20190617Staff 15 to Gem State.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 334-03 14
IDAHO BAR NO. 10446
BAR ESTATES, L.L.C. AND BAR CIRCLE ''S''
WATER,INC.; FOR TRANSFER OF
CERTIFICATES OF PUBLIC CONVENIENCE
AND NECESSITY OF DIAMOND BAR
ESTATES, L.L.C. (NO. 413) AND BAR CTRCLE
rrsrr WATER,INC. (NO.296); AND REQUEST
FOR MODIFIED PROCEDURE
RECEIVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
BEFORE THE TDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPROVAL OF )
ACQUISITION OF THE ASSETS OF DIAMOND )CASE NO. BCS.W.19-01
DIA-W-19-01)
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SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
GEM STATE WATER
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Gem State Water Company (Gem State
Water) provide the following documents and information as soon as possible, or by MONDAY,
JULY 8,2019.
This Production Request is continuing, and Gem State Water 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Gem State Water is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
SECOND PRODUCTION REQUEST
TO GEM STATE WATER COMPANY JUNE 17,2OI91
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0r.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 15: The following is DEQ's Ground Water Source Redundancy
requirement:
IDAPA 58.01.08.501.17. Ground Water Source Redundancy. New
community water systems served by ground water shall have a minimum
of two (2) sources if they are intended to serve more than twenty-five (25)
connections or equivalent dwelling units (EDUs). Under normal operating
conditions, with any source out of service, the remaining source(s) shall be
capable of providing either the peak hour demand of the system or a
minimum of the maximum day demand plus equalization storage. See
Subsection 501.18 for general design and redundancy requirements
concerning fire flow capacity.
Please provide a detailed explanation of Gem State's long-term plan to satisff the requirement
which includes the following:
a. Purchasing the existing backup well and serving the customer from the system if
needed.
b. A timeline and cost estimates for each of the plan's elements.
c. If the Company has considered construction of a new back-up well, please provide
information about siting, and any easements for the well or the pipeline from the well to
the Diamond Bar Water System.
d. If the Company has considered construction of an interconnect from another water
system (such as Bar Circle S), please provide information about the location of the
interconnect and any easements that may be necessary.
SECOND PRODUCTION REQUEST
TO GEM STATE WATER COMPANY 2 JLINE 17,2OI9
Dated at Boise, Idaho, this nY1"'day ofJune 2019.
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Ed*"rd GAe
Deputy AttoXey General
i:umisc:prodreq/bcswl9. 1_ejcwh prod req2
SECOND PRODUCTION REQUEST
TO GEM STATE WATER COMPANY 3 JUNE 17,2OI9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF JI.INE 2019,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO GEM STATE WATER COMPANY, IN CASE NOS.
BCS-W-I9-OI/DIA-W-l9-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
PRESTON CARTER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE TD 83702
E-mail: [e-mail]
kendrah(!. givenspursley. conr
ERIC W NELSEN
SR REGULATORY ATTORNEY
NW NATURAL
220 NW 2ND AVE
PORTLAND OR 97209
E-mail: Eric.Nclsen(t?nwnatural.com
CERTIFICATE OF SERVICE
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