20070518Rhead rebuttal.pdf

Dean J. Miller (ISB No. 1968)
MCDEVITT & MILLER LLP
420 West Bannock Street
O. BOX 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
Joe ~ mcdevitt-miller .com
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j ill f! :,; ISSii
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
CASE NO. UWI-O7-
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
REBUTTAL TESTIMONY OF SCOTT RHEAD
May 18 2007
Please state your name.
Scott Rhead
Are you the same Scott Rhead who previously filed Direct Testimony in this
proceeding?
Yes, I am.
What is the purpose of your Rebuttal Testimony?
I will respond to certain statements contained in the Amended Direct Testimony
of Vem Brewer filed on behalf of the City of Eagle.
Do you have a general observation regarding Mr. Brewer s testimony?
Yes. In my Direct Testimony, I provided a detailed explanation of United
Water s ability to serve the Lanewood development. In his Amended Direct
Testimony, Mr. Brewer does not dispute any part of my Direct Testimony
regarding United Water s ability to serve the development. Because my testimony
is not challenged, I take it that the City does not dispute United Water s ability to
serve.
On page 2 of his testimony Mr. Brewer discusses various water facilities
including wells , which have been or are being constructed as a part of a City
water system. Does the City have ground water rights or permits from the Idaho
Department of Water Resources (IDWR) for any of the wells to which Mr.
Brewer refers?
No. IDWR has issued no approvals of pending water rights associated with these
well facilities.
Rhead, Re
United Water Idaho Inc.
At page 3 Mr. Brewer also refers to the City having "received a favorable staff
recommendation" and that he "expects the applications to be approved in the
June-July period." Are you aware of any recent favorable staff recommendations
regarding the City s applications with IDWR in this matter?
No. I have reviewed the public record in the City s IDWR water right application
proceeding. There is an internal IDWR Staff memo dated February 27 2007 that
concludes that the data lacking from the application in November 2006 has now
been provided. However, six (6) Protestants in the proceeding have filed
Technical Comments on April 25 , 2007 disputing the Staff analysis , stating in
part
, "
The City of Eagle s Addendum does not provide more and/or better
information that the Hearing Officer can use to evaluate whether the proposed
water rights will injure other water rights . The Protestant's Technical Comments
are attached as Exhibit 4
What will be the next steps in the IDWR water right permit approval process for
Eagle?
That is difficult to say with certainty, and it is equally difficult to say with
certainty, as Mr. Brewer has, that the application can be expected to be approved
in the June-July period.
Why is that the case?
The City s application for the water rights permits is currently in the hands of the
hearing officer awaiting his written decision and determination. Even if the
hearing officer was to deliver a decision favorable to the City in June or July, the
Protestants in the proceeding, and there are many, would have approximately two
Rhead, Re
United Water Idaho Inc.
weeks to request that the matter be reconsidered. With the large number of
Protestants this is a potential outcome. A reconsideration process could take
another several months. If the City prevailed at that stage, one or more
Protestants could still appeal the decision to the Director of the IDWR, and after
that process was completed, a Protestant could, if they chose, appeal the decision
to District Court. All of this uncertainty and the significant amount of time the
appeal processes could take makes it not only unlikely that Eagle will receive its
approved water rights permits in the June-July period, but nearly impossible.
You have mentioned Protestants in Eagles water rights permits application
proceeding, and at page 3 of his testimony Mr. Brewer states
, "
... part of the delay
in getting the applications approved was caused by United Water protesting the
applications." Is this a fair characterization of the delay?
Absolutely not. It is true that United Water protested Eagle s water rights
application because United Water owns and operates its Redwood Creek Well
less than one mile east of the proposed new wells. United Water was concerned
that the new diversions could injure the rights of Redwood Creek In addition
United Water believed that Eagle s requested diversion of almost 9 cubic feet per
second (cfs) was not based on any approved Master Plan or justification related to
future demands. So United Water had very legitimate reasons for protesting
Eagle s applications. It is not uncommon for water right permit applications to
experience significant delay when even one protestant enters the process.
How many other Protestants were there other than United Water?
Rhead, Re
United Water Idaho Inc.
