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Home My WebLink About20200921Falls Water to Staff 1-8.pdfPreston N. Carter (ISB No. 8462) Charlie S. Baser (ISB No. 10884) Givens Pursley LLP 601 W. Bannock St. Boise,lD 83702 Telephone: (208) 388-1200 Facsimile: (208) 388-1300 prestoncarter@givenspursley. com charliebaser@givenspursley. com Attornqtsfor Falls Water Co., Inc. IN THE MATTER OF THE APPLICATION OF FALLS WATER CO., INC. FOR APPROVAL OF ACQUISITION OF THE ASSETS OF MORNING VIEW WATER COMPANY Iq,il,;*lVf;l] ;r:* SrP ? t P}{ l:0? '', '! rra;_.r - .,. 1. -\Lir.."r- :. .-i,l; rl;rii:rli$Sti"Ji{ BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case No. FLS-W-20-04 FALLS WATER CO., INC.'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Falls Water Co., Inc. ("Falls Water") submits the following responses to the First Production Request of the Commission Staffto Falls Water, dated August 31,2020. Please note that the response to Request No. 6 is confidential and will be submitted under separate cover per the Commission's rules. DATED: September 21, 2020. GMENS PURSLEY LLP Preston N. Carter Charlie S. Baser Givens Pursley LLP Attorneys for Falls Water Co., Inc. FALLS WATER',S RESPONSE TO FIRST PRODUCTION REQLTEST I53I9852_l.docx [3988-l l] PAGE I oF 2 CERTIFICATE OT SERYICE I certify that on September 21,2020, a true and correct copy of Falls Water Co. Inc.'s Response to First Production Request of the Commission Staff was served upon all parties of record in this proceeding via electronic mail as indicated below: Commission Staff Jan Noriyuki, Commission Secretary Idaho Public Utilities Commission I 1331 W. Chinden Blvd., Bldg. 8, Ste. 201-A Boise,ID 83714 i an.noriyuki@puc. idaho. eov Electronic Mail Matt Hunter Deputy Attorney General Idaho Public Utilities Commission 11331 W. ChindenBlvd., Bldg. 8, Ste.20l-A Boise, ID 83714 Matt. Hunter@nuc. idaho. gov Electronic Mail ,?2-4:-:- PrestonN. Carter FALLS WATER'S RESPONSE TO FIRST PRODUCTION REQUEST I 531 9852_l.docx U3988-l U Pecs 2 or 2 {} ** rqturof Rates & Regulatory Affairs FLS-W-20-04 Morning View Water Company Acquisition Data Request Response Reouest No.: FLS-W-20-04 IPUC DR 1 REQUEST NO. 1: On page 5 of its Application, the Company states that one of Morning Vie#s wells will likely require an upgrade. Please provide the following information: a.The IDWR Well lD Number; b.The reason for the proposed upgrade; c.A description of the proposed upgrade; and d.Estimated costs for the proposed upgrade. Response: a. IDWR lD Number 390668 (Wel!#1). b. Well #1 was drilled in 1986. The sump pump for that wellfailed. c. The upgrade replaces the sump pump with a new pump. d. The estimated cost of the upgrade is $10,000. <fr t{W }lqturol" Rates & Regulatory Affairs FLS-W-20-04 Morning View Water Company Acquisition Data Request Response Request No.: FLS-W-20-04 IPUC DR 2 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 circumstiances does the Company foresee needing either a conservation plan or additionalwater rights? c.Please provide the estimated costs of the conservation plan or additional water rights. Response: a. The Company examined data for water production that came from annual reports. The annual production (Duty) in these reports clearly exceeded water rights held by Morning View Water Company (MVWC). More recent data have been provided by M\ /VC that show a steep reduction in production from previous years that indicate that water right Duty is not being exceeded. The Company questions reliability of the data that have been supplied and cannot rule out the need for a conservation plan or additionalwater rights until more robust, data driven analyses can be made under our ownership. Additionally, diligence efforts revealed that the well pump control configuration would exceed the MMIVC water right for instantaneous flow (Allowed Diversion Rate). The Company believes that this issue may be resolved through controls and relays to prevent both pumps from coming on at the same time. b. A conservation plan or additional water rights will be required if subsequent reliable data and analyses show exceedance of existing water rights (Duty or Allowable Diversion Rate) for current and projected platted connections. Additionally, if efforts fail to yield desired empirical results, a conservation plan and/or additionalwater rights will be required. c. Additionalwater rights cost is determined by the Duty, Allowed Diversion Rate Required and Use (i.e., consumptive and non-consumptive). Allthree variables are unknown at this point. The cost of a Conservation Plan is dependent on the scope of work, which will be dependent upon working knowledge of the three variables mentioned. O .