20210323Staff 1-5 to Western Aircraft.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
WESTERN AIRCRAFT,INC.
CASE NO. SUZ-W-21-01
COMPLAINANT,
vs.FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
WESTERN AIRCRAFT, INC.
SUEZ WATER IDAHO INC.,
RESPONDENT.
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
John R. Hammond, Jr., Deputy Attomey General, requests that Westem Aircraft, Inc. ("Western")
provide the following documents and information as soon as possible, or by TUESDAY, APRIL
6,2021.r
This Production Request is continuing, and Western 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. Western is reminded that responses pursuant to
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staff s attorney
at [phone].
FIRST PRODUCTION REQUEST
TO WESTERN AIRCRAFT
MARCH 23,2021
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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 31.01.01.228.
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. 1: In its Complaint, Western asks the Commission to provide relief by
allowing "a temporary domestic water connection to Hangar 0 from the existing Hangar 1 water
line, pending the final resolution of this matter..." Complaint at 6. Please provide the following
information:
a. Please provide a drawing showing the routing, size, and capacity of the proposed
temporary connection.
b. Is its Western's intent that this temporary line provide water for fire service? If so,
will the proposed temporary line be able to provide the necessary fire flows?
c. Will Western be able to occupy Hangar 0 without it receiving fire service?
d. If this temporary connection were made, does Western intend to continue construction
of the covered walkway connecting Hangars 0 and l?
REQUEST NO. 2: What are the fire flow requirements for Hangar 0 and Hangar 1?
REQUEST NO. 3: In its Complaint (2B), Western asks the Commission to either approve
the revised connection plan prepared by T.O. Engineers on August 20,2020, or to "indicate which
of the (other) previously proposed alternative solutions it endorses so as to allow a water service
connection to Hangar 0..." Please provide a list and descriptions of the solutions that Westem
would like the Commission to consider.
REQUEST NO. 4: Regarding the non-potable lines encountered during Westem's
excavation for the Hangar 0 project:
a. What is the purpose of these lines and whom do they serve?
b. Who installed these lines?
c. Were these lines installed before, or after the Suez main on Boeing?
d. Please provide a drawing showing the location of these lines. Are they above or below
the Suez main?
FIRST PRODUCTION REQUEST
TO WESTERN AIRCRAFT
2 MARCH 23,2021
REQUEST NO. 5: Regarding the sewer line encountered during Western's excavation for
the Hangar 0 project:
a. Whom does this sewer line serve?
b. Who installed this line?
c. Was this line installed before or after the Suez main on Boeing?
d. Please provide a drawing showing the location of this line. Is it above or below
the Suez main?
Dated at Boise, Idaho, this 23'd day of March202l.
John Jr.
General
i:
umisc/prod req/suzw2l .ljh prod reql westem aircraft
FIRST PRODUCTION REQUEST
TO WESTERN AIRCRAFT
J MARCH 23,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF MARCH2O2I,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO WESTERN AIRCRAFT, INC., IN CASE NO.
SUZ-W-21-01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
DAVID H LEROY
ATTORNEY AT LAW
802 W BANNOCK ST STE 201
BOISE ID 83702
E-MAIL: [e-mail]
PRESTON N CARTER
BLAKE W RINGER
GIVENS PI.]RSLEY LLP
PO BOX2720
BOISE tD 83701-2720
E-MAIL: [e-mail]
blakeringer@.g ivenspursley. com
MARSHALL THOMPSON
SUEZ WATER IDAHO INC
8284 W VICTORY RD
BOISE ID 83709
E-MAIL: [e-mail]
I ..1..A ,4/n,--,.
SECRETARY /
CERTIFICATE OF SERVICE