The following is a list of Protestants still active in the Eagle permit application
and the IDWRprocess as of May 17 2007:
REPRESENTED BY CHARLES HONSINGER:
DANA & VIKI PURDY
5926 FLOATING FEATHER
EAGLE ID 83616
286-9701
JOSEPH & LYNN MOYLE
C/O MICHAEL MOYLE
480 N PLUMMER RD
STAR ID 83669
870-6667
EUGENE MULLER
320 N PALMER LN
EAGLE ID 83616
286- 7369
CHARLES MEISSNER JR
3101 N PALMER
EAGLE ID 83616
866-8688
CHARLES HOWARTH
C/O GUNNER & MATT HOWARTH
833 NPALMER
EAGLE ID 83616
286-9760
MIKE DIXON PRES
HOOT NANNEY FARMS INC
C/O TERRY WHITE
RT 1 2650 WING RD
STAR ID 83669
INDIVIDUAL PARTIES:
JERRY & MARY TAYLOR
3410 HARTLEY
EAGLE ID 83616
286- 7575
Rhead, Re
United Water Idaho Inc.
CORRIN & TERRY HUTTON
10820 NEW HOPE RD
STAR ID 83669
286-7752
SAM & KARl ROSTI
1460 N POLLARD LN
STAR ID 83669
286- 7685
Fax: [phone]
LEEROY & BILLIE MELLIES
6860 W ST ATE ST
EAGLE ID 83616
286- 7257
DEAN & JAN COMBE
6440 W BEACON LIGHT
EAGLE ID 83616
286- 7174
What has become of United Water s protest?
As a result of the new well tests and associated test pumping United Water
confirmed that Redwood Creek would not likely be affected beyond acceptance
limits. United Water s protest in this matter was withdrawn early in the hearing
process in December 2006.
At page 4 of Mr. Brewer s testimony he refers to a planned 16" main that will run
through the Lanewood development to connect and loop other portions of the
City s planned system. At page 6 Mr. Brewer implies that service by United
Water would hinder the City in implementing its Master Water Plan. Does water
service by United Water to the Lanewood development obstruct or impede
Eagle s ability to complete its anticipated 16" water main?
Rhead, Re
United Water Idaho Inc.
No. Ada County Highway District (ACHD) has existing rights-of-way along
Floating Feather Road and Lanewood Drive in the area of Eagle s concern. The
proposed development keeps these rights-of-way intact in the development plan.
ACHD anticipates a slight realignment for a portion of Floating Feather at the
southwest end of Lanewood but will maintain the necessary corridors. The City
will not be obstructed or impeded in its ability to construct its mainline because
water service is provided to Lanewood by United Water. In fact, Eagle
construction of its proposed main line will result in an unnecessary duplication of
water service assets since United Water currently has adequate water supply and
transmission capacity to serve Lanewood and surrounding areas. The Lanewood
development is contiguous to United Water s existing certificate boundary and
constitutes only a small extension of that boundary.
At page 4 Mr. Brewer says the City provides water less expensively than United
Water. Do you agree?
Not necessarily. It is true that currently the City s tariff rate for water service is
somewhat less than United Water s. The City s current rates , however, may not
include recovery of the costs associated with the City s ambitious plan to build a
municipal water system. These costs are unknown but potentially huge. Whether
those costs are eventually recovered through consumption rates, connection fees
surcharges , or some other mechanism, they will create upward pressure on the
City s overall cost of service.
Rhead, Re
United Water Idaho Inc.
At page 5 of Mr. Brewer s testimony he claims that the City of Eagle encourages
conservation of water by requiring the use of surface water for irrigation. Please
comment.
Requiring the use of surface water for irrigation can not be equated to
encouraging conservation for several reasons. First of all, the use of surface water
for irrigation, where available, is required both by Idaho state law and Ada
County ordinance. Thus , Eagle can make no "conservation" claim for requiring
what the law already requires. Secondly, in many cases, using un-metered, less
expensive irrigation water may lead to greater use; not less use of the overall
water resource. It is true irrigation is a different type of water (i.e. not treated to
potable standards) but this in itself is not conservation. Finally, the City of Eagle
historically has not provided its existing water customers with any conservation
education or information, water saver kits, or other conservation programs
typically offered by water providers. In contrast, United Water has had an active
and varied conservation program in place for many years. In addition, United
Water has recently completed and the Commission has recently approved in part a
detailed revised Water Conservation Plan.
