses. Responsive documents are available for download using the
link provided in the accompanying email.
DATED: March 15, 2024.

By:_____________________________
Preston N. Carter
Givens Pursley LLP
Attorneys for Falls Water Co., Inc.

RECEIVED
Friday, March 15, 2024 5:35PM
IDAHO PUBLIC
UTILITIES COMMISSION

FALLS WATER CO., INC.’S RESPONSES TO STAFF’S FIRST PRODUCTION REQUEST PAGE 2 OF 2
18258097.1)

CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT on March 15, 2024, I caused a true and correct copy of the
foregoing to be served upon the following parties as indicated below:

Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
[e-mail]

Email
U.S. Mail
Fax
Hand Delivery

Preston N. Carter

Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 1
On page 21 of the Facility Plan, it states, "Information about well #4 and its design
will be included in a future document about the design of well #4." Please provide
the additional information and design for Well No. 4.
Response:
The additional information about well #4 is the preliminary design drawing for the well.
See the attached design file, FLS-W-24-01 IPUC DR 1 Attachment 1.
Preparer/Sponsoring Witness: Scott Bruce, General Manager, Falls Water Co., Inc.,
[phone]
FLS-W-24-01
IPUC Staff PR 1
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 2
Please provide supporting workpapers for the Project cost estimates that breaks
down the total cost by component and further broken down by material, labor, and
overhead.
Response:
Please see the project cost estimate found in the Excel file FLS-W-24-01 IPUC DR 2
Attachment 1.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.,
[phone]
FLS-W-24-01
IPUC Staff PR 2
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 3
Please explain if the Company plans to cease operating Well Nos. I and 2 once the
proposed Well No. 4 becomes operational. If not, please explain why.
Response:
The Company will decommission Well Nos. 1 and 2 after Well 4 is operational. The
existing water rights will be used for the diversion rate of Well 4 and they are sufficient
for use by Well 3 and Well 4.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 3
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 4
Please explain if the Company will operate Well Nos. 3 and 4 simultaneously or if
Well No. 4 will only serve as a back up to Well No. 3.
Response:
The Company will use the SCADA system to use both Wells 3 and 4 in normal
operation. The SCADA system will be set up to alternate the run time on the two wells
to ensure that the wells are operational. In using the wells in this manner, the wells
have time to rest and receive regular maintenance.
In the event demand is great enough to require production from both wells, they will be
available to cover the demand.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 4
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 5
Please provide the estimated maximum water pumping capacity and annual water
production (in gallons) from the proposed Well No. 4.
Response:
The Company’s response is provided by J. Ryan Loftus, P.E., Aspen Engineering, Inc.:
Well No. 4 requires a pumping capacity of 550 to 600 gallons per minute and is
expected to produce approximately half of the annual water production for Morning View
equaling 23.8 million gallons per year. (Morning View currently requires 48 million
gallons per year.)
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 5
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 6
Please explain how the Company plans to fund this capital investment.
Response:
The Company will receive an equity infusion from its parent companies to fund this
project.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 6
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 7
Please explain whether Appendix B in the Application includes all water rights of the
Morning View ("MV") system. If not, please explain and provide supporting
documentation of all MV water rights.
Response:
All Morning View water rights are listed in Appendix B in the Application. These are all
water rights acquired in the purchase of the Morning View water system.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 7
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 8
Please provide the monthly metered amount of water (in terms of both Gallons and Acre
Feet) pumped from each MY-system well during 2021 -2023. Please provide your
response in spreadsheet format (such as Microsoft Excel) with formulas intact.
Response:
The Morning View well log files for 2021 – 2023 are included in the response. The files
are:
 FLS-W-24-01 IPUC DR 8 Attachment 1 - Morning View Well Log 2021
 FLS-W-24-01 IPUC DR 8 Attachment 2 - Morning View Well Log 2022
 FLS-W-24-01 IPUC DR 8 Attachment 3 - Morning View Well Log 2023
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 8
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 9
