20231025Staff 1-26 to HWC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 BLilBOISE,IDAHO 83720-0074 MMISS:N
[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 HUSKY WATER )CASE NO.HWC-W-23-01
COMPANY FOR APPROVAL OF )ACQUISITIONOF THE ASSETS OF )FIRST PRODUCTION
RESORT WATER CO.INC.AND FOR THE )REQUESTOF THE
ISSUANCE OF A CERTIFICATE OF PUBLIC )COMMISSION STAFF
CONVENIENCE AND NECESSITY )TO HUSKY WATER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that HuskyWater Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
WEDNESDAY,NOVEMBER 15,2023.
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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO HUSKY WATER COMPANY 1 OCTOBER 25,2023
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.
REQUESTNO.1:Please provide all documentation used by the Company in performing
its due diligence for purchasing the water supply and distribution system assets of the Resort Water
Co.Inc.
REQUESTNO.2:Please provide the metes and bounds legal description of the
requested service territories attributed to the Resort Water Co.Inc.
REQUESTNO.3:Please indicate whether any private water,co-operative,municipal
or other Commission regulated water utility customer service territories overlap with the Resort
Water Co.Inc.service territory.If so,please identify all those that overlap,how they overlap,
and explain any effect from the overlapping of territories,such as disputes that may occur or
current or future planned agreements for keeping them separated.
REQUESTNO.4:Is the Resort Water Co.system currentlyin compliance with all
Idaho Department of Environmental Quality("IDEQ")and Idaho Department of Water
Resources ("IDWR")requirements and regulations?If not,please describe all noncompliance
issues and resolution plans.
REQUESTNO.5:For each water right used by the Resort Water Co.potable water
system,please provide the IDWR Water Right Number (basin and sequence number).
REQUESTNO.6:For each well used by the Resort Water Co.potable water system,
please provide the following:
a.The current IDWR Well Tag Number (D-Tag Number)on file;
b.Location (Township,Range,Section,and Tract);and
c.The well log.
REQUESTNO.7:Please provide details of all Resort Water Co.IDEQ and IDWR
FIRST PRODUCTION REQUEST
TO HUSKY WATER COMPANY 2 OCTOBER 25,2023
compliance discrepancies resolved within the past 5 years.
REQUESTNO.8:Please provide a thorough and complete description of the system
being acquired.This should include any known deficiencies that need to be addressed to
maintain system integrity and to support growth,as well as any changes/investments that the
Company plans to implement to address deficiencies relative to items included below.Please
include the costs and benefits for any future investments or potential increases in expense.
a.Processes and methods.This should include processes involved in the delivery of
water and business processes (i.e.billing,maintenance,customer support,etc.);
b.Manpower/staffmg,includingthe amount of labor and the level of
expertise/experience;
c.Equipment/infrastructure/software both direct (i.e.pipes,tanks,and pumps)and
indirect (maintenance equipment,computers,etc.);
d.Policies and standards (i.e.service level,maintenance turnaround time,etc.);and
e.Materials (productive material used for water quality,spare parts inventory,etc.).
REQUESTNO.9:Please provide an up-to-date geo-spatial system map of the Resort
Water Co.system showing the location and elevation of major equipment includingwells,
distribution piping,storage tanks,booster pumps,shut-off valves,meters,fire hydrants,and
water treatment equipment.Please include the followinginformation:
a.The make,model,and rating of each well pump;
b.The make,model,and rating of each well pump motor;
c.The make,model,capacity,and limit switch settings of each pressurized storage
tank;
d.The make,model,capacity,and limit switch settings of each unpressurized
storage tank/reservoir;
e.The make,model,and rating of each booster pump and motor;
f.The make,model,and capacity of all water treatment equipment;
g.The distribution piping line size and materials specified in the installation;and
h.The year,make,model,and capacity for backup generation supporting the well
pumps.Indicate if the generationhas an automatic transfer switch or otherwise if
FIRST PRODUCTION REQUEST
TO HUSKY WATER COMPANY 3 OCTOBER 25,2023
it must be manuallystarted.
NOTE:Please provide this map in an electronic format which can be enlarged to identify all
aspects of the system.
REQUESTNO.10:Please provide the specified material requirements and
construction details used in the installation of the Resort Water Co.distribution system piping.
REQUESTNO.11:Please provide any studies completed on the Resort Water Co.
potablewater system.This information would likely include assessments of:1)the capacity and
sizing of the system;2)system condition;3)the ability of the system to meet historical and
future system peak demand;4)capacity/constraints within the system;and 5)average
consumption and consumption during peak periods.