At page 5 of his testimony Mr. Brewer seems to contradict your Direct Testimony
and states that the City s wells are constructed to Idaho Department of
Environmental Quality (IDEQ) standards.
Mr. Brewer may be correct that the wells are "constructed" to IDEQ standards
however, they are currently classified with IDEQ and IDWR merely as test wells.
Rhead, Re
United Water Idaho Inc.
Even if these two test wells are constructed to IDEQ standards can they be used to
provide municipal water supply without an associated water right permit?
No. IDEQ is very clear in this regard. The City has been allowed to construct
these wells to municipal standards but they are considered as test wells only and
cannot provide public water service without a water right permit. This
requirement can be found in IDAPA 58.01.08 503 19c approved March 30, 2007.
As I have testified above, the permitting process may require considerable more
time.
Mr. Brewer, at page 6 of his testimony, suggests that if United Water serves
Lanewood, the City will forgo revenue from those customers that could partially
off-set costs of constructing the new trunk line network and storage facilities. Is
this a legitimate concern?
I believe what this indicates is that the City s intended water system in the area is
very much in its infancy. It does not yet have approved water rights permits for
its wells; it does not yet have an integrated transmission and distribution system;
it does not yet have storage capacity for fire protection. In contrast, United
Water s system in the area is currently fully integrated with adequate supply
redundancy. As Mr. Brewer implies, the costs of constructing such new facilities
are significant and would duplicate United Water s facilities already constructed
to provide service in the area.
Does this conclude your testimony?
Yes it does
Rhead, Re
United Water Idaho Inc.
CERTIFICATE OF SERVICE
I hereby certify that on the ~day of May, 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
ii ewellrillpuc.state.id. us
Bruce Smith
MOORE, SMITH, BUXTON & TURCKE
950 W. Bannock, Suite 520
Boise, ID 83702-5716
Robert B. Burns
MOFF A TT THOMAS
101 S. Capitol Blvd. 10th Floor
O. Box 829
Boise, ID 83701-0829
REPLY COMMENTS-
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BY.
CHARLES L, HONSINGER (ISB #5240)
DANIEL V. STEENSON (lSB #4332)
RINGERT ClARK CHARTERED
455S. Third Street, P.O. Box 455
Boise, Idaho 83701-2773
Telephone: [phone]
Facsimile: [phone]
RECEIVED
APR 2 ~ 2007
DEPARTMENTOF
WATERRF~nIIRr.E1='
Attorneys for Protestants Joseph, Lynn and Michael Moyle
Eugene Muller. Dana and Viki Purdy, Charles W" Meissner; Jr.,
Charles Howalth and Mike Dixon!Hoot Nanney Fanns, Inc.
BEFORE THE IDAHO DBP AR'IMENT OF WATER RESOURCES
OF THE STA1E OF IDAHO
IN THE- MATTER OF APPLICATIONS TO,
APPROPRIATE WATER RIGHT NOS. 63-
32089 AND 63-32090 IN THE NAME OF THE CITY OF EAGLE
PROTESTANTS' TEC~CAL
COMMENTS REGARDING ADDENDUM
TO CITY OF EAGLE'S 7-DAY AQUIFER
TEST REPORT ANDIDWR'S STAFF
MEMORANDUM
COMBS NOW, Protestants Joseph, Lynn and Michael Moyle, Eugene Mullel, Dana and Viki
PUIdy, Charles W. Meissner, Jr", Charles Howarth, and Mike DixonlHoot Nanney FaTIns, Inc. by
and through their counsel of record Ringert Clalk, ChaItered, and, pursuant to the Healing OfficeI' s
March 27 2007 Notice olConsideration of Additional Evidence and Post Hearing Order hereby
submit technical comments regarding the Addendum to the City of Eagle s 7-Day Aquifer Test
Report and IDWR's Febma:ry 27 2007 Stafj'Memorandum reviewing the same,
PROTESTANTS' TECHNICAL COMMENTS REGARDING ADDENDUM TO CITY OF
EAGLE'S 7-DA Y AQUIFER TEST REPORT AND IDWR'S STAFF MEMORANDUM -
Page 1
Exhibit No.
