200501212nd Request of staff.pdf

DONOVAN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
RECEWEO ra
F fLED
2uns JA~I 21 AM \1):
In ;IC1 F' BLIC
UT'L iES' COr-1M1SS1ON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
OF TERRA GRANDE WATER AND THE
ISSUANCE OF RELATED CERTIFICATE OF
PUBLIC CONVENIENCE AND NECESSITY
NO. 429.
CASE NO. TGW-04-
SECOND PRODUCTION
REQUEST OF THE COMMISSION
STAFF TO TERRA GRANDE
WATER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Donovan E. Walker, Deputy Attorney General, requests that Terra Grande Water (Terra Grande;
Company) provide the following documents and information on or before FRIDAY, FEBRUARY 18,
2005.
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.
SECOND PRODUCTION REQUEST TO
TERRA GRANDE WATER
JANUARY 21 2005
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.6: On July 8, 2004, the Company replied to Staff Production Request No.1 that
the Company had retained the services of a professional engineer to assess the condition of the water
company. Please provide the results of the engineer s assessment, any reports and or
recommendations. If the information is still unavailable please provide the status of the assessment
and the expected date of the resulting information.
Request No.7: On July 8 , 2004 the Company replied to Staff Production Request No.
regarding a written plan for capital investments with estimated costs and proposed timing. The
response stated: "The requested plan is being developed and will be provided upon its completion.
listing of capital expenditures made will be provided at that time." Please provide the written capital
investment plan with estimated costs and proposed timing or provide your anticipated completion date
for this plan.
Request No.8: Please provide the Company s latest DEQ sanitary survey. Please report on
any changes made since the survey.
Request No.9: Please provide an update on the status of water quality testing and a summary
of testing performed since September 2004.
DATED at Boise, Idaho, this :?15 r-da y of January 2005.
onovan E. Walker
Deputy Attorney General
Technical Staff: Michael Fuss
SW:i:umisc/prodreq/tgwwO4.swprodreq2
SECOND PRODUCTION REQUEST TO
TERRA GRANDE WATER
JANUARY 21 2005
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 21 sT DAY OF JANUARY 2005
SERVED THE FOREGOING SECOND 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 BA
BATT & FISHER
PO BOX 1308
BOISE ID 83701
CERTIFICATE OF SERVICE