20060517UWI to staff 1-3.pdf

McDevitt & Miller LLP
Lawyers
[phone]
[phone] (Fax)
420 W. Bannock Street
O. Box 2564-83701
Boise, Idaho 83702
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Chas. F. McDevitt
Dean 1. (Joe) Miller
May 17, 2006
Via Hand Delivery
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, Idaho 83720
Re: Case No. UWI-06-
Dear Ms. Jewell:
Enclosed for filing in the above matter please find three (3) copies of United Water
Idaho s Response to Commission Staff s First Production Requests.
An additional copy of the document and this letter is included for return to me with your
file stamp thereon.
Very Truly Yours
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tQfller LLP
Miller
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ORtG1NAL
Dean J. Miller (ISB No. 1968)
MCDEVITT & MILLER LLP
420 West Bannock Street
o. BOX 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
i oe(ti),mcdevitt- miller .com
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Attorneys for United Water Idaho Inc.
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
UNITED WATER IDAHO INC'
RESPONSE TO COMMISSION
STAFF'S FIRST PRODUCTION
REQUESTS
CASE NO. UWI-O6-
United Water Idaho Inc, by and through its undersigned attorneys, hereby submits its
Response to Commission Staffs First Production Requests as follows:
REQUEST NO.: 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 of Impact 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?
RESPONSE TO REQUEST NO.: United Water Idaho does not have current plans to
serve any portion of the Olsen Ranch that lies within the City of Eagle s Area of Impact
boundary. The property identified in UWI's Application to serve the Trailhead Community
includes only the portion of the Olsen Ranch which lies north of the City of Eagle s Area of
Impact northern boundary.
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S FIRST PRODUCTION REQUESTS-
REQUEST NO.: 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 of Impact
d. the proposed boundaries of Eagle s Area of Impact according to the City'
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.
F or all of the infonnation depicted on the map including base map data please provide
electronic files in an Arc Info export file fonnat (e. 00) in order to enable Staff to prepare its
own maps.
RESPONSE TO REQUEST NO.: In response to the above request a, b, and c, please
refer to map marked Exhibit A which includes the boundaries of the Olsen Ranch property, the
area United Water is asking to be added to its certificated area, and the existing north boundary
of Eagle s Area of Impact.
In response to request d, to the best of United Water s knowledge the area depicted on
Exhibit A as Eagle Area of Impact includes the existing Area of Impact. To the best of United
Water s knowledge, Eagle has not made a fonnal request to expand its Area of Impact.
In response to request e, there have been a few infonnal phone conversations regarding water
availability with individuals owning property north of Homer Road between Highway 55 & 16.
There have been no other fonnal conversations or requests for service :from developers.
The requested ArcInfo file will be e-mailed directly to Rick Sterling per a phone
conversation with him.
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S FIRST PRODUCTION REQUESTs. 2
REQUEST NO.: 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 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.
RESPONSE TO REQUEST NO.: Construction of a transmission main, booster
station, and reservoir will be necessary to provide water service to the Trailhead Community.
The transmission main is proposed to extend north on Eagle Road and Willow Creek Road, from
United Water s existing 16" water main in Floating Feather Road, to the Trailhead Community
existing and proposed facilities are shown on Exhibit B. The location of a booster station and
storage reservoir will be dictated by elevation of the future building lots and is yet to be
determined.
The proposed size of the future transmission main to serve the Trailhead Community is
12". United Water has not made any decision regarding over sizing.
DATED this day of May, 2006.
Respectfully submitted
McDEVITT & MILLER LLP
G1 W1
Dean J. Miller
Attorneys for United Water Idaho Inc.
UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S FIRST PRODUCTION REQUESTS- 3
CERTIFICATE OF SERVICE
I hereby certify that on the r:r-fday of May, 2006, I caused to be served, via the
methodes) indicated below, true an~rrect copies of the foregoing document, upon:
Jean Jewell, Secretary Hand Delivered
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Idaho Public Utilities Commission S. Mail 1....1
472 West Washington Street Fax 1....1
O. Box 83720 Fed. Express 1....1
Boise, ID 83720-0074 Email 1....1
i iewell(2V,puc. state.id. us
Bruce M. Smith Hand Delivered 1....1
MOORE SMITH BUXTON & TURCKE S. Mail
225 N. 9th Street, Suite 420 Fax 1....1
Boise, ID 83702 Fed. Express 1....1
Email 1....1
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UNITED WATER IDAHO INC'S RESPONSE TO COMMISSION STAFF'S FIRST PRODUCTION REQUESTS- 4
SEE CASE FILE
FOR MAP(S)