20080421Corvino to MSW 1-6.pdf

Gerad J. Corvo
11865 West Tusti LN
Kuna, ID 83634
John R. Hamond
Fisher Pusch & Alderman, LLP
101 S. Capita Blvd, Suite 500
Boise, ID 83702
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UTn~\'riËS COMM1SSiü;
Re: Idaho Springs Water Company, IPUC Case No. ISW-W-08-01
Dear John,
Gerad J. Corvino, intervener, Idaho Public Utilities Commssion rate case No. ISW-W-
08-01, requests tht Idaho Sprigs Water Company, Inc. (Ida Sprigs) provide the
followig inormation as soon as possible but no later than May 2, 2008.
"Company" in the followig questions refers to Idaho Sprigs Water Company and its
predecessors (Arbor Ridge, LLC) and related companes (Intermounta Water and
Sewer, Inc., Powder River Development, Inc). "PUC" in the followig questions refers to
the Public Utilities Commission, its st and contrtors.
Ths production request is considered to be contiuig and Idaho Sprigs is reuested to
provide additional inormation or documents that it may later obta tht will augment the
documents produced.
Request No.1: Please provide a list of beneficial owners of Idaho Sprigs Water
Company, Inc., Arbor Ridge, LLC, Intermounta Sewer and Water, Inc. and Powder
River Development, Inc. by nae and percentage owned.
Request No.2: When did the Company first chage and collect a water connection fee
for the Arowrock Rach subdivision? Please provide a detaled description of the
transaction (e.g., date biled or contracted, payer, payee, amount, etc.) including
copies of the contract or sales agrement.
Request NO.3: When did the Company fit contat the PUC regardig a Certificate
of Public Necessity and Convenience (CPCN)? What form did the contact tae (e.g.,
phone call, letter, meeting)? Who was involved from the Company and the PUC?
Please provide any documentation frm tht contact.
Request NO.4: Did the PUC ever demand or request the Company apply for a CPCN?
Who was involved from the Company and PUC? When did the contat tae place?
Please list all occurences and provide any documentation.
Request NO.5: Has the Company diectly or though its agents ever waived or offered
to waive or pay in whole or in par the water connection fee or water service fees in
considertion for the purchase of a lot or house? If so, which entity (e.g., Powder
Production Request
To Idaho Springs
1 April 16, 2008
Gerad J. Corvo
11865 West Tusti LN
Kun il 83634
River, Arbor Ridge) made the offer? What was the tota value of the consideration? Is
this practice stil continuig? Please provide any documentation (e.g., real estate
flyer) available.
Request NO.6: For all employees identified in PUC Firt production Request No.2,
please provide the history of employment by the Company (i.e., Idao Sprigs and
related companes as described above.)
Sincerely,.YJ~~
Gerad J. Corvo
Cc: Krstine Sasser, Deputy Attorney General, IPUC
Production Request
To Idaho Sprigs
2 April 16, 2008