Please provide justification and available documentation showing the need for a
replacement well. The documentation may include but is not limited to 3rd party
analysis or reports, Idaho Department of Environmental Quality ("IDEQ") reports
reflecting regulatory requirements for a replacement well, etc.
Response:
Please refer to Morning View Water System Facility Plan (Exhibit 1 of the Application)
section ‘Water Supply and Storage Requirements’ on page 17. This section describes
the key criteria outlined in the Idaho Rules for Public Drinking Water Systems to
determine the timing and development of new water supply wells, storage, and
emergency power generation capabilities.
The current Wells 1 and 2 do not have the capacity to produce the firm pumping
capacity to satisfy the maximum daily demand of 399,200 gpd for the water system. If
Well 3 were to fail, the system does not have the capacity in its remaining wells to meet
the estimated maximum daily demand of the system.
Well 3 is the only source that can meet the water system’s need by itself, absent this
project. If Well 3 were to become inoperable, the remaining wells (1 and 2) would not
be able to meet anything other than average daily demand as they currently exist.
Even if the existing Wells 1 and 2 were to be deepened, the deepening process reduces
the diameter of the well shaft and would not allow a submersible pump of the same size
or larger to be put into the well. This would essentially improve the reliability of the
water source but reduce the amount of water that could be pumped. This result does
not help the system meet the customer demand if Well 3 were to become inoperable.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 9
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 10
Please explain whether the Company has considered sharing the existing backup
generator (for Well No. 3) with the proposed replacement Well No. 4. If not, please
explain why.
Response:
Based upon information provided by J. Ryan Loftus, P.E., Aspen Engineering, Inc.:
No. Well #4 will be located approximately 2,500 feet (“as the crow flies”) from Well #3.
Following a directional path along road rights-of-way would make the path over 3,300
feet. Wire size for that length of run would require at least 1.0 AWG wire (copper) and
cost about $2/foot just to buy the wire, add the conduit ($2/foot) and excavation costs
($15/foot). Assuming no cost for easements or ROW use, the wire and conduit labor
installation would be $2/foot, making the wire installation cost $21/foot equaling
$69,300, which is approximately $10,000 more than the new generator cost.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 10
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 11
Please provide justification and available documentation showing the need for a
backup generator for Well No. 4. The documentation may include but is not limited
to 3rd party analysis or reports, IDEQ reports reflecting regulatory requirements for
a backup generator, etc.
Response:
In speaking with J. Ryan Loftus, P.E., Aspen Engineering, Inc., the need for a backup
generator for Well No. 4 is needed redundancy for water production. If Well 3, which
has the only back up power source for the system, were unavailable due to repairs, Well
No. 4 is the only source of water production. Should the power go out for hours and
Well No. 3 were not working, the customers would have no water at all. The system
would lose pressure and would be under a boil advisory when power was restored and
the water system was brought back online. A backup generator on each well protects
the water system from possible power loss.
It has been the Company’s experience that short power outages in the Morning View
water system area happen three to four times per year. Backup power is needed to
ensure a reliable water system for the Morning View customers.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 11
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 12
Please provide a copy of the Company's latest IDEQ sanitary survey report.
Response:
Morning View’s latest IDEQ sanitary survey report is included in the response. The file
is:
FLS-W-24-01 IPUC DR 12 Attachment 1 - ID7260063 MORNING VIEW WATER
COMPANY - ID7260063 Morning View Water Company Sanitary Survey 11082021
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 12
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 13
Please explain whether the Facility Plan provided in the Application is approved by
IDEQ.
Response:
The Company submitted the Facility Plan earlier this month (March 2024) to IDEQ for
approval, and we expect a response from IDEQ in the coming weeks. The Company
will supplement this response with the IDEQ’s response once we receive it.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 13
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 14
Please provide the projected load growth by customer type for the next five years.
