20060630UWI observations City of Eagle responses.pdf

McDevitt & Miller LLP R E eEl V E 0
Lawyers
2006 JUN 30 PH 2= 32
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June 30, 2006
Via Hand Delivery
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, Idaho 83720
Re:Case No. UWI-06-04;
City of Eagle s Response to Staff Production Request.
Dear Mr. Woodbury:
United Water Idaho has received and reviewed the Responses of the City of Eagle to
Staff Production Requests dated June 23 , 2006. To aid in Staffs evaluation of the City
Responses, United Water has the following observations:
Response to Request No.
Eagle s Exhibit 2 references item #5 as Floating Feather Well (existing), however this is
a United Water well facility and does not belong to the City of Eagle. The Floating
Feather Well should not be considered when evaluating the City s ability to serve the
Kastera Development.
Res-ponse to Request No.
The method used by Eagle to calculate the number of new customers it can serve from
current facilities is flawed. In its Response, Eagle projects it can serve 2 624 customers
merely because it has a 3.25 cfs water right, but does not take existing water
infrastructure and facilities into consideration. The City s calculation also assumes all
customers consume water on a flat demand rate over every 24 hour period. This is both
incorrect and unrealistic. Customer usage during maximum instantaneous demand must
be considered.
The current pumping capacity of City Well #1 , which is Eagle s only reliable source of
water to the system, is approximately 800 gpm, based on both the larger (550 gpm) pump
and smaller (250 gpm) pump operating simultaneously. Even using Eagle s calculation
methodology, the current pumping capacity for the City s system can then support only
440 customers, not the 2 624 customers the City suggests. Since the City s system
Scott Woodbury
June 30, 2006
Page 2
currently serves approximately 1 320 customers, the current system could only support an
additional 120 customers, even under the equalized demand calculation method as used
by the City.
Capacity to serve must, however, be determined by knowing current system capabilities
of wells, pumps, storage, etc. Reliable capacity to serve, under IDEQ requirements
would be calculated assuming the system s largest production facility out of service. (See
IDAP A 55..01.08.550.03 (0). In Eagle s case then, because the City currently has only
one reliable production well, and its only emergency back-up supply currently is via an
interconnection and agreement with United Water Idaho, the City s current capacity to
serve new customers is zero. Putting it more simply, Eagle has little or no capacity
serve new customers without the addition of either a new well or storage facility or both.
Response to Request No.
This Request asked how long it would take to install necessary facilities to serve the
Kastera development. Eagle s answer is not responsive to the question. The City
responded by referencing the development approval and construction timeline rather than
address the timeline for construction of additional required water source (well) and or
storage facilities. Ultimately Eagle has not answered the question, " how long would it
take for the City to install the necessary facilities.
We hope the foregoing observations will be useful to Staff in its evaluation of the City
Responses.
Very Truly Yours
\ MCDevi
ITU:LP~Miller
DJM/hhCc: United Water Idaho
Bruce Smith, Esq, Attorney for City of Eagle.