20200831Staff 1-8 to Falls Water.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10655
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TI33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF FALLS WATER
COMPANY, INC.'S APPLICATION FOR
APPROVAL OF ACQUISITION OF THE
ASSETS OF MORNING VIEW WATER
COMPANY
cAsE NO. FLS-W-20-04
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
FALLS WATER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Falls Water Co., Inc.
(Falls Water; Company) provide the following documents and information as soon as possible,
by MONDAY, SEPTEMBER 21,2020.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company 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
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3t.01.0t.228.
FIRST PRODUCTION REQUEST
TO FALLS WATER AUGUST 3I,2O2O
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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. 1: On page 5 of its Application, the Company states that one of
Morning View's wells will likely require an upgrade. Please provide the following information:
a. The IDWR Well ID Number;
b. The reason for the proposed upgrade;
c. A description ofthe proposed upgrade; and
d. Estimated costs for the proposed upgrade.
REQUEST NO. 2: On page 5 of its Application, the Company states that a water
conservation plan or additional water rights may be required.
a. How did the Company determine it might need either a conservation plan or
additional water rights?
b. Under what circumstances does the Company foresee needing either a
conservation plan or additional water rights?
c. Please provide the estimated costs of the conservation plan or additional water
rights.
REQUEST NO. 3: Please provide a list of other likely capital investments for the
Morning View water system. Please include the estimated costs for those investments.
REQUEST NO.4: Confidential Exhibit No. 1, pg. 13, item (i) mentions "Terms and
Conditions of Morning View Water Company [nc." Please explain what those terms and
conditions are and provide any supporting documentation, including any applicable contracts.
REQUEST NO.5: In Confidential Exhibit No. l,pg.2, Section 5O, an "irrigation
water conservation plan" is discussed. Please provide the details of this plan and how it was (or
will be) implemented.
FIRST PRODUCTION REQUEST
TO FALLS WATER AUGUST 3I,2O2O2
REQUEST NO. 6: In Palfreyman's direct testimony on page 7, he requests that the
Commission treat prudently incurred expenditures in Morning View's Water Business as IO\Vo
equity. Did Falls Water consider any other treatment(s) to make the purchase of Morning View
economically viable? Please provide a list of the other treatments considered and reasons why
Falls Water decided on the one proposed in the Application.
REQUEST NO.7: In an effort to determine responsibilities after completion of the sale,
do Falls Water and Morning View have an agreement regarding who will be responsible for
filing the2020 Annual Report with the IPUC?
a. If not, why not?
b. If not, would the parties be able and willing to enter into an agreement regarding
which party, or a breakdown of how the parties, will be responsible for filing the
2020 Annual Report?
REQUEST NO.8: In an effort to determine responsibilities after completion of the sale,
do Falls Water and Morning View have an agreement on who will be responsible for filing and
paying the IPUC annual assessment for calendar year 2020? See ldaho Code *E 61-1003 and
61-1004.
a. If not, why not?
b. If not, would the parties be able and willing to enter into an agreement regarding
which party, or a breakdown of how the parties, will be responsible for filing and
paying the IPUC annual assessment for calendar year 2O2O?
,i*Dated at Boise, Idaho, this 3l day of August 2020
Matt Hunter
i/utility/umisc/production requestVfl sw20.4mhjt prod req I
FIRST PRODUCTION REQUEST
TO FALLS WATER J
Deputy Attorney General
AUGUST 3I,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3I't DAY OF AUGUST 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO FALLS WATER COMPANY, IN CASE NO. FLS-W-20-04, By E-MAILING A COpy
THEREOF, TO THE FOLLOWING:
PRESTON CARATER
CHARLIE BASER
601 W BANNOCK ST
BOISE TD 83702
E-MAIL: prestoncarter@gi vensourslev.com
charlebaser @ givenspursley.com
kendra @ givenspursley.com
ERIC W NELSEN
SR REGULATORY ATTORNEY
NW NATURAL
220 NW 2ND AVE
PORTLAND OR 97209
E-MAIL: [e-mail]
SECRET Y
CERTIFICATE OF SERVICE