20241112Staff 1-7 to PLW.pdf

RECEIVED
Tuesday, November 12, 2024 2:28:17 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
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 PRIEST LAKE WATER )
LLC APPLICATION FOR CERTIFICATE OF ) CASE NO. PLW-W-24-01
PUBLIC CONVENIENCE AND NECESSITY )
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO PRIEST LAKE WATER LLC
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Priest Lake Water LLC ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY,DECEMBER 3, 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.
FIRST PRODUCTION REQUEST
TO PRIEST LAKE WATER LLC 1 NOVEMBER 12, 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: As noted in the Application, Appendix 2B—Map, it shows seven
parcels that have a water connection that are not reflected on the legal description of the plat map
in Appendix 2A. Please clarify whether the proposed area for the Certificate of Public
Convenience and Necessity ("CPCN") to be issued in this case includes the seven parcels as well
as the legal description of the area in the plat map. Additionally, if the seven parcels are
included in the proposed area,please provide a legal description of the seven parcels.
REQUEST NO. 2: The map shown in the place-of-use boundary for water right 97-
7368 in Appendix5A does not match the legal description in the Plat map. Specifically, the
southwest corner, Lot No. 21 in Block 2 is excluded in the water right map. Please explain
whether the corner area will be excluded from the proposed area for the CPCN or whether the
water right will be amended to include the corner area.
REQUEST NO. 3: As per Appendix 8 —Facility Plan Map, in the Application, the plan
area has 7 blocks with a total of 90 lots, as shown in the table below:
BLOCK 1 BLOCK 2 BLOCK 3 BLOCK 4 BLOCK 5 BLOCK 6 BLOCK 7 Total
17 21 10 25 12 12 10 107
However, the Company stated that 113 lots will be supplied by the water system. Please
reconcile the difference in the totals and provide the reconciled number of lots for each block.
REQUEST NO. 4: The Idaho Department of Environmental Quality rules, IDAPA
58.01.08 Section 501.17 states that under normal operating conditions, with any source out of
service, the remaining source(s) must be capable of providing either the peak hour demand of the
Public Water System or a minimum of the maximum day demand plus equalization storage.
Please explain whether the remaining well can provide the maximum day water demand in the
service area, in case any well is out of service. Additionally, if the water system supports fire
FIRST PRODUCTION REQUEST
TO PRIEST LAKE WATER LLC 2 NOVEMBER 12, 2024

flow capacity, please explain whether the maximum day demand plus fire water can be provided
with any pump out of service, as noted in IDAPA 58.01.08 Section 501.18.
REQUEST NO. 5: Appendix 5A in the Application shows that Marvin Estates Water
owns water right No. 97-7368. Please provide proof that the Company to use the water right.
Also,please explain the relationship between Marvin Estates Water and the Company.
REQUEST NO. 6: The Company only provided the seasonal production water rate in
Appendix 9 of the Application, and not the monthly metered amount of pumped water data from
each source over the past 3 years as requested in Question 7 in the Application. Please answer
the following:
A. Please explain in detail why the requested information wasn't provided.
B. If the information is available, please provide the requested information.
C. If not, please provide any pumped water data that is available as close to that
requested in Question 7 as reasonably possible.
D. If five years of data is available for B and C, above, please provide the data for the
additional years.
REQUEST NO. 7: Please provide detailed information related to the capacity of the
system to meet historical and future system peak demand. Information should include not only
the capacity of the system and the identification of constraints within the system, but also
ordinary consumption and consumption at peak hour. Please provide the necessary workpapers
in Microsoft Excel format with formulas intact.
DATED at Boise, Idaho, this 121h day of November 2024.
A m riplett
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\PLW-W-24-01 PR#l.docx
FIRST PRODUCTION REQUEST
TO PRIEST LAKE WATER LLC 3 NOVEMBER 12, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS —11; DAY OF NOVEMBER
2024, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PRIEST LAKE WATER LLC , IN CASE NO. PLW-W-24-
01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
JARED HORLACHER SARAH B McOWEN
OWNER SMITH & McOWEN
PRIEST LAKE WATER LLC 102 SUPERIOR ST
279 TRACY LANE PO BOX C
PRIEST LAKE ID 83856 SANDPOINT ID 83864
E-MAIL: jaredhorlacherLayahoo.com E-MAIL: sarah�smithmcowenlaw.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE