20240409Staff 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
[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 )
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