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Home My WebLink About20070409City of Eagle to UWI 1-13.pdfMOORE SMITH BUXTON & TURCKE, CHARTERED ATTORNEYS AND COUNSELORS AT LAW 950 W. BANNOCK STREET, SUITE 520; BOISE, ID 83702 TELEPHONE: (208) 331-1800 FAX: (208) 331-1202 www.msbtlaw.com STEPHANIEJ. BONNEY SUSAN E. BUXTON' PAULJ. FITZER MICHAEL c. MOOREI BRUCEM. SMITH PAUL A. TURCKE' CARL J. WITHROE,, TAMMY A. ZoKAN' JOHN J. McFADDEN*' Of Counsel " Also admitted in California + Also admitted in New Mexico . Also admitted in Oregon , Also admitted in South Dakota I Also admitted in Washington ,-co ---' April 6, 2007 f~ :::; CJ ' ' Mr. Scott Woodbury Idaho Public Utilities Commission 472 W. Washington Boise, ill 83720 c;.co' . ' Co ::"; ,. '" ,~ ,.--,:~:;::, ,,:;~;;:-: (.r;,:-" t:""UJ RE: UWI-07- Our File No. 1019.49 Dear Mr. Woodbury: Enclosed for filing in the above matter please find the original and 3 copies of the City of Eagle Requests for Production to United Water Idaho and Capital Development, Inc, along with the original and 7 copies of the City of Eagle s Reply to Capital Development, Inc.s Motion to File Brief on Legal Issues An additional copy of each document and this letter are included for return to our office. Thank you for your assistance. Sincerely yours MOORE SMITH BUXTON & TURCKE, CHTD. Bruce M. Smith BMS/dls Enclosures Bruce M. Smith, ISB # 3425 Susan E. Buxton, ISB # 4041 MOORE SMITH BUXTON & TURCKE, CHARTERED Attorneys at Law 950 West Bannock Street, Suite 520 Boise, Idaho 83702 Telephone: (208) 331-1800 Facsimile: (208) 331-1202 Attorney for City of Eagle, Idaho 7i,. ;--;j Fi;:,::5~~; rt'i~.1 ! ~(-.\' ~~;i~ BEFORE THE IDAHO PUBLIC UTILIES COMMISSION IN THE MATTER OF THE APPLICATION OF ) UNITED WATER IDAHO INC., TO AMEND AND REVISE CERTIFICATE OF CONVENIENCE AND NECESSITY NO 143 Case No. UWI-07- CITY OF EAGLE'S FIRST PRODUCTION REQUESTS TO UNITED WATER IDAHO INC. The City of Eagle, Idaho, by and through its attorney of record, Bruce M. Smith, requests that United Water Idaho Inc. provide the following documents and information on or before FRIDAY, APRIL 20, 2007. United Water Idaho Inc. 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 Idaho Inc. 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. CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO, INc. - 1 1019. Please provide answers to each question; supporting work papers 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. REQUEST NO.: Please provide any correspondence or comments by you, which includes written or email versions, to the City of Eagle or Ada County related to adoption of the City of Eagle s 2025 Comprehensive Plan. REQUEST NO.: Please provide any correspondence or comments by you, which includes written or email versions, relating to the adoption of the City s Municipal Water System Master Plan. REQUEST NO.Please provide a copy of all correspondence, including emails facsimiles, and any attachments thereto, between UWI and Ada County regarding the Lanewood development. REQUEST NO.Please provide a copy of all correspondence, including emails facsimiles, and any attachments thereto, between UWI and Capital Development, Inc. regarding the Lanewood development. REQUEST NO.Please provide a copy of any water needs assessments for the Lanewood development. REQUEST NO.: Please provide a copy of all engineering designs , cost estimates or budgets for construction and development schedules for all facilities that will be needed for UWI to serve the Lanewood development. REQUEST NO.: Please identify and provide a copy of all water rights that UWI will use or propose to use to supply the Lanewood development. CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO, INC. - 2 1019. REQUEST NO.: Please identify all wells and transmission lines which UWI will use or propose to use to serve the Lanewood development. REQUEST NO.Please provide any contracts or agreements between UWI and Capital Development, Inc. regarding the Lanewood development. REQUEST NO. 10: With regard to the water rights, welles), and transmission lines that UWI will use or proposes to use to serve the Lanewood development, please identify all other UWI customers that these facilities are used to serve. REQUEST NO. 11 : Are any of the water rights, wells , or transmission lines that UWI will use or proposes to use to serve the Lanewood development currently included in the rate base for which UWI receives revenue? REQUEST NO. 12 : Please provide a copy of any assessment or analysis prepared by UWI or any consultant regarding the wells which UWI will use or could be used to supply the Lanewood development. REQUEST NO. 13: Will the water rights , wells , or transmission lines which UWI will use or proposes to use to serve the Lanewood development be used to serve the Trailhead Community or A vimor developments? If so, please describe how that use will occur. DATED at Boise, Idaho, this day of April, 2007. MOORE SMITH BUXTON & TURCKE CHARTERED By: , ruce M. Smith Attorney for City of Eagle, Idaho CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO, INC. - 3 1019.49 CERTIFICATE OF SERVICE I hereby certify that on this day of April, 2007, the foregoing document was served to the following parties by the method indicated below: Dean J. Miller McDevitt & Miller, LLP 420 W. Bannock Street (83702) PO Box 2564 Boise, ID 83701 i oe(qJ,mcdevitt - miller. com ----.... ( ) u.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile ( ) Other Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Street (83702) O. Box 83720 Boise, ID 83720-0074 scott. woodburv~puc. idaho. gov Robert B. Burns ~) u.S. Mail, Postage Prepaid Moffatt, Thomas, Barrett, Rock & Fields, Chtd ( ) Hand Delivered 101 S. Capitol Blvd., loth Floor ( ) Overnight MailPO Box 829 ( ) Facsimile Boise, ID 83701 ( ) Other rbb~moffatt.com ) u.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile ( ) Other Bruce M. Smith Attorney for City of Eagle, Idaho CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO UNITED WATER IDAHO, INc. - 4 1019.