* Noturqr Rates & Regulatory Affairs FLS-W-20-04 Morning View Water Company Acquisition Data Request Response Request No.: FLS-W-20-04 IPUC DR 3 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. Response: Falls Water may decide to conduct a leak detection assessment on the Morning View water system after the acquisition. The assessment would cost about $6,000. lf any leaks are found, additional repair costs would be needed to fix the leaks. The cost to repair any leaks detected is roughly estimated at $10,000. ln that case, the project in totalwould cost about $16,000. {|} *, ilqturol' Rates & Regulatory Affairs FLS-W-20-04 Morning View Water Company Acquisition Data Request Resoonse Request No.: FLS-W-20-04 IPUC DR 4 REQUEST NO. 4: Confidentia! Exhibit No. 1, pg. 13, item (i) mentions "Terms and Conditions of Morning View Water Company lnc." Please explain what those terms and conditions are and provide any supporting documentation, including any applicable contracts. Response: FLS-W-20-04 IPUC DR 4 Attachment 1 is a copy of the referenced "Terms and Conditions" document, dated Apri|27,2000. It is our understanding that this contract was already fully performed. Falls Water is taking assignment of the contract out of an abundance of caution, in the unlikely event that the contractor did not comply with the specifications, we discover a problem related to such failure and we want to try to enforce the contract against the contractor. f_*,302837 F :TST AMEF.;CAN TITLE MORNING VIEW WATER C0., INC. 208-745-0079 Apdl27,200o Brent Charles Hillman 260 State Street Rigby ID 83442 SUBJECT: MATERIAL SPECIFICATIONS :. Valves : Cast-iron gate valves ' Joint couplings: cast iron with bolts and gaskets.. Concrete. Tee's: cast iron. Flushing raalves: steel and cast iron 2". Pipe: Class 200 PVC with washers A}I IDAHO PUC 3996 E 200 N P O BOX 598 RJGBY TD 83M2 FlX208-745-0041 Mvhomes@ida.net * 'l flriru (t, lnrtnrrrnt # !02137llltYJEriEttoI,D fio2OE05.tg oa:tOfl tao o, p.e..: tlcqdrdbr: tntTAEttCiAX TTTLE - COrIGLKELLET t.:i-m {UEr€{lcblrcor& Dary O?h-rb: [CB-LALq.affi ]ERMS A}ID CONDITIONS OF MORNING VIEW WAIER CO INC. PROVIDING WATER TO: COLINTRY GRO\IE ESTATES, MOBILE HOtvIE SUBDTUSION, DTVISION #I, JEFFERSON COLINTY, DAHO, LEGAL DESCRIPTION; T4N., R39E., B.M. SECTION 30. MORNING VIEW WATER CO. INC. I.P.U.C., WATER PROVTDE& HEREIN AFTER CALLED TI{E WATER PROVIDER. CHARLES BRENT HILLT4AN, A T{ARRIED I{AN, CONTRACTOR. HEREIN AFTER CALLED CONTRACTOR WATER SERVICES: All fittings are to be brass Brass corporation valve and collar Brass grip joint adapter to c,onnect with corp. valve and l' PVC water pipe l" copper and brass meter yokc and holder 5'X 20' poly metor pit with 20n X 12' pit octension Cast iron L2242 meter pit ring & cover l'w&ter metcrl' bEll or gate valve under the homes A\ I L2 b rw rhi,^) d]okL^r + o )n'o ,,,'r.,0*, 1t/'a I{'1 I '-l- Wrtrr rtrsra! b56va Cordry Or9r . lla AK,,C" B.ar Hilh.o l,/rah3 Virn Warr Co be a. .&tro h$lic ud&y eocplty INSTALLATION: The contractor is to provide all the materiats, and do all the installation under the zupewision of a licensed engineer. The trenghes are to be 5'-6' in the ground with 6" of bedding sand under the pipe arrd 6" of sand on top of the pipe. Anyrhere there is a.T or a bend in the pipe, a concrete thrust block is to be installed. The ends must bc capped and a thrust block must be installed or an approved joint. Restraint must be placed on all the ends. A flushing valve is to be attsched to thc ends ofthe pipe, also. SERVICE INSTALLATION: Each service is to have a brass cotlar on the 6o mainline. A brass corporation valve is to be attached to the collar and a male tlreaded, brass squeegee connestor is to be instslled. One inctr, 200 PSI PVC, water pipe is to be instatled; and run up into the meter pit. A copper meter yoke is to be installed in the pit and a 2' water line is to be run up under the footing with alelrer/ball valve or 8 glte valve attached using a 1" squeezo coupling. The services arc to be bedded in sand and inspected by the plumbmg department, (Crug Hammond, 208452-7210). When completed the lines and the seryice's are to be dedicated to Morning View Watcr Co., Inc., an tdabo Public Utility Company for service and maintenance. RATES:The rates 8re set by the Idatro Pubtio Utilities Commission and each lot owner is to pay this amount alier we start to providc scrvicc. Thc billings are to be provided montfily, by the water provider and an sgrecmcnt is to be sigred bdweecr the water provider and each now lot owner. 