Case No. UWI-O7-Scott Rhead, Engineer
Pa~e 1 of8
. . -- :'
INTRODUCTION
After the December, 2006 hearing 1evealed seven: deficiencies in its Day Aquifer Test
Repor't fo.,. Water Right Appropriation 63-32089 and 63-32090 the City of Eagle met with IDWR
personnel in an effort to flesh out its Report and address the concems raised at hearing.. On Februmy
, 2007, IDWR hydrogeologists authored a memO1'andum reviewing the February 22, 2007
Addendum to City oj'Eagle 7-Day Aquifer Test Report ("Addendum
).
Both the Cityof'Eagle
Addendum and the IDWR StaffMemorandll1n ("Memorandum were provided to the parties by the
end of March, 2007, The patties were then given until April 25, 2007 to submit "technical
comments" about both documents pursuant to the Hearing Officer s March 27, 2007 Notice and
Order.
Despite its attempt to better address concexns regarding its previous report, the City of
Eagle sAddendum does not provide mole and/or better information that the Healing Officer can use
to evaluate whether the proposed water rights will injure othe1 water rights, Rather, the Addendum
to address many of the same concerns raised at hearing, including the failure to analyze or explain
data bearing upon the issue of ~jUIY to existing water rights..
COMMENTS
One of the primary issues in this litigation is whether and to what extent the water rights
proposed by the City of Eagle will injure other water rights, including those of the protestants.
the December healing in this matter, it was apparent that the City had not sufficiently demonstrated
through its analysis that the proposed appropriation would not cause injury. As a result oUhe events
at the hearing, the City conducted another round of analysis culminating in theAddendlim.
PROTESTANTS' TECHNICAL COMMENTS REGARDJNG ADDENDUM TO CITY OF
EAGLE'S 7-DA Y AQUIFER TEST REPORT AND IDWR'S STAFF MEMORANDUM ~
Page 2
Exhibit No.
Case No, UWI-O7-Scott Rhead, Engineer
Page 2 of 8
'0,
" ." "
Graph Showing Groundwater Withdrawals
Figure 10 of the Addendum ( p. 30) is not cuuent. Data through 2006 would have been
helpful to determine whether groundwater withdrawals are continuing to increase oj' have instead
stabilized.. Ifgzoundwaterwithdrawals have continued the incn~asjngtIend shown from 1993 to 2001
in Figure 10, then the appropriation proposed by the City combined with aU otherwithdrawals could
very well result in injury to existing water rights. Figure 10 should have been updated with recent
data so that the Hearing Officer could make an infoIDled decision.. Without such information, no
informed decision can or should be made.
2. "Meaningful Drawdown
The discharge rate during the aquifer test (and that which was used in drawdown-analysis
calculations) was 1,580 gpm. Addendum p. 8. The Addendum states that the "maximum diversion
rate requested under Application 63-32089 (in which the Eaglefield well is listed as a point of
diversion) would be limited to 4,0 cis (1,795 gpm).. Jd. Apparently, the wen had a potential
capacity of 2 000 gpm~ Id" Why then was the well pumped at a lower rate than either the proposed
diversion rate or the weIrs capaci~? It seems difficult to make the City s conclusion, based upon
the data in evidence, that "it is unlikely that a higher pumping rate would have provided meaningful
drawdown data in wells that showed no drawdown at the 1580 g..p.m. rate.ld (bolded emphasis
added). We do not know what is meant by the telm '"meaningful dIawdown data," We do not know
the basis of the Addendum author s opinion that the discharge rate used (1,580 gpm) was sufficient.
In fact, every well monitored showed drawdown during the pumping portion of the test. The
authors have concluded that in some wells the amount of drawdown was meaningless. Pumping at
PRaTES T ANTS' TECHNICAL CONIMENTS REGARDING ADDENDUM TO CITY OF
EAGLE'S 7-DA Y AQUIFER TEST REPORT AND IDWR'S STAFF MEMORANpUM-
Page 3
Exlribit No.