REQUESTNO.12:Please provide an estimate of total unaccounted water losses of the
Resort Water Co.system due to leaks,wasted water,etc.by month over the past 5 years.Please
explain how these losses are estimated.
REQUESTNO.13:Please provide the Resort Water Co.power bills over the past 5
years indicating the amount of electricity (kilo-watt-hour)used by each well and booster pump.
REQUESTNO.14:Please provide the Resort Water Co.monthlymetered amount of
water produced by each well over the past 5 years.
REQUESTNO.15:Please provide all Company analysis used for determining the
value of assets acquired from Schweitzer Mountain LLC Resort Water and the Ridge Water
System.Provide supporting information in Excel with formulas enabled.
REQUESTNO.16:Regarding fire protection,please provide the following:
a.The name and contact information of the fire authoritywho prescribes
requirements for the system;
b.Fire flow and storage requirements prescribed by the fire authority;and
FIRST PRODUCTION REQUEST
TO HUSKY WATER COMPANY 4 OCTOBER 25,2023
c.All reports,citations,warnings,and similar documents issued by the fire authority
over the last five years for the Resort Water Co.system.
REQUESTNO.17:Please provide the most recent Idaho Division of Environmental
Quality Sanitary Survey for Schweitzer Mountain LLC Resort Water and Ridge Water System
systems.
REQUESTNO.18:Please explain how the combined water system is interconnectedto
any other entity'swater system.
a.Describe the name and ownership of each interconnected water system;
b.Indicate if each interconnected water system is private,municipal,or regulated by
the IPUC;
c.Provide interconnection agreements for each interconnected water system;
d.Please explain any effect to the requested Certificate of Public Convenience and
Necessity;and
e.Provide DEQ interconnection approvals for each interconnectedwater system.
IDAPA 58.01.08 Rule 542.
REQUESTNO.19:Please describe any legal obligations,beyond water service,that
would be assumed by the Company as a result of the proposed acquisition.
REQUESTNO.20:Please describe the impact of de-annexing Lots 6,7,8,9,and 10
Block E plus the adjoining un-platted 2.3-acre parcel of land,and all of the Crystal Springs
Subdivision from Resort Water Company's service area and annexed into The Spires Water
Company's service area.See Case No.RES-W-ll-01 Order No.32327.
REQUESTNO.21:Please describe all public outreach activities that have occurred to
date.Indicate the type of outreach activities,locations,and dates.
REQUESTNO.22:Please describe credentials (certifications,licenses...)of all
individuals in addition to Robert Lesniewski who will be operating the proposed water system.
FIRST PRODUCTION REQUEST
TO HUSKY WATER COMPANY 5 OCTOBER 25,2023
Indicate individual names,credentials,dates credentials were issued and expirations.
Application at 7.
REQUESTNO.23:Please provide definitions of currentlyactive,inactive committed,
and available equivalent residential units ("ERU"s).T.Trulock Direct at 2.
REQUESTNO.24:Please provide the number of commercial ERUs for both the
Schweitzer Mountain LLC Resort Water and the Ridge Water System systems.
REQUESTNO.25:Please provide the number of municipal customers and the number
of ERUs for each for both the Schweitzer Mountain LLC Resort Water and the Ridge Water
System systems.
REQUESTNO.26:Please provide approval by the IDWR of the transfer of water
rights listed in Exhibit No.0004 on page 29 of the Application.
DATED at Boise,Idaho,this 25th day of October 2023.
Michael Duval
Deputy AttorneyGeneral
i:umisc:prodreq/HWC-W-23-01 PR#l
FIRST PRODUCTION REQUEST
TO HUSKY WATER COMPANY 6 OCTOBER 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF OCTOBER 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO HUSKY WATER COMPANY,IN CASE NO.HWC-W-23-
01,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE FOLLOWING:
RONALD L WILLIAMS TOM TRULOCK VP
BRANDON HELGESON C/O MOUNTAIN UTILITY COHAWLEYTROXELLETAL165VILLAGELANESTEA
PO BOX 1617 SANDPOINT ID 83864
BOISE ID 83701-1617 E-MAIL:ttrulock schweitzer.com
E-MAIL:rwilliams hawleytroxell.com
bhelgeson hawleytroxell.com
BRADLEY MULLILNS
MW ANALYTICS
TEITOTIE 2 STE 208
OULUNSALO FINLAND FI 90460
E-MAIL:brmullins mwanalytics.com
SECRETARY
CERTIFICATE OF SERVICE