20050301Amendment and Supplement.pdf

John R. Hammond, Jr., ISB No. 5470
William J. Batt, ISB No. 2938
BATT & FISHER, LLP
S. Bank Plaza, 5th Floor
101 S. Capitol Boulevard
Post Office Box 1308
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
F?ECE1VED
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Z3u5 MAR - I PH 3: S~
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UTILIT lES'- cof:i~1fSS'nN
Attorney for Terra Grande Water
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA TTER 0 F THE
APPLICATION OF TERRA GRANDE
WATER REQUESTING THAT THE
COMMISSION AUTHORIZE INTERIM
RATE RELIEF AND FURTHER
PROCEEDINGS TO ESTABLISH JUST
AND REASONABLE RATES
Case No. 'fCW 05 i6lV- w-dj"'-O I
AMENDMENT AND SUPPLEMENT
TO APPLICATION
COMES NOW Terra Grande Water (the "Company" or "Terra Grande ) and pursuant to
Commission Rule of Procedure 66 makes this Amendment and Supplement to its Application
filed on February 9, 2005, with the Idaho Public Utilities Commission ("Commission ) that
requested an Order approving interim rate relief that would increase the Company s current rates
and charges for water service in the State of Idaho.
First, due to the emergency which created this matter and because the Company filed its
Rate Application prior to receiving its first bill from United Water, Terra Grande requests that
the Commission make any interim rate relief effective as of January 28 2005 , the date on which
United Water began supplying water to the Company s system.
At the time Terra Grande submitted its Application to the Commission, it had yet to
receive a bill from United Water of Idaho, Inc. for the water that was supplied to the Company
AMENDMENT AND SUPPLEMENT TO APPLICATION, P. 1
ORiGINAL
for its customers. Terra Grande received its first bill from United Water on February 22, 2005, a
copy of which has been attached as Exhibit A to this pleading for the Commission s review.
This bill is for $723.49 for a seventeen day period. Although this bill is for a relatively short
period of time, it still provides the Commission with hard data to consider in the context of the
Company s request for interim and more permanent rate relief.
Finally, Terra Grande has recently been annexed into the City of Boise. Accordingly, to
the extent applicable, Terra Grande requests that the Commission consider the potential impacts
on the Company s rates that could occur due to the imposition of any municipal franchise fee by
the City of Boise for the sale of water to its customers.The Company requests that the
Commission consider this both for any interim or permanent rates it chooses to authorize.
WHEREFORE, Terra Grande respectfully requests of the Commission:
That the Commission allow the above Amendments to its Application.
That its previously filed Application, amended and supplemented by this filing, be
heard and acted upon at the earliest possible date;
That the Commission find that Terra Grande s existing rates are unjust
unreasonable and insufficient to provide the Company the recovery of its costs
and a fair rate of return, and that the revised rates and charges proposed in this
Application are just and reasonable on an interim basis. Terra Grande requests
that the Commission permit the Company to charge its customers these rates
effective upon the receipt of its first bill from United Water.
The Commission establish further proceedings to establish just and reasonable
rates for Terra Grande s customers.
AMENDMENT AND SUPPLEMENT TO APPLICATION, P. 2
Deferred accounting treatment for excess water supply costs above interim rates if
appropriate.
That the Commission grant such other and further relief as the Commission may
determine proper in the circumstances.
6";-
DATE this of March, 2005.
BA TT & FISHER, LLP
. Hammond, Jr.
tto eys for Terra Grande Water
AMENDMENT AND SUPPLEMENT TO APPLICATION, P. 3
CERTIFICATE OF SERVICE
!,~
I HEREBY CERTIFY that on this day of March, 2005 , I caused a true and correct
copy of the above and foregoing document to be served, in the manner indicated, on the
following:
Dean J. Miller
Attorney for United Water of Idaho, Inc.
MCDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, Idaho 83702
Hand Delivery
~ U.S. Mail
Facsimile
Federal Express
AMENDMENT AND SUPPLEMENT TO APPLICATION, P. 4
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PLEASE DIRECT ALL
INQUIRIES OR
CORRESPONDENCE TO UNITED WATER IDAHOPO 80X 190420
8Z~8 WEST VICTORY RbBOISE, 10 83719-0420PHONE ~ 208-~'2-7~O4
METER READINGS
04180747 01/28/05 02/14/05000000 00031604180747 01/28/05 02/14/05
0000 0375CONSUM~TIDN 691 CCF
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BIll INS SUHMARY-
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PR lOR BILL AMoUNT $0.PAYHENTS THRU 02/16/05 $0.BALANCE FORWARD $0.
CURRENT BILL CHARGES CONSUMPTION CHARGECUSTOMER CHARGE
SAFE DRINKING WTR FEEBOISE FRANCH ISE F~ETOTAL CURRENT CHARGES
TOTAL AMOUNT DUE
~678..23.
$O.lCi$21.$723.
*723.
you HAD NO CONSU"PTION RECORDED
FOR THE SAME PER IOD LAST YEAR.** WINTER RATEs ARE
IN EFFECT UNITt APRIL
30TH. AS COLD WEATHER
NFARS. BE SURE TO
WINTERIZE YOUR SPRINklER
SVST~". DISCONNECT
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02/16/05 i DORIAN/ENTERrAINMENT
06000998168747 72~. 49
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BOISE In 83704-6723
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EXHIBIT
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;;iil !)j(\l" Due j~uit'
02/16/051 03/08/2005
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