Case No. UWI-O7-Scott Rhead, Engineer
PaJ!;e3 of 8
, ,.. '. ,: .
a higher rate would have established if the minot drawdown was related to pumping or to other
factors. One pmpose of an ~quifer test is to stress the interconnected aquifers, This test did not
accomplish that putpose.
Ricks Well
The City states that "( w Jater levels duIing the measurement period declined apPIOximately
1 foot, although it is not clear that the decline was caused by the aquifer test." Addendum, P, 10.
Although the City explains that this decline was "most possibly caused by other, nearby wells , it
does not provide the data to back up its conclusion, In fact,the City has never explained the water
level change in the Ricks Well.. It has simply failed to analyze the data that show rapid drawdown
in the Ricks Well near the end of the pumping test without recovery - a situation that certainly
wauants further analysis, data and explanation. One question that arises is what will happen to
water levels in the Ricks Well when pumping lasts longer than one week? Will the dtawdown
continue? W:il1 thele ever be a recovety of drawdown levels? Certainly more analysis and data
gathering was wananted '
4. Lack of response to pumping in the Ricks and QRC No.4 Wells
In their Conclusions and Recommendations, the Addendum authors state that Ricks and
QRC No.4 wells' lack of response to pumping is "likely because of an insufficient hydraulic
connection,Addendum p. 17. However, the premise for the conclusion that there is an
insufficient hydraulic connection" cannot be that there was no response to pumping., In fact, there
was a response to pumping. Both wells showed a steady drawdown, the rate of which increased neal
the end of pumping period and then continued to drop after pumping had stopped. At a bare
PROTESTANTS' TECHNICAL COMMENTS REGARDING ADDENDUM TO CIIY OF
EAGLE'S 7-DA Y AQUIFER TEST REPORT AND IDWR'S STAFF MEMORANDUM.
Page 4
Exhibit No.
Case No.UWI-O7-Scott Rhead, Engineer
Page 4 of8
minimum, the Applicant should have determined the cause of this decline in water levels; should
have determined what would happen when pumping occurs on a continual. basis; and should have
determined the reason fO1 the wells' failure to fully recover aftel pumping had ceased"
Wells Did Not Fully Recover
TheAddendum concludes that "w)ater levels fully recovered in the pumping and monitoring
wells from drawdown associated with the aquifer test." Addendum p. 18- This conclusion is
erroneous. The data establishes that QCR No.4, Ricks Well, StIata We111B, and UWI WelllB did
not fully recover. See Addendum, Appendices C.5, C., C7, CS, CIO. Only three wells fully
recovered fiom drawdown and one well showed a very slight drawdown which was probably too
small to be significant. Thus, less than 50% of the wells that were monitored fully recovered from
drawdowns associated with the aquifer test - in direct contradiction to the Addendum 5 conclusion.
Well Interference Event(s)"
Individual Water Level Elevation graphs for each well attached to the Addendum show
event on June 10 identified as "well interference event (see r able 1)"Addendum Appendices C.3,
4, CoS, etc. Although Table 1 is referenced on the graphs, neither it nOl any other pall of the
Addendum or the DayAquifer Te5tIeport address this weUinteIfel'ence event The event or events
stopped recovelY from June 10 until June 1311\ in the pumping well, Legacy well, QCR4, and Strata
lB well. The Water Level Elevation gtaph for Strata 1A well did not show significant drawdown
so impact from the "wen interference event(s)" was not noticeable in that well.
The Water Level Elevation graphS for UWI wells lA and IB didn't show any impact on
recovery on June 10, but an event prevented drawdown recovelY in those wells from about June 12'h
PROTESTANTS' TECHNICAL COMMENTS REGARDING ADDENDUM TO CITY OF
EAGLE'S 7-DAY AQUIFER TEST REPORT AND IDWR'S STAFF MEMORANDUM
Page 5
Exlu"bit No.