Please include all assumptions and workpapers showing the projections.
Response:
The Morning View water system is finite in size currently. The housing additions
surrounding the water system are homes with private wells and septic tanks. The
Morning View system currently has 138 connections, with the potential of 3 additional
connections from 3 vacant lots in the development. The Morning View Water Company
PER & Facility Plan (Attachment 1 to the Application) on page 16 under the Future
Water Demands section states, “It is anticipated that the 3 additional lots will be built out
by the end of the year 2026…”. The development has only residential customers. No
commercial or multi-family customers are expected to connect to the system.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 14
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 15
What other feasible alternatives besides the proposed well or refurbishment of the
existing wells did the Company consider? For example, did the Company consider
building a storage tank as an alternative? Please explain and provide a cost-benefit
analysis comparing the different feasible alternatives.
Response:
The Company did not consider any other feasible alternatives besides the proposed
well or refurbishment of the existing wells. Please see Application, paragraphs 17-21,
for a discussion of alternatives deemed not feasible. As to the example, the ‘Water
Supply and Storage Requirements’ section of the Facility Plan, page 17 (Application,
Exhibit 1), shows that the firm pumping capacity of the system is not met if Well No. 3 is
out of service. Even if a storage tank were a feasible option, the existing wells would be
insufficient to stay ahead of demand and fill the tank on maximum demand days.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 15
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 16
Please explain why the Company is not considering deepening the two existing wells
(Well Nos. I and 2) as one of the alternatives to mitigate water production issues.
Please provide the followings for Well Nos. 1 and 2:
a. Justification and necessary documentation included but not limited to
cost estimations, quotes to repair these wells, etc.;
b. Justification of how the well casings do not meet current requirements;
and
c. Cost-benefit analysis of deepening the wells.
Response:
Based on information provided by J. Ryan Loftus, P.E., Aspen Engineering, Inc.:
Well #1 could possibly be deepened but would require reduction to 10 inches in
diameter. The well casing is 0.25 inches thick and does not meet Idaho DEQ
requirements of 0.375 inches for the 12-inch diameter casing. The well was constructed
with a cable tool drill rig and well straightness has not been tested/determined. The
surface seal is 47 feet which is 11 feet short of the current 58’ requirement.
Well #2 is only six inches in diameter and deepening would have to reduce to 4 inches
which would severely limit the size of pump to a maximum diameter of 3 inches. Well
#2 has a surface seal of only 18 feet which is 40 feet less than required for public
drinking water wells.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 16
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 17
Please explain why the Company is not considering utilizing the existing sand separator
(at Well Nos. 1 and 2) instead of updating it? Please provide the followings:
a. Any evidence showing the reutilization of the existing sand separator
was considered and final results of the investigation;
b. Justification of any insufficiency or inadequacy/incompatibility of the
existing sand separator to the proposed replacement Well No. 4; and
c. Justification and necessary documentation included but not limited to
cost estimations, quotes, etc. to update the sand separator.
Response:
Based on information provided by J. Ryan Loftus, P.E., Aspen Engineering, Inc.:
The existing sand separator (at Well Nos. 1 and 2) is more than 20 years old and is
sized for maximum flow of 525 gpm to remove sand from Well Nos. 1 and 2 only (which
produce a combined 400 gpm) and not sized to instead be used for Well No. 4 (which
will produce 600 gpm). Further, the model of the existing sand separator is no longer
produced (making replacement parts very hard to obtain).
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 17
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 18
Please explain whether using the existing Variable Frequency Drive ("VFD") is feasible,
instead of purchasing a new one for the new well. If not, please explain why not. Please
include any documentation or evidence supporting the Company's decision.
Response:
Based on information provided by J. Ryan Loftus, P.E., Aspen Engineering, Inc.:
Using the existing VFDs is not feasible because of size. The existing drives are sized
for 10 hp on Well #2 and 30 hp on Well #1. Neither of these drives have adequate
