200408122nd Request of Staff to United Water.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 APPLICATION OF
UNITED WATER IDAHO INC., FOR AN
AMENDMENT TO ITS CERTIFICATE OF
PUBLIC CONVENIENCE AND NECESSITY NO. )
142 AND FOR AN ACCOUNTING ORDER.
CASE NO. UWI-04-
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
UNITED WATER IDAHO INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, requests that United Water Idaho Inc. (United
Water; Company) provide the following documents and information on or before FRIDAY
SEPTEMBER 3, 2004.
This Production Request is to be considered as continuing, and United Water 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.
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.
SECOND PRODUCTION REQUEST
TO UNITED WATER AUGUST 12 , 2004
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. 20: Please provide the current production capacity of the Carriage Hill
well.
Request No. 21: If the existing Carriage Hill well can be expanded, please provide the
maximum capacity of the existing Carriage Hill well.
Request No. 22: How many customers can be served by the existing well, with and
without the maximum expansion? Please include maximum number of customers with and
without the second source included.
Request No. 23: What is the anticipated size and estimated cost of the second source
well required for the Carriage Hill service area?
Request No. 24: What entity is responsible for the cost of the second well source for the
Carriage Hill service area? Please explain.
Request No. 25: What is the value of the capacity credits available to the developers of
Carriage Hill Subdivision? Please provide a detailed calculation with all backup information.
Request No. 26: Please explain the difference between the Carriage Hill service areas
proposed in Case No. UWI-99-1 (250 acres, stated in Staff Comments) and the current Case
No. UWI-04-03 (198.84 acres, Nampa Agreement).
SECOND PRODUCTION REQUEST
TO UNITED WATER AUGUST 12, 2004
Request No. 27: If the City of Nampa has or intends to annex all the remaining areas of
the Carriage Hill subdivision, what is the likelihood that the City will provide all subsequent
areas of the subdivision water service even if the Purchase Agreement is not executed?
Request No. 28: What is United Water s current source obligation to the Carriage Hill
Service Territory and the anticipated time frame for completion?
Dated at Boise, Idaho, this
fr1.
l;l
day of August 2004.
Scot Woodbury
Deputy Attorney General
Technical Staff: Michael Fuss
Patricia Harms
Joe Leckie
SW:i:umisc/prodreq/uwiwO4.3.swrpsphjl prod req 2
SECOND PRODUCTION REQUEST
TO UNITED WATER AUGUST 12, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF AUGUST 2004
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO UNITED WATER IDAHO INC., IN CASE NO.
UWI-04-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE
FOLLOWING:
GREGORY P WYATT
UNITED WATER IDAHO INC
PO BOX 190420
BOISE, ID 83719-0420
DEAN J MILLER ESQ
McD EVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
SECRET
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CERTIFICATE OF SERVICE