Case No. UWI-O7-
Scott Rhead, Engineer
Page 5 of8
to about June 13th.. This well inteIfel'ence event was not discussed in either the Addendum or the 7-
Day Aquifer Test report, but the data demonstrates that combined pumping impacts can prevent
recovery.. The cumulative effect of all pumping from existing wells togethel with pumpingfiom the
wells proposed by the City may result in significant drawdowns to area wells, including those owned
by the plotestants. Neithel theAddendum not the DayAquifer Test repOI t address the issue of the
cumulative impacts on water levels if this application is approved - celtainly, given the data showing
the possibility that cumulative pumping effects may prevent drawdown lecovelY, further analysis and
data gatheling is and was wauanted.
Summary
The deficiencies of the aquifer test and the Day Aquifer Test 16pOIt and Addendum
generated therefrom can be summaIized as follows:
Test pumping lasted only seven days - an insufficient period of time to detelmine
long-telm effects both to the aquifer and to individual wells.
The pumping rate of 580 gpm did not stress the aquifer sufficiently to be able to
determine the impact of the plOposed higher pumping Iates on both the aquifer and
individual wells,
c.,On1y six or seven wells were monitored dming the pumping test instead of a number
more appropIiate to determining the impacts of this very significant proposed water
right on the aquifer and individual wells in the area.,
Sunounding well owners were not given adequate notice to monitor their own wells
and detelmine the impacts of pumping upon them.
PROTESTANTS' TECHNICAL COMMENTS REGARDING ADDENDUM TO CITY OF
EAGLE~S 7~DA Y AQUlFER TEST REPORT AND IDWR'S STAFF MEMORANDUM -
Page 6
Exhibit No.
Case No. UWI-O7-
Scott Rhead, Engineer
Page 6 or8
Significant effects such as well interference from sources other than the pumping of
the test well were not explained or analyzed. Such explanation and analysis is
necessary to determine the possible impacts of cumulative pumping from additional
area wells on the aquifer and on existing wells.
A monitoring program using dedicated monitoring wells completed in the same
aquifer zone as the pumping wells shomd be installed if the application is approved
to assist the parties in determining how the City's pumping impacts the aquifer and
to assist the parties in determining whether and to what extent existing wells are
injured by such pumping.
TheIe has simply not been sufficient data or analysis generated by the City in the Day
Aquifer Test report aIJdAddendum to warrant the approval ofthe City's applications.. Accordingly,
the Heming Officer should either deny the applications, or require the gathering of additional data
and additional analysis horn the City priOl to making any decision upon the applications..
Dated this 25th day of APIil, 2007
RIN
u;;:;:;
By: Charles L. Honsinger
PROTESTANTS' TECHNICAL COMMENTS REGARDING ADDENDUM TO CITY OF
EAGLE'S 7~DAY AQillFER TEST REPORT AND IDWR'S STAFF MEMORANDUM Page 7
Exhibit No.
Case No. UWI-O7-
Scott Rhead, Engineer
Page 7 of8
CERTIFICATE OF SERVICE
IHEREBY CERTIFY that on this 25lh day of Apri4 2007, the above and foregoing documen t
was seIved on the following by placing a copy ofthe same in the United States mail, postage prepaid
and propedy addressed to the folJowing:
Je.uy & Mary Taylor
3410 Hartley
Eagle. Idaho 83616
Corrin & Terry Hutton
10820 New Hope Road
Star, Idaho 83669
Sam & Kad Rosti
1460 N. Pollald Lane
Star. Idaho 83669
Westem Region
Attn: John WestIa
2735 AiIpO1t Way
Boise, Idaho 83705-5082
Leeroy & Billie Memes
6860 W. State Street
Eagle, Idaho 83616
Dean & Jan Combe
6440 W. Beacon Light
Eagle, Idaho 83616
Bluce Smith
Moore Smith Buxton & Tulke
225 N, 9th Street. Ste.420
Boise, Idaho 83702
.J ohn M. Marshall
Givens PuIsley
O. Box 2720
Boise, Idaho 83701~~1
PROTESTANTS' TECHNICAL COMMENTS REGARDING ADDENDUM TO CITY OF
EAGLE'S 7-DA Y AQUIFER TEST REPORT AND IDWR'S STAFF MEMORANDUM-
Page 8
Exhibit No.
Case No. UWI-O7-
Scott Rhead, Engineer
Page 8of 8