200408312nd Response of United Water to Staff.pdf

ORIGINAL
Dean J. Miller (ISB No. 1968)
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564-83701
Boise, Idaho 83702
Tel: [phone];
Fax: [phone]
BEFO RE THE ID AH 0 PUBLIC UTILITIES CO MMISSI ON
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INC., FOR AN
AMEND MENT TO ITS CER TIFI CA TE OF
PUBLIC CONVENIENCE AND NECESSITY
NO. 142 AND FOR AN ACCOUNTING
ORDER.
Case No. UWI-O4-
UNITED WATER IDAHO INC.
RESPONSE TO STAFF'S SECOND
PRODUCTION REQUEST
COMES NOW United Water Idaho Inc.
, ("
United"
, "
the Company ) and responds to the
Second Production Request of the Commission Staff.
Each Response was prepared by the person identified herein as the witness to answer
questions at hearing and any documents associated with an answer are in the possession of that
person.
Dated this~ day of August, 2004.
McDEVITT & MILLER LLP
Dean J. Miller
Attorneys for United Water Idaho Inc.
UNITED WATER IDAHO INC.'S RESPONSE TO STAFF S SECOND PRODUCTION REQUEST-
Request No. 20:
Please provide the current production capacity of the Carriage Hill well.
Response:
The Carriage Hill well is currently equipped with two pumps; a "domestic" pump rated at
300gpm at a total dynamic head of 255', and a "fire" pump rated at 1 OOgpm at a total dynamic
head of255'
Witness to answer questions at hearing: Gregory Wyatt
UNITED WATER IDAHO INC.'S RESPONSE TO STAFF S SECOND PRODUCTION REQUEST-
Request No. 21:
If the existing Carriage Hill Well can be expanded, please provide the maximum capacity of the
existing Carriage Hill well.
Response:
Based on the original pumping test data a continuous pumping rate of 1 ,600gpm was
expected to be obtainable from the existing well, provided there is no interference from another
well on the existing lot.
Witness to answer questions at hearing: Gregory Wyatt
UNITED WATER IDAHO INC.'S RESPONSE TO STAFF S SECOND PRODUCTION REQUEST-3
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.
Response:
The Carriage Hill Subdivision currently provides its homeowners with an alternate source
of summer irrigation water that is separate from the United Water Idaho potable water system.
Assuming that an alternate source of summer irrigation water is made available to all future
customers in the area, we estimate that each customer would require approximately Yz-gpm from
the United Water Idaho system. Using this assumption, the existing Carriage Hill well with the
existing 300gpm "domestic" pump could then serve up to approximately 600 customers. With
the pumping plant changed to produce the maximum yield physically possible from the well
(1,600gpm based on the original drilling log), and taking into account that the fire protection
requirement for the area of 1 000gpm must be reserved for a fire, then approximately 1 200
customers (600gpm divided by 1/2gpm per customer) could be served from the existing Carriage
Hill well. However, in order to utilize the maximum capacity of the well (1 600gpm) additional
water right volume would need to be acquired.
It is impossible to estimate how many customers would be able to be served with a
second source included. This is because a second source has not been sited, drilled or placed
into production, thus it is impossible to know its capacity. The second source, as it was
originally conceived and as required by IDEQ, was planned as a back up to the existing domestic
supply and not as additional source capacity for Carriage Hill.
Witness to answer questions at hearing: Gregory Wyatt
UNITED WATER IDAHO INC.'S RESPONSE TO STAFF S SECOND PRODUCTION REQUEST-4
Request No. 23:
What is the anticipated size and estimated cost of the second source well required for the
Carriage Hill service area?
Response:
The second source well was anticipated to be constructed on the same lot that contains
the existing well. The anticipated size of the second well is 12-inches in diameter and
approximately 350 feet deep with an estimated capacity of 400gpm. Engineering assumption of
probable cost is $88 000. This cost does not include the anticipated costs of obtaining a drilling
permit and obtaining the necessary additional water right beyond the current 3.0cfs right for the
existing well. It is impossible to accurately project these costs in the current water rights
environment.
