20210805Staff 4-15 to NSW.pdf

Street Address for Express Mail:
I 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03r4
TDAHO BAR NO. 5214
IN THE MATTER OF THE APPLICATION OF
NORTH STAR WATER, LLC TO REQUEST
THE COMMISSION TO ISSUE A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY (CPCN) AUTHORIZING THE
NORTH STAR WATER, LLC TO OPERATE AS
A PUBLIC UTILITY IN THE STATE OF IDAHO
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CASE NO. NSW-W-21-01
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO NORTH STAR WATER, LLC
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The Staff of the Idaho Public Utilities Commission ("Commission"), by and through its
attorney of record, Erick Shaner, Deputy Attorney General, requests that North Star Water,
LLC ("Company") provide the following documents and information as soon as possible, but
no later than THURSDAY, AUGUST 26,2021.
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
SECOND PRODUCTION REQUEST
TO NORTH STAR WATER AUGUST 5,2021
number of the person preparing the documents. Please also identifu the name, job title,
location, and telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 4: Please provide the Electrical Rate Schedule(s) that North Star
Water, LLC will be charged for electricity to operate the water system.
REQUEST NO. 5: Please provide the following information needed to calculate
consumption per subdivision lot:
a. An estimated average number of bathrooms, number of bedrooms, and square
footage by lot;
b. The amount of estimated consumption in gallons for potable water by lot for each
month of the year; and
c. The amount of estimated consumption in gallons for irrigation water by lot for each
month of the year.
REQUEST NO. 6: Is North Star Water able to provide irrigation service to North Star
customers outside of the beneficial use period of 03/01 to 1ll15 stated in the Water Right No.
63-33225? Please explain.
REQUEST NO. 7: The Well House Schematic provided with the Application in
Appendix 3 shows a single flowmeter. Will North Star Water be able to track consumption for
the Domestic system and the Irrigation system separately? If so, please explain how
consumption for the two systems will be tracked separately. If not, please explain if North Star
Water has any plans to add additional meter(s) to track consumption separately.
REQUEST NO. 8: In Attachment 6 of North Star Water's response to Staff
Production Request No. 3, there is at3,l25 hookup fee in the Water System Agreement.
Please answer the following:
SECOND PRODUCTION REQUEST
TO NORTH STAR WATER 2 AUGUST 5,2021
a. What is the purpose for the $3,125 hookup fee paid by Elevation Partners, LLC to
North Star Water?
b. If the $3,125 hookup fee is for the cost to hook up a new customer, please provide a
breakdown of the individual component costs for irrigation and potable water
system, separately.
REQUEST NO. 9: Please provide a breakdown of the cost responsibility for installing
the domestic water distribution system between Elevation Partners, North Star Water, and the
lot owner. Please provide the breakdown by the following sections of the domestic distribution
system:
l. The well house to individual corporation stops for each lot on the distribution water
lines;
2. Corporation stops to the curb stops for each lot; and
3. The curb stops to final consumption points on each lot.
REQUEST NO. 10: Please provide a breakdown of the cost responsibility for
installing the irrigation water distribution system between Elevation Partners, North Star
Water, and the lot owner. Please provide the breakdown by the following sections of the
irrigation distribution system:
1. The well house to individual corporation stops for each lot on the distribution water
lines;
2. Corporation stops to the curb stops for each lot; and
3. The curb stops to final consumption points on each lot.
REQUEST NO. 1l: In reference to "Pressurized irrigation will be provided to the
common area lots of North Star Subdivision at the cost of the irrigation service for one lot per
yeff," mentioned in the Water System Agreement in Attachment 6 of North Star Water's
response to Staff Production Request No. 3, please provide the estimated average monthly
consumption in gallons for the common area lots of the North Star Subdivision.
SECOND PRODUCTION REQUEST
TO NORTH STAR WATER J AUGUST 5,2021
REQUEST NO. 12: Please provide the basis and calculations for how the $70 per
month domestic service charge and the $30 per month irrigation charge were determined.
Please provide any workpapers used to determine the charges in electronic format with links
and formulae enabled.
REQUEST NO. 13: Please provide the basis and calculations for how the $250 per
month and $3,000 annual power cost in the Application (Appendix 8 - Operation &
Maintenance Expenses Budget) were derived. Please provide any workpapers used to
determine the power cost in electronic format with links and formulae enabled.
REQUEST NO. 14: Please provide the basis and calculations for all other costs (aside
from power costs) listed in Appendix 8 - Operation & Maintenance Expenses Budget. Please
provide any workpapers used to determine these costs in electronic format with links and
formulae enabled.
REQUEST NO. 15: Please explain the discrepancies between the Operations and
Maintenance Expenses in Appendix 8 in the Company Application and Exhibit I l.l in the
Technical, Financial, and Managerial Capacity for a New Public Water System dated May
202t.
DATED at Boise, Idaho, thi, {Aay of Augu st2O2l.
'A
Erick Shaner
Deputy Attorney General
i:umisc:prodreq/nsww2l. lesme prod req 2
SECOND PRODUCTION REQUEST
TO NORTH STAR WATER 4 AUGUST 5,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAvE THIS 5TH DAY oF AUGUST 2021,
SERVED THE FOREGOING SECOND PRODUCTION REQI]EST OF THE
CoMMISSTON STAFF TO NORTH STAR WATE& LLC, IN CASE NO.
NSW-W.2I-OI, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MIKE BLACK
NORTH STAR WATER LLC
PO BOX 3723
NAMPA ID 83653
E-MAIL: [e-mail]
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SECRETTF{ /--
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CERTIFICATE OF SERVICE