200406171st Request of Staff to Terra Grande.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO 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 INVESTIGATION
OF TERRA GRANDE WATER AND THE
ISSUANCE OF RELATED CERTIFICATE
PUBLIC CONVENIENCE AND NECESSITY
NO. 429.
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO TERRA GRANDE WATER
CASE NO. TGW-04-
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
(Attorney Name), Deputy Attorney General, requests that Terra Grande Water (Terra Grande;
Company) provide the following documents and information on or before FRIDAY, JULY 9,
2004.
This Production Request is to be considered as continuing, and Terra Grande 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
TERRA GRANDE WATER
JUNE 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). 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.
Request No.1: It is Commission Staff's understanding that Terra Grande has retained
an engineer to assess the condition of its water system.
A. Please provide the name, address and telephone number of the engineer retained by
the Company.
B. Please indicate when the Company expects to receive the engineer s report.
C. Upon receipt of the engineering report by the Company, please provide a copy to
Commission Staff.
Request No.2: In Case No. UWI-04-, Commission Staff filed comments assessing
the condition of the Terra Grande Water system. Terra Grande in meetings with Commission
Staff and Staff's attorney has represented that the water system is in better condition than
reflected in Staff Comments.
A. Please provide in this case docket a formal written reply to Staff Comments in Case
No. UWI- W -04-, specifically noting the points of disagreement.
B. In responding to Request 2A, please provide a basis for the Company s assessment
and position as pertains to the condition of the Terra Grande Water system, including any
studies, reports, memos or other written documents of any nature in the possession or control of
the Company.
Request No.3: Please provide a copy of the recent schedule of water testing required by
the Idaho Department of Environmental Quality (DEQ) and agreed to by Terra Grande. Has
Terra Grande signed a consent order? If so, please provide a copy.
Request No.4: In Commission Order No. 29512 , Case No. TGW - W -04-, the
Commission made the following finding:
FIRST PRODUCTION REQUEST TO
TERRA GRANDE WATER
JUNE 17, 2004
The Commission further finds it reasonable to require Terra Grande Water to
file a written plan for any additional capital investment in the water system
with estimated costs and proposed timing. No further capital investment in the
water system is to be made without Commission approval."
Please provide a copy of the Company s written plan for additional capital investment, with
estimated costs and proposed timing. Also, please provide a written report detailing all capital
investment (if any) in the Terra Grande Water system made by the Company since June 8, 2004
the date of the Commission s Order No. 29512.
Request No.5: Please provide copies of all trust documents for the trust that may own
manage or operate the water company. Trust documents include but are not limited to the
original trust document, all additions and amendments to the original document, all designation
oftrustee(s), and successor trustee(s), all transfer or assignment of beneficial interests in the
trust, and a list of all property, tangible or intangible, owned by the trust.
A. Please provide a copy of all documents evidencing the transfer of any trust property
or asset.
B. Please provide a copy of all documentation evidencing all liabilities of the trust.
C. Please provide a copy of all tax returns filed by the trust since 1995.
DATED at Boise, Idaho, this 1,)1A day of June 2004.
Technical Staff: Bob Smith
Marge Maxwell
Rick Sterling
Joe Leckie
Scott Woodbury
Deputy Attorney General
SW :i:umisc/prodreq/tgwwO4.swprodreq 1
FIRST PRODUCTION REQUEST TO
TERRA GRANDE WATER
JUNE 17, 2004
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF JUNE 2004
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO TERRA GRANDE WATER IN CASE NO. TGW-04-
, BY MAILING A COpy THEREOF POSTAGE PREPAID, TO THE FOLLOWING:
BARBARA V CHILD
TERRA GRANDE WATER
10012 ESHELMAN
BOISE ID 83704
WILLIAM J BATT
BATT & FISHER
POBOX 1308
BOISE ID 83701
CERTIFICATE OF SERVICE