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HomeMy WebLinkAbout20240409Staff 27-31 to FLS.pdf RECEIVED Tuesday,April 9,2024 4:40 PM IDAHO PUBLIC UTILITIES COMMISSION CHRIS BURDIN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 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 ) OF FALLS WATER CO., INC. FOR ) CASE NO. FLS-W-24-01 APPROVAL OF A REPLACEMENT WELL ) FOR ITS MORNING VIEW SYSTEM ) THIRD 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 TUESDAY, APRIL 16, 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. THIRD PRODUCTION REQUEST TO FALLS WATER CO., INC. 1 APRIL 9, 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. 27: Please provide the necessary documentation and supporting workpapers on the estimated cost for decommissioning Well Nos. 1 and 2. REQUEST NO. 28: Please provide the estimated useful life of the proposed Well No. 4. REQUEST NO. 29: As supplement to the Company's Response to Production Request No. 2—Attachment 1, please explain the line item"Contract Administration." REQUEST NO. 30: Please provide the necessary documentation and supporting workpapers on the estimated power cost of the Morning View system with Well No. 4 fully operational. REQUEST NO. 31: Please provide justification and necessary workpapers on how the Company calculated the estimated future water demand parameters, "ADD = 124,000 gpd," "MDD = 399,200 gpd," and"PHD=496,000 gpd," as reported in MV Facility Plan at 16. DATED at Boise, Idaho, this 9th day of April 2024. Chris Bur in Deputy Attorney General I:\Utility\UMISC\PRDREQ\FLS-W-24-01 PR#t 3.docx THIRD PRODUCTION REQUEST TO FALLS WATER CO., INC. 2 APRIL 9, 2024 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE ON THIS q]�_DAY OF APRIL 2024 SERVED THE FOREGOING THIRD 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.nelsenRnwnatural.com E-MAIL: prestoncarter(a givenspursley.com morgan og odin(a,givenspursley.com stephaniewA ivenspursley.com K. SCOTT BRUCE FALLS WATER CO., INC. 2180 NORTH DEBORAH DRIVE IDAHO FALLS, ID 83401 E-MAIL: scottlOc fallswater.com PATRICIA JORDAN CERTIFICATE OF SERVICE