20240917Staff 1-6 to ROC.pdf

FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN UTILITY CO. 1 SEPTEMBER 17, 2024
MICHAEL DUVAL DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 BOISE, IDAHO 83720-0074 [phone] IDAHO BAR NO. 11714

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 ROCKY MOUNTAIN UTILITY CO., INC. TO AMEND ITS CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY
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CASE NO. ROC-W-24-01
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO ROCKY MOUNTAIN UTILITY CO., INC.
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Rocky Mountain Utility Co., Inc.
(“Company”) provide the following documents and information as soon as possible, but no later
than TUESDAY, OCTOBER 8, 2024.
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
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
RECEIVED
Tuesday, September 17, 2024 11:11:26 AM
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN UTILITY CO. 2 SEPTEMBER 17, 2024
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. 1: In its Application, the Company requests an amendment to its
Certificate of Public Convenience and Necessity (“CPCN”) No. 296. However, Commission
Order No. 30703 issued CPCN No. 481 for the Company to operate under. Please explain this
discrepancy.

REQUEST NO. 2: The legal description and Attachment A show the requested area for
a CPCN is Division No. 3 in Pepperwood Crossing Subdivision. However, Attachment B that
includes the plat map for the new phase, shows only Division No. 3A. Please clarify whether the
requested expansion area for CPCN in this case is Division No. 3 or Division No. 3A.

REQUEST NO. 3: CPCN No. 481 that was approved in Case No. ROC-W-08-01
through Commission Order No. 30703, was issued for Division I - Pepperwood Crossing
Subdivision. In that case, the Company requested a CPCN for Division 1, and Division 2, as
well as other subdivisions outside of Pepperwood Crossing. Division 2 in that case appears to be
the same area as Division 3, which is the area of expansion for the amended CPCN being
requested in this case. Please explain and reconcile the different divisions in reference to the
ROC-W-08-01 case and the present Application.

REQUEST NO. 4: As mentioned in the Application, the hydraulic modeling study
determined that there is adequate capacity on the Company’s existing system to serve this new
subdivision without the need for construction of additional sources of supply or storage facilities.
Please explain why a new well was constructed for Division No. 3B.

REQUEST NO. 5: Please provide the engineering report and hydraulic modeling results
in raw file format, which can be opened in Excel.