capacity to control an anticipated 60 hp pump.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 18
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 19
Please provide documentation for well maintenance performed on each of the three MV
wells during 2021 -2023.
Response:
Attached is an Excel spreadsheet (FLS-W-24-01 IPUC DR 19 Attachment 1) showing
the routine work done at each wellsite owned by the Company. These tasks were
performed during the years 2021 – 2023.
During the years 2021 – 2023, three extra maintenance events occurred:
On August 12, 2021, American Pump pulled the 30 hp pump. It was full of rocks and
dirt. The pump was cleaned up onsite then reinstalled in casing. When the pump was
started to test it, it still sucked up rocks and mud. It was pulled a second time.
American Pump took the pump to their shop tore it apart and cleaned all rocks and mud
out. They built a special screen to help keep the rocks entering the pump and mounted
the screen to the pump. The pump was reinstalled and tested again. The well still
produced very muddy water. The pump was run to see if the water would clear up, but
the water failed to get clear. The Company’s personnel came back the next day to run
the pump to see if it would clear up. The water became clearer but not good enough for
drinking.
On December 6, 2021, American Pump pulled pump 2 to investigate why it kept having
faults showing on the ABB - VDF controls. They found a spot in the wiring insulation that
had rubbed the wire insulation off and exposed the bare wire. So, they spliced about 15
feet of new wire.
On June 12, 2023, American Pump lifted the well 1 pump so the water level could be
measured. The water level was at 67 feet. The pump was pumping murky water. The
discussion between the pump company and Tony Wise, the Company’s Operations
Manager, was that the well was in not recovering like it had in the past. No measuring
equipment could be put down well 2 casing to gauge the depth of the water level.
Attached As FLS-W-24-01 IPUC DR 19 Attachment 2 are the American Pump invoices
for the three maintenance events.
FLS-W-24-01
IPUC Staff PR 19
Page 1 of 2
In preparation for the 2024 irrigation season, wells 1 and 2 were started to determine
their condition. From March 11, 2024, through March 13, 2024, well 1 started and
produced around 150 gpm. The water did clear up for a time, but then produced some
murky water. The Company ran the pump several times with the same results. The
Company increased hertz setting on the VFD to try to produce more water. The flow
increased to 350 gpm and produced clear water. Tony Wise’s opinion is that the well
had some time to recharge itself, but he is not sure how long the better flow and
cleanness of the water will last.
Well 2 was started during this same period. The pump will not generate enough rpm to
produce water. The pump VFD set at 30 hertz produced 470 rpms. Increasing up to 55
hertz did not improve the rpms. This was tried several times with the same result. The
pump will need to be pulled to determine the problem.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 19
Page 2 of 2
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 20
Please provide the following documentation for the Project construction.
a. Project Plan
i. Initial project scope;
ii. Proposed budget;
iii. Proposed schedule;
and
iv. Expected completion date.
b. Requests for proposals ("RFP") or request for quotes ("RFQ")
i. Project requirements;
ii. Specifications; and
iii. All submitted bids including the bid selected by the Company.
Response:
The initial project scope is to drill a new well with 600 gpm to replace the existing wells 1
and 2. This will provide a firm pumping capacity to match Well 3 in the system to
provide adequate production redundancy for the system.
The proposed budget is provided in the response to FLS-W-24-01 IPUC DR 2.
The proposed project schedule is found in the Morning View Facility Plan (Application,
Exhibit 1) on page 26. It is estimated that the project will take approximately 198 days.
The expected completion date is November 15, 2024.
The construction design is not finalized or approved by DEQ at this time. All project
requirements and specifications will be provided to the PUC staff by July 1, 2024.
Bid results will be provided to the PUC staff by August 1, 2024.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 20
Page 1 of 1
Rates & Regulatory Affairs
FLS-W-24-01
In the Matter of the Application of Falls Water Co., Inc. For Approval of a Replacement
Well for Its Morning View System
Data Request Response
Request No.: FLS-W-24-01 IPUC DR 21
Please explain how the Company will ensure the construction of the Project is
completed at a reasonable least cost.
Response:
The Company will bid out the project to get the best low-cost and qualified bid for the
project.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 21
Page 1 of 1