20070202Staff to UWI 1-5.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
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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 ITS CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY AND FOR
APPROVAL OF A SPECIAL FACILITIES
AGREEMENT WITH A VIMORE LLC.
CASE NO. UWI-07-
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
Weldon B. Stutzman, Deputy Attorney General, requests that United Water Idaho Inc. (United
Water; Company) provide the following documents and information on or before FRIDAY
FEBRUARY 23, 2007.
The Company 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.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name and telephone number of the person
FIRST PRODUCTION REQUEST
TO UNITED WATER
FEBRUARY 2, 2007
preparing the documents. Please identify 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 if need
be.
Request No.1: Please provide a break down of the estimated facilities costs included in
the Avimor Special Facilities Agreement that add to $6 308 805. Show the costs separated into
the following categories; storage tank, booster pumping station, off site transmission main and on
site transmission main. Show the overheads for each facility category separately.
Request No.2: On page 5 of the Avimor Special Facilities Agreement in the first line of
paragraph 10 "Off-site Main Reimbursement" reference is made to "12- inch" main. Does this
agreement include 12-inch main that Avimor is contributing or advancing? Ifit does, please
provide the 12-inch main costs, location(s) and advance/contribution treatment proposed along
with the reasoning that justifies the proposed treatment.
Request No.3: Please provide Company Exhibit G in Excel electronic format. Also
provide the calculation of Exhibit G inputs in Excel electronic format. Please provide the backup
document for the inputs for Exhibit G as well.
Request No.4: What is the estimated maximum operating capacity (gpm) of the 16-inch
transmission main?
Request No.5: In Mr. Wyatt's testimony, page 6, lines 18 and 19, four previous special
facilities agreements executed by United Water are mentioned. For each of these agreements
please provide the following:
a) the Special Facilities agreement
b) contributed costs by facility,
c) advanced costs by facility,
d) total facilities costs
FIRST PRODUCTION REQUEST
TO UNITED WATER
FEBRUARY 2, 2007
e) the amount of advanced costs refunded to date
f) the contract beginning date and ending date,
Dated at Boise, Idaho, this ~day of February 2007.
~~~~
Deputy Attorneys General
-------?
Technical Staff: Keith Hessing
i:umisc/prodreq/uwiwO7, 1 wskhl
FIRST PRODUCTION REQUEST
TO UNITED WATER
FEBRUARY 2, 2007
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF FEBRUARY 2007
SERVED THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO UNITED WATER IDAHO INc.IN CASE NO, UWI-07-, 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
BOISE ID 83701
;JLISECRET
CERTIFICATE OF SERVICE