20051214Response to motion to approve.pdf

RINGERT
+CLARKCHARTEREDLA WYERS
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Laura E. Burri
Jeffrey R. Christenson
David P. Claiborne
D. Blair Clark
S. Bryce Farris
Jon C. Gould
David Hammerquisl
Charles L. Honsinger
James P. Kaufman
Jennifer Reid Mahoney
James G. Reid
Daniel V. Steenson
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TO:IDAHO PUBLIC UTILITIES COMMISSION William F. Ringer!, of Counsel
Allyn L. Sweeney of Counsel
Samuel Kaufman (1921.1986)
FROM:CHARLES L. HONSINGER DATE:DECEMBER 13, 2005
RE:IN THE MATTER OF THE APPLICATION OF UNITED WATER IDAHO
INc.TO AMEND AND REVISE ITS CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY NO. 143
1. Original and 8 copies of Response to Motion to Approve Uncontested Expansions
FOR YOUR INFORMATION /--- FILE ORIGINAL & CONFORM COpy
FOR YOUR FILE PLEASE REPLY FOR MY SIGNATURE
PLEASE FILE PLEASE ANSWER AND SEND COpy OF
LETTER TO' ME
IN ACCORDANCE WITH
YOUR REQUEST
PLEASE RECORD AND RETURN
PLEASE COMMENT RUSH
PLEASE SIGN AND RETURN AS PER OUR PHONE CONVERSATION
PLEASE TELEPHONE/SEE ME PLEASE REVIEW
DISCUSS
AND CALL TO
REMARKS: Please file the above-referenced document, conform the enclosed copy and return
it in the enclosed pre-paid envelope. Thank you, Kimi.
455 South Third Street. P.O, Box 2773 . Boise, Idaho 83701 . 208/342-4591 FAX [phone]
LCE \fED
CHARLES L. HONSINGER (ISB #5240)
RINGERT CLARK CHARTERED
O. Box 2773
Boise, ID 83702
[phone]
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Attorneys for Protestant
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. UWI-05-
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INc., TO
AMEND AND REVISE ITS CERTIFICATE
OF PUBLIC CONVENIENCE AND
NECESSITY NO. 143
RESPONSE TO MOTION TO
APPROVE UNCONTESTED
EXPANSIONS
COMES NOW, the City of Meridian, by and through its counsel, Ringert Clark, Chartered
and hereby responds to the Motion to Approve Uncontested Expansions filed by United Water Idaho
Inc. on December 7, 2005.
The City of Meridian agrees with United Water Idaho, Inc. that it is appropriate for
the Commission to enter an order approving amendments to United Water
certificate of public convenience and necessity.
The parties are negotiating over certain areas requested by United Water to be
included in its certificate of public convenience and necessity.
The areas that are not contested, or that are not part of the negotiation process are the
following:
A. Hidden Springs/Cartwright Ranch
RESPONSE TO MOTION TO APPROVE UNCONTESTED EXPANSIONS - Page 1
B. Lexington Meadows Subdivision
The City of Meridian agrees that the above-referenced areas can be included in
United Water s certificate of public convenience and necessity, but that the other
areas should not, at this time , be so included.
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Dated this I~-day of December, 2005.
RINGERT CLARK, CHARTERED
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By: Charles L. Honsinger, Attorneys for City of
Meridian
CERTIFICATE OF SERVICE
I certify that on the 11 ay of December, 2005, I served copies of this document
including all attachments by U.S. Mail to the following:
Commission Secretary
Idaho Pubic Utilities Commission
O. Box 83720
Boise, ID 83720-0074
Dean J. Miller, Esq.
McDevitt & Miller LLP
O. Box 2564
Boise, ID 83701
Gregory P. Wyatt
United Water Idaho Inc.
O. Box 190420
Boise, ID 83719-0420
a!~ 24L----
Charles L. Honsinger
RESPONSE TO MOTION TO APPROVE UNCONTESTED EXPANSIONS - Page 2