20080505MSW to Corvino 1-6.pdf

RECEIVED
John R. Hammond, Jr., ISB Nõ. 5470
Fisher Pusch & Alderman LLP
U.S. Ban Plaza, 5th Floor
101 S. Capitol Boulevard, Suite 500
Post Office Box 1308
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
- 2 PM 4: ~ 6
iDAHO PUbLiC
UTILITIES COMMISSION
Attorneys for Applicant
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO SPRINGS
WATER COMPANY, INC., FOR A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY
CASE NO. ISW-W-08-01
IDAHO SPRINGS' RESPONSES TO
FIRST PRODUCTION REQUEST OF
GERALD J. CORVINO
IDAHO SPRINGS WATER COMPANY, INC. ("Idaho Springs), by and its attorney of
record, John R. Hammond, Jr.; responds to the First Production Request of the Commission Staff
as follows:
Request No.1: Please provide a list of beneficial owners ofIdaho Springs Water
Company, Inc., Arbor Ridge, LLC, Intermountain Sewer and Water, Inc. and Powder River
Development, Inc. by name and percentage owned.
Response: The response to this request wil be made as soon as the ownership
information if provided to counsel for the Company.
Request No.2: When did the Company first charge and collect a water
connection fee for the Arrowrock Ranch subdivision? Please provide a detailed
description of the transaction (e.g., date biled or contracted, payer, payee, amount, etc.)
including copies of the contract or sales agreement.
IDAHO SPRIGS' RESPONSES TO FIRST PRODUCTION REQUEST OF GERALD J. CORVINO - i
Responsè: At this time the Company has been unable to determine when the
exact date of the first connection was. The Company wil supplement the response to this
request when detailed records in this regard are locate.
Request No.3: When did the Company first contact the PUC regarding a
Certificate of Public Necessity and Convenience (CPCN)? What form did the contact
take (e.g., phone call, letter, meeting)? Who was involved from the Company and the
PUC? Please provide any documentation from that contact.
Response: The Company believes its first contacts with the Commission Staff in
early 2007. The Company will supplement the response to this request as soon as it
locates more details on the nature of these first contacts.
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 contact take
place? Please list all occurrences and provide any documentation.
Response: Although there had been previous discussions with the Commission
Staffno until January of2008 did it (not the PUC itself) demand that the Company fie an
application for a Certificate of Public Convenience and Necessity. This contact was
made in telephone calls between counsel for the Company and a Deputy Attorney
General who works at the Commission. Previous to this date the Company had
discussions with the Commission Staff concerning when an application for a certificate
would be filed. It is believed that these contacts were in early 2007 based on
correspondence between the Commission Staff and yourself.
Request No.5: Has the Company directly or through its agents ever waived or
offered to waive or pay in whole or in part the water connection fee or water service fees
IDAHO SPRIGS' RESPONSES TO FIRST PRODUCTION REQUEST OF GERALD J. CORVINO - 2
in consideration for the purchase of a lot or house? If so, which entity (e.g., Powder
River, Arbor Ridge) made the offer? What was the total value ofthe consideration? Is
this practice stil continuing? Please provide any documentation (e.g., real estate flyer)
available.
Response: The Company is not aware of any waiver in whole or in part.
Request No.6: For all employees identified in PUC First production Request No.2,
please provide the history of employment by the Company (i.e., Idaho Springs and
related companies as described above.)
Response: There are no employees.
DATED THIS ~ day of May, 2008.
IDAHO SPRINGS WATER COMPANY, INC.
.-1By:
IDAHO SPRINGS' RESPONSES TO FIRST PRODUCTION REQUEST OF GERALD J. CORVINO - 3
.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this ~ day of May, 2008, a true and correct
copy of the foregoing document was served on the following individuals by the method
indicated below:
Jean Jewell
IDAHO PUBLIC UTILITIES COMMISSION
472 W. Washington St.
PO Box 83720
Boise ID 83720-5983
Don Howell
Krstine A. Sasser
Deputy Attorney General
IDAHO PUBLIC UTILITIES COMMISSION
PO Box 83720
Boise ID 83720-0074
Gerald J. Corvino
11865 W. Tustin Lake
Kuna ID 83634-5032
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IDAHO SPRINGS' RESPONSES TO FIRST PRODUCTION REQUEST OF GERALD 1. CORVINO - 4