20060504Motion to Approve Stipulation.pdf

McDevitt & Miller LLP
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O. Box 2564-83701
Boise, Idaho 83702
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Chas. F. McDevitt
Dean 1. (Joe) Miller
May 10, 2006
Via Hand Delivery
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, Idaho 83720
Re: Case No. UWI-05-
Dear Ms. Jewell:
Enclosed for filing in the above matter please find the original and seven (7) copies of a
Motion To Approve Stipulation between United Water and the City of Meridian.
An additional copy of the document and this letter is included for return to me with your
file stamp thereon.
Very Truly Yours
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ORIGINAL
Dean J. Miller (ISE No. 1968)
MCDEVITT & MILLER LLP
420 West Bannock Street
O. BOX 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
ioe(ti),mcdevitt- miller .com
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INC., TO
AMEND AND REVISE CERTIFICATE OF
CONVENIENCE AND NECESSITY NO 143
MOTION TO APPROVE
STIPULATION
CASE NO. UWI-05-
COMES NOW United Water Idaho Inc.
, ("
United Water ) and moves the Commission
for an Order approving the Stipulation between United Water Idaho and the City of Meridian
Stipulation ) filed herein on May 2, 2006, and in support thereof respectfully shows as follows
to wit:
During the course ofthis proceeding, representatives of the City of Meridian ("City ) and
United Water met on several occasions to discuss their respective service territory boundaries in
the area encompassed by the original Application filed herein by United Water. The Stipulation
is the result of those arms-length, good faith discussions.
In arriving at the Stipulation, the parties took into account factors such as the location and
capacity of existing facilities of each party, and the capability of each party to serve expected
future growth in the areas. Also taken into account were the City s plans for future expansion of
its municipal boundaries.
MOTION TO APPROVE STIPULATION - 1
The Stipulation results in an allocation of territories that is fair and equitable to the
parties and insures that future residents of the areas will receive safe, reliable, and adequate
domestic water service.
WHEREFORE, United Water respectfully requests that the Stipulation be approved.
DATED this
\ '
day of May, 2006.
McDEVITT & MILLER LLP
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Dean J. Miller
Attorneys for United Water Idaho, Inc.
MOTION TO APPROVE STIPULATION - 2
CERTIFICATE OF SERVICE
I hereby certify that on the ~ay of May, 2006, I caused to be served by the methodes)
indicated below, a true and correct copy of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise ID 83720-0074
i i ewellCip,puc.state.id. us
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Charles L. Honsinger, Esq.
RINGERT CLARK CHARTERED
O. Box 2773
Boise ID 83702
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MOTION TO APPROVE STIPULATION - 3