20080902City of Nampa Reply Comments.pdf

ORIGINAL
RE.CE\VEO
Terrnce R. Whte (ISB No. 1351). . ow 3i33
WHTE PETERSON 881- SEP -Z r n
5700 E. Frain Rd., Ste. 200 ..0 PUßUC
Nampa ID 83687 . u'R~s COMM1SS\ONT: [phone] UTi
F: [phone]
trw(!whitepeterson.com
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE APPLICATION Case No. UW-W-08-02
OF UNITED WATER IDAHO INC., FOR AN
AMNDMENT TO ITS CERTIFICATE OF REPLYCOMMNTS
PUBLIC CONVENIENCE AN NECESSITY
NO. 143 AND FOR AN ACCOUNTING
ORDER.
COMES NOW the City of Nampa, Idao and replies to the Comments of the
Commssion Sta ("Sta Comments") dated Augut 8, 2008, as follows, to wit:
The City of Nampa appreciates the Idao Public Utilities Commission's (lPUC) prompt
review of the Unite Water, Inc., application. The acquisition of United Water's resources by
the City of Nampa will provide substatial benefit to the acquied customers and the City of
Nampa Wate System. The followig is a response to the questions/concern posed by the IPUC
sta and Mr. Don Lyn as requested.
IPUC STAFF COMMNTS
"Sta recommends tht these customer be allowed to reai at existing United Water
irgation rates for a fied period of the to five years or until the system is interconnecte with
or anexed into the City." (page 8)
It is the City of Nampa's intention to interconnect the Coventr System with the City's
system withn 30 days of IPUC's approval of the City of Nampa and United Wate purhae
REPLY COMMNTS - i
agreement. Nampa can assur ths action because, 1) The interconnection design is complete, 2)
The City of Nampa has sufcient piping materals to complete the project, 3) City forces will
complete the interconnection constrction activity and, 4) The City of Nampa has ongoing
contrcts with asphat contrto to complete the paving repair. Given ths expected
interconnection tie frame, the City of Nampa does not believe a rate frze is appropriate or
necessar for the Coventr system.
DON LYN COMMNTS
Mr. Lyn appear to have the followi thee mai conces:
. Uncerty over the interonnection tie frame for Belmont water
. Water Rates Repreentaion
. Anexaon Representation
INERCONNECTION TIME FRA
The Belmont Water System is acquied under a Consent Order from the Idaho
Deparent of Environmenta Quaity. The Consent Order tranfers with the sale of the system.
The order is very clea that the Belmont system must be interconnected with the City of Nampa
system by December 1,2009. The City of Nampa is on track to meet ths requiment.
WATER RATES REPRESENTATION
i. C. § 63-131 lA requis a public heag be held prior to imposing any new fee or for
any fee increase in excess of five percent (5%) of the amount of the fee last caculated.
I.C. § 63-1311A fuer provides the necesar notification requirements prior to the
public hearg and for fee incrases. Furerore, any incree in rates or chaes must be
approved by the Nampa City CounciL.
REPLY COMMENTS - 2
Public Heargs and Nampa City Council meetigs are open to the genera public.
Therefore, all customers not just those withi the City limts, have an opportty for input prior
to fi rate decisions.
ANXATION REPRESENTATION
i.C. § 50-222, provides the City's anexation authority and procedur reuiements. I.C.
§ 50-222(5) includes provision for public heargs and notification requiements.
Therefore, propert owners have an opportty to present their cas before the City
Council prior to anexaton.
The City of Nampa appreciates the opportty to provide reply comments and looks
forwd to the Commssion's favorable Order.
DATED ths ~ day of September, 2008.
WHTE PETERSON
Terrnce e
Attorneys for the City of Nampa
REPLY COMMENTS - 3
"
CERTIICATE OF SERVICE
I hereby certfy tht on the ~ day of September, 2008, I caused to be served, via the
metodes) indicated below, tre and corrct copies of the foregoing document, upon:
Jean Jewell, Secreta Hand Delivered ~l.
Idaho Public Utilties Commission U.S. Mail ~l.
472 West Washigton Stret Fax ~l.
P.O. Box 83720 Fed. Express ~~Boise, ID 83720-0074 Emai
j j ewell(ßpuc.state.id. us
Scott Woodbur Hand Delivered ~l.
Idaho Public Utilties Commssion U.S. Mail iJ
472 West Washington Street Fax ~l.
P.O. Box 83720 Fed. Express ~l.
Boise, ID 83720-0074 Email ~l.
Terrnce R. te
WHTE PETERSON
REPLY COMMENTS - 4