Witness to answer questions at hearing: Gregory Wyatt
UNITED WATER IDAHO INC.'S RESPONSE TO STAFF S SECOND PRODUCTION REQUEST-
Request No. 24:
What entity is responsible for the cost of the second well source for the Carriage Hill service
area? Please explain.
Response:
Carriage Hill, L.C. Paragraph 4 of The Residential or Multiple Family Housing Non-
Contiguous Water System Agreement, entered into between United Water Idaho and Carriage
Hill, L., clearly states that the "Owner" (Carriage Hill) shall be responsible to construct and
pay the cost of the Water Facilities as required by the appropriate federal, state, or local
government authorities, agencies, or officials. Paragraph 5 of the same Agreement states that the
facilities so constructed are to be transferred and conveyed to the Company (United Water
Idaho). A copy of the Agreement is attached and marked "Production Request No. 24"
Witness to answer questions at hearing: Gregory Wyatt
UNITED WATER IDAHO INC.'S RESPONSE TO STAFF S SECOND PRODUCTION REQUEST-6
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.
Response:
The Residential or Multiple Family Housing Non-Contiguous Water System Agreement
entered into between United Water Idaho and Carriage Hill, L.C. contains no provision for
capacity credits, th(~refore none have been or are calculated.
Witness to answer questions at hearing: Gregory Wyatt
UNITED WATER IDAHO INC.'S RESPONSE TO STAFF S SECOND PRODUCTION REQUEST-
Request No. 26:
Please explain the difference between the Carriage Hill service areas proposed in Case No. UWI-
99-l (250 acres, stated in Staff Comments) and the current Case No. UWI-04-03 (198.
acres, Nampa Agreement).
Response:
The 250 acres is the area United Water Idaho originally requested as the service territory
for the Carriage Hill area in its filing Case No. UWI-99-l. However the Commission Order
No. 27976 on the ITlatter dated March 26 1999 required United Water Idaho to amend the
service territory to include only the Carriage Hill Subdivisions. United Water Idaho filed for this
additional area under the 27th amendment to its Certificate of Convenience and Necessity No.
143 on January 3 , 2000 and received approval on January 19 2000. The area is described as:
Carriage Hill Subdivision No. 1 located in the South Yz of Section 31 , Township 3
North, Range 2 West, Boise Meridian, and recorded in Book 26 of Plats at Page
, records of Canyon county, Idaho.
The above area covers only Phase 1 and contains approximately 22 acres. United Water
Idaho now provides service to both Phase 1 and 2 of the Carriage Hills Subdivision and in doing
so has grown the service territory in a contiguous fashion from the initial Phase 1 area initially
authorized.
United Water Idaho believes the 198.84 acres represents the area that the Carriage
received preliminary subdivision plat approval on from Canyon County in 1998. This area
would encompass all proposed phases of the subdivision, and would have been included in
United Water Idaho s original 250 acre filing. United Water Idaho anticipates abandoning all of
its service territory related to the Carriage Hills Subdivision if the proposed sale to Nampa is
consummated.
Witness to answer questions at hearing: Gregory Wyatt
UNITED WATER IDAHO INC.'S RESPONSE TO STAFF S SECOND PRODUCTION REQUEST-8
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?
Response:
Based on conversations between representatives of the Company and the City ofNampa
United Water Idaho believes that if the sale transaction fails, the City will abandon its annexation
effort. The City, United is informed, desires to extend city services to the area as part of its plans
for orderly growth. If the City cannot own the well and water system it cannot extend its other
services. It is uncertain as to whether the City of Nampa will extend services adjacent to or
beyond the Carriage Hill Subdivision, thus encircling it.
Witness to answer questions at hearing: Gregory Wyatt
UNITED WATER IDAHO INC.'S RESPONSE TO STAFF S SECOND PRODUCTION REQUEST-9