6rrt Brent Charles tlltmarl Contractor Morning , LP.U,C. Water 2 tr" STATE OFIDATIO COLINTY OFJEFFER^SON On this 18III day of IvIAY, 2m, before sE, a Nomry Rfilic, persunlly qppearcd BRENIT CHARLES HILLMAN, knoqm u llentiff to np to be te person or pemons wtnse ran(s) is suhcribed o ttE wittin ksm:rrer4 ard aclmvledgBd to rre that lr exeqred tlr sure. kr Wiurss wtEreot I harc hereuo set my hard ard Certificae fint abow sri@n. tte day ard year in this Noary Publb b StaE ofldaho ReskiirgAx RD(BURG,ID Cornmisskln Eryircs: 11{&2m5 STATE OF IDAHO COI]NTY OFJEFFERSON On tlds l8TlI day of IvIAY, 200, before m, a Nohry fublb in ard for salt Shte of Idab, persorully apeearcd NOL"AN GNEITING, known or llerrifiod to rrr to be fb PRESIDENT of tir corpor*ion that ei.orU tre irstumert u the persm wln oxured fu Insrurnerr on belnlf of said Corpcration, ard acknowledged b ne frat srh corporatixt extm.d tp sanp. h WitrEss t'ereot I ha\rc hemrtb setmy tnrd ard affixod my official seal the day ard year in ftis Certificale f:rst above wriffit., Noury Publb Shte of Idaho Residing: REGURG,ID Commission Epires: I 1-0&2m5 $ ** roturqr Rates & Regulatory Affairs FLS-W-20-04 Morning View Water Company Acquisition Data Request Resoonse Request No.: FLS-W-20-04 IPUC DR 5 REQUEST NO. 5: ln Confidential Exhibit No. 1, pg. 2, Section 5(j), an "irrigation water conservation plan" is discussed. PIease provide the details of this plan and how it was (or will be) implemented. Response: The irrigation water conservation plan was created in April 2009 for Moming View Water Company. This plan was part of a master plan effort ("Final Facility Plan, Morning View Water Company'' Aspen Engineering, J. Ryan Loflus, P.E., April, 2009). The plan srunmary is shown below "Recommendations/Conclusions: Providing and maintaining adequate system pressure is the first priority for the MVWC water system. System operating pressures were adjusted in late July of 2008 to 50 psi min and 7 5 psi max. Pressure monitoring data collected November 13-20,2008 indicates adequate pressures are being maintained in system indicating the low pressures are due to the increased demand during the irrigation season. Installation of meters to promote water conservatioz should be the first capital improvement to the system. Implementation of a tiered rate structure, after installation of the meters, will further aid conservation efforts and reduce the ADD [(Average Daily Demand)]." Individual connection meters are an effective way of sending price signals to consumers to reduce excessive consumption. The metering project has been completed and meters .tre now installed at all individual connections in the system. {} ** llqturol' Rates & Regulatory Affairs FLS-W-20-04 Morning View Water Company Acquisition Data Request ResPonse Request No.: FLS-W-20-04 IPUC DR 7 REQUEST NO. 7: ln an effort to determine responsibilities after completion of the sale, do Falls Water and Morning View have an agreement regarding who will be responsible forfiling the2020 Annual Reportwith the IPUC? a.lf not, why not? b.lf not, woutd 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 2O2O Annual Report? Response: Yes, Falls Water will be responsible forfiling the 2020 Annual Report with the IPUC '(f ** Noturol' Rates & Regulatory Affairs FLS-W-20-04 Morning View Water Company Acquisition Data Request Response Request No.: FLS-W-20-04 IPUC DR 8 REQUEST NO. 8: ln 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 2O2O? See ldaho Code SS 61-1003 and 61-1004. a.lf not, why not? b.lf 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 2020? Response: Yes, Falls Water wil! be responsible for filing and paying the IPUC annual assessment for calendar year 2020.