20060721Staff to City of Eagle 7.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
RECEIVED
200& JUL 2' AM 9: 55
\OAHO PUBLlQ
UTILITIES COMMISSION
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 (TRAILHEAD COMMUNITY).
CASE NO. UWI-06-
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO THE
CITY OF EAGLE, IDAHO
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, requests that the City of Eagle (City) provide the
following documents and information on or before FRIDAY, AUGUST 4, 2006.
The City of Eagle 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 the City of Eagle 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.
SECOND PRODUCTION REQUEST TO
THE CITY OF EAGLE, IDAHO JULY 21 2006
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.7: In response to Staffs Request No., the City of Eagle submitted a
map labeled as Exhibit 2 showing existing City-owned facilities as well as proposed facilities that
would be added to serve the Trailhead development and adjacent areas. The map references item
# 5 as the Floating Feather Well (existing). Please clarify who owns the Floating Feather Well
and describe any agreements the City of Eagle has for utilization ofthe Floating Feather Well.
Was the Floating Feather Well considered when evaluating the City s ability to serve the Trailhead
development? Please reference the City s response to Request No.4 in your answer.
Dated at Boise, Idaho, this
;)
day of July 2006.
c0f)~
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc/prodreq/uwiwO6.4.swrps pr2 _City of Eagle.doc
SECOND PRODUCTION REQUEST TO
THE CITY OF EAGLE, IDAHO JULY 21 2006
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF JULY 2006 SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
TO THE CITY OF EAGLE, IDAHO, IN CASE NO. UWI-06-, BY MAILING A
COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
CITY OF EAGLE
% BRUCE M. SMITH, ESQ
225 NORTH 9TH ST SUITE 420
BOISE ID 83702
MAIL: bms(fYmsbtlaw.com
DEAN J MILLER ESQ
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
GREGORYP. WYATT
UNITED WATER IDAHO INC
PO BOX 190420
BOISE ID 83719-0420
~"2D.
SECRETARY
CERTIFICATE OF SERVICE