200412171st Request of Staff to Bar Circle.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
BAR CIRCLE'S' RANCH, INC. FOR
AUTHORITY TO AMEND ITS CERTIFICATE
OF PUBLIC CONVENIENCE AND NECESSITY
NO. 296 AND EXPAND ITS CERTIFICATEDAREA OF SERVICE.
CASE NO. BCS-04-
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO BAR CIRCLE'S' RANCH,
INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, requests that Bar Circle S' Ranch , Inc. (Bar Circle;
Company) provide the following documents and information on or before MONDAY,
JANUARY 3, 2005.
This Production Request is to be considered as continuing, and Bar Circle is requested to
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO BAR CIRCLE'
DECEMBER 17, 2004
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
Reference IDAP A 31.01.01.228. For documents provided please include the name and phone
number of the person preparing the document, and the name, location and phone number of the
record holder.
For all responses to the following requests, please provide all workpapers, diskettes
(3.5 in.) and all underlying formulas in Excel (version 5) language.
Request No.1: Please provide a map of suitable scale showing the location of the
construction or expansion and it's relation to other public utilities, corporations, or persons with
whom the expanded utility is likely to compete and the location of public utilities in the area that
offer or provide similar utility service. Reference IDAP A 31.01.01.112.02 and .03.
Request No.2: Please provide a detailed estimate of the cost to the Company of the
construction or expansion and the effects of the construction or expansion on Bar Circle
revenue requirement. IDAP A 31.01.01.112.05.
Request No.3: Please provide any calculations, studies, or other documents that
demonstrate Bar Circle s ability to provide adequate supply, storage and water rights to serve the
requested service area expansion. If the Company does not have adequate facilities to provide
service to the requested area, please indicate how additional supply, storage or water rights will
be acquired to serve the additional customer base.
Respectfully submitted this /7 day of December 2004.
Technical Staff: Michael Fuss
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FIRST PRODUCTION REQUEST
TO BAR CIRCLE'
DECEMBER 17 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF DECEMBER 2004
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO BAR CIRCLE S' RANCH, INC., IN CASE NO.
BCS-04-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE
FOLLOWING:
ROBERT TURNIPSEED
PRESIDENT
BAR CIRCLE'S' RANCH INC
PO BOX 1870
HAYDEN ID 83835
SECRET
CERTIFICATE OF SERVICE