20240417PAC to Staff 27-31.pdf

RECEIVED
Wednesday,April 17,2024 9:35 AM
IDAHO PUBLIC
UTILITIES COMMISSION
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]
morgan og odin(i�givenspursley.com
Attorneys for Falls Water Co., Inc.
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 FALLS WATER CO.,INC.'S RESPONSES TO
FOR ITS MORNING VIEW SYSTEM THE THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF
Falls Water Co., Inc. ("Falls Water" or"Company"), in response to the Third Production
Request of the Commission Staff to Falls Water Co., Inc. dated April 9, 2024, submits the
following responses. Responsive documents are available for download using the link provided
in the accompanying email.
DATED: April 17, 2024.
By:
Preston N. Carter
Givens Pursley LLP
Attorneys for Falls Water Co., Inc.
FALLS WATER CO.,INC.'S RESPONSES TO STAFF'S THIRD PRODUCTION REQUEST PAGE 1 OF 2
18308926.1)

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT on April 17, 2024, I caused a true and correct copy of the
foregoing to be served upon the following parties as indicated below:
Monica Barrios-Sanchez ® Email
Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Fax
P.O. Box 83720 ❑ Hand Delivery
Boise, Idaho 83720-0074
monica.barrio s sanchez(&_puc.Idaho.gov
Preston N. Carter
FALLS WATER CO.,INC.'S RESPONSES TO STAFF'S THIRD PRODUCTION REQUEST PAGE 2 OF 2
18308926.1)

(�) NW Natural
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 27
Please provide the necessary documentation and supporting workpapers on the
estimated cost for decommissioning Well Nos. 1 and 2.
Response:
The estimated cost to decommission Well Nos. 1 and 2 is $8,060. See FLS-W-24-01
IPUC DR 27 Attachment 1.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 27
Pagc 1 of 1

(�) NW Natural
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 28
Please provide the estimated useful life of the proposed Well No. 4.
Response:
Aspen Engineering estimates the useful life of the proposed Well No. 4 to be forty
years.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 28
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(;) NW Natural'
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 29
As supplement to the Company's Response to Production Request No. 2 -
Attachment 1 , please explain the line item "Contract Administration."
Response:
Ryan Loftus of Aspen Engineering gave the following explanation for the "Contract
Administration" line item:
"Contract Administration covers the Company's [Falls Water's] costs to coordinate and
oversee both the engineering work and the well drilling work. The work under this item
is generally completed by a third party that is hired directly by the Company (the utility)
to independently review design and bidding documents, to ensure they meet DEQ,
IDWR, and PUC requirements. Project documentation, as-built drawings, and insuring
contract work is completed in conformance to specifications and drawings are also
included in this item."
Pre parer/Res pond ing Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 27
Page 1 of 1

(�) NW Natural
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 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.
Response:
The power costs are not expected to rise significantly because most of the time (-90%),
Well Nos. 3 and 4 will not operate simultaneously. During emergencies or times of
record water demand, both wells will be operated simultaneously. This is expected to
be less than ten percent of the time. Inflation of power costs and rate increases have
not been included in this analysis.
It is estimated that the power costs may increase by ten percent due to the proposed
well having a larger pump than the two existing wells that will be replaced. The annual
increase is estimated to be $1,841.
The Morning View electrical cost summary for 2023 and the estimated power increase
calculation are provided in FLS-W-23-01 IPUC DR 30 Attachment 1.
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 30
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(�) NW Natural
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 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.
Response:
Aspen Engineering calculated the Average Daily Demand using the well production logs
in Appendix D: Water Production Data, pages 41-43 of the MV Facility Plan. The
average daily demand for each year was calculated and the average of the three years
average daily demand was calculated (See FLS-W-24-01 IPUC DR 31 Attachment 1 for
the Company's calculation of ADD, MDD and PHD).
Preparer/Responding Witness: Scott Bruce, General Manager, Falls Water Co., Inc.
[phone]
FLS-W-24-01
IPUC Staff PR 31
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