20070316Rhead affidavit.pdf

OR\G\NAL
Dean J. Miller (ISB No. 1968)
McDEVITT & MILLER LLP
420 West Bannock Street
O. BOX 2564-83701
Boise, Idaho 83702
Tel: [phone]
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Joe (g) 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
AFFIDAVIT OF SCOTT RHEAD
CASE NO. UWI-O7-
STATE OF IDAHO
:ss
County of Ada
Scott Rhead , being first sworn upon an oath deposes and says:
I am employed by United Water Idaho Inc.
, ("
United Water ) in the capacity of Director
of Engineering. I have been employed by United Water for 15 years. In my capacity as
Director of Engineering, I am responsible for the design and construction of United Water
integrated water production and delivery system. I am a licensed Professional Engineer in the
State of Idaho.
I make this Affidavit in response to certain statements contained in the Letter Comments
of the City of Eagle filed herein on February 23 2007 (Letter Comments).
The Letter Comments (Pg. 2) raise the question of whether United Water has adequate
source of supply and supporting water rights to serve the Lanewood Development. The primary
source of supply for the Lanewood Development will be the Redwood Creek Well, the location
AFFIDAVIT OF SCOTT RHEAD - 1
of which is depicted on the map attached hereto as Exhibit A. The Redwood Creek Well is
capable of producing 1 000 million gallons annually and has a peak pumping capacity of 2 100
gallons per minute. In the year 2006, the Redwood Creek Well had an annual production of
14.65 million gallons and a peak daily production of 317 gallons per minute.
Because the United Water production and distribution system is completely integrated
other adequate sources of supply are available in the event the Redwood Creek Well is
unavailable, due to maintenance or other reasons. For example, the 2.0 million gallon Hidden
Hollow Storage Reservoir provides operational peaking and fire protection to this area.
Based on the size of the proposed Lanewood Development, United Water estimates that
at build--out an additional 380 customers using alternate irrigation would be added to the United
Water system. For planning purposes United Water assumes, based on historical consumption
records for this type of user, peak day demand of 0.7 gallons per minute per customer. This
translates to an approximately 266 gallons per minute of additional peak demand (380 x 0.7). In
2006, the peak day pumping demand for the Redwood Creek Well was 317 gallons per minute.
The additional 266 gallons per minute of peak demand results in a total projected peak demand
of 583 gallons per minute. This demand is well below the well capacity and provides the
assurance that this and other developments can be served without jeopardizing service to current
customers.
The Redwood Creek Well produces water for the United Water System under two water
rights , Permit 63-11878 and 63-12194, which have a combined peak diversion rate of 2 068
gallons per minute and an annual volume of 1 086 million gallons.
AFFIDAVIT OF SCOTT RHEAD - 2
Based on the foregoing, it is my professional opinion that United Water has adequate
source of supply supported by adequate water rights to provide safe, reliable and continuous
service to the Lanewood Development.
The Letter Comments (Pg. 2) call into question the time frame for development requested
by the Lanewood developer. Based on information provided by the developer, United Water
understands the developer desires to commence construction of the water distribution system
within the development in July of 2007. As depicted on Exhibit A, attached hereto, United
Water s existing 12" main line facilities are along Linder Road, which is immediately adjacent to
the eastern boundary of the Lanewood development. Connection of the Lanewood development
to this 12' mainline will not require construction of any off-site mainline extensions. Also as
depicted on Exhibit A, the Lanewood development is contiguous to United Water s existing
service territory and to United Water s existing, integrated water delivery system.
Based on the foregoing it is my professional opinion that United Water has both
available source of supply and available transmission facilities to immediately provide safe
continuous and reliable service to the Lanewood development.
United Water Idaho Operations Inc., an affiliate of United Water Idaho, has a contractual
agreement with the City of Eagle to provide operation and maintenance services to the City with
respect to its municipal water system. As a consequence, I am familiar with the design and
operation of the City s municipal water system.
The City has one operational well, known as the Lexington Well, and one well under
construction known as the Brookwood Well. These wells are located at the eastern edge of the
Eagle system, and are approximately two and one half (2 Y2) miles from the Lanewood
Development. Serving the Lanewood Development from the Lexington or Brookwood Wells
AFFIDAVIT OF SCOTT RHEAD - 3
would require construction of two and one half (2 Y2) miles of transmission mainline along
Floating Feather Road.
In 2006, the City drilled two test wells in an area approximately one qumier and one half
miles south of the Lanewood Development. The location of these test wells is depicted on
Exhibit A, attached hereto. While the City has applied to the Idaho Department of Water
Resources (IDWR) for water right permits, the City s Application is still pending before the
IDWR and no water right permits have been issued.
Before a well may be placed in service to provide service to a public drinking water
system, approvals are required from the Idaho Depatiment of Environmental Quality (DEQ). The
DEQ cannot issue its approvals until a water right permit has been issued by IDWR. The DEQ
has not issued approvals required to place either of the two weBs into service.
10.Assuming that IDWR and DEQ approvals are eventually obtained and that either of the
test wells are up-graded to municipal standards, it would be necessary to construct main line
facilities to connect the welles) to the Lanewood Development. Construction of required
mainline facilities has not been commenced.
11.I am over the age of 21 years and make this Affidavit of my own knowledge.
Dated this day of March, 2007.
c;:-
..-
Scott Rhead P .
SUBSCRIBED AND SWORN to before me this
J4!ky of Mat', 2007.
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Notal Pub for IDAHO
Residing at
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Commission Exp./:J- ofi
CERTIFICATE OF SERVICE
I hereby certify that on the Jki'kay of March, 2007 , I caused to be served, via the
methodes) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
jiewell (g)puc,state.id.
Bruce M. Smith
MOORE SMITH BUXTON & TURCKE
225 N. 9th Street, Suite 420
Boise, ID 83702
AFFIDAVIT OF SCOTT RHEAD - 5
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McDEvrrr& MILLER, LLP
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