20060509Staff to UWI 1-3.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
. i., i
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. TO AMEND AND)
REVISE CERTIFICATE OF CONVENIENCE
AND NECESSITY NO. 143.
CASE NO. UWI-06-
FIRST 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;
UWI; Company) provide the following documents and information on or before WEDNESDAY
MAY 17 2006.
United Water is reminded that responses pursuant to Commission Rules of Procedure must
include the name and phone number of the person preparing the document, and the name, location
and phone number of the record holder. Reference IDAPA 31.01.01.228.
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.
FIRST PRODUCTION REQUEST TO
UNITED WATER MAY 9, 2006
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.
Request No.1: A February 21 , 2006 letter from Kastera Homes to John Lee of United
Water requesting service to the Olsen Ranch property states that "The southerly 140 acres is
within the Eagle Area of City Impact boundary." Please indicate whether United Water is
proposing to serve those portions of the Olsen Ranch property that will lie within the City of
Eagle s Area ofImpact boundary. Is the Olsen Ranch property referred to in the letter the same as
the property identified in UWI's application as the Trailhead Community?
Request No.2: Please provide a map showing the following:
a. boundaries of the Olsen Ranch property,
b. the area United Water is asking to be added to its certificated area
c. the existing boundaries of Eagle s Area ofImpact
d. the proposed boundaries of Eagle s Area ofImpact according to the City s recent
request to Ada County to expand its Area of Impact, and
e. all currently unserved areas in the vicinity north of the City of Eagle for which
developers have discussed or requested service from United Water in the future,
To the extent possible, please identify each proposed development and show each
development's respective boundaries.
For all of the information depicted on the map including base map data, please provide
electronic files in an ArcInfo export file format (e.OO) in order to enable Staff to prepare its own
maps.
Request No.3: Please provide a map showing the proposed location(s) of all mains and
other facilities that will be added to provide the requested service to the Trailhead Community. In
addition, show all existing mains, wells , boosters, and storage facilities in the general vicinity of
FIRST PRODUCTION REQUEST TO
UNITED WATER MAY 9, 2006
the proposed development. Please discuss whether any facilities will be oversized in anticipation
of serving future proposed developments in the vicinity. Include an analysis of the expected water
demand for the Trailhead Community,
Dated at Boise, Idaho, this day of May 2006.
ex k~ij;) U~~_(A
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc/prodreq/uwiwO6.4.sw.rps prl
FIRST PRODUCTION REQUEST TO
UNITED WATER MAY 9, 2006
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF MAY 2006
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF IN CASE NO, UWI-06-, 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
McDEVITT & MILLER LLP
PO BOX 2564
BOISEID 83701
SECRET AR Y
CERTIFICATE OF SERVICE