20060721Staff to UWI 4.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
RECEIVED
2006 JUL 2' AM 9: 55
IDAHO PUBLICUTILITIES 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
UNITED WATER IDAHO
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 (United Water)
provide the following documents and information on or before FRIDAY, AUGUST 4, 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 IDAP A 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.
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
UNITED WATER 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.4: In response to Staffs Request No.2 to the City of Eagle, the City
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 United Water s ownership
interest in the Floating Feather Well and describe any agreements United Water has with the City of
Eagle for utilization of the Floating Feather Well. Please provide copies of all written agreements
and correspondence between United Water and the City of Eagle and/or the manager/operator of the
City water system related to the Floating Feather Well. Should the City have rights to use Floating
Feather water, has the City ever utilized such rights? Please provide supporting data.
Dated at Boise, Idaho, this
dl
~y
of July 2006.
oJ.5itH~
Scott WooClbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc/prodreq/uwiwO6.4.swrps pr2 - UWI.doc
SECOND PRODUCTION REQUEST TO
UNITED WATER 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 UNITED WATER IDAHO INc., 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~msbtlaw.com
DEAN J MILLER ESQ
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
GREGORYP. WYATT
UNITED WATER IDAHO IN
PO BOX 190420
BOISE ID 83719-0420
~~.
SECRETARY
CERTIFICATE OF SERVICE