20070420UWI to City of Eagle 1-13.pdf

McDevitt & Miller LLP
Lawyers
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Chas. F. McDevitt
Dean J. (Joe) Miller
April 20, 2007
Via Hand Delivery
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, Idaho 83720
Re: Case No. UWI-07-
Dear Ms. Jewell:
Enclosed for filing in the above matter please find three (3) copies of United Water
Idaho s Response to City of Eagle s First Production Requests.
An additional copy of the document and this letter is included for return to me with your
file stamp thereon.
Very Truly Yours
Devitt & Miller LLP
VJf ean J. Miller
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ORIGINAL
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Dean J. Miller (ISB No. 1968)
MCDEVITT & MILLER LLP
420 West Bannock Street
O. BOX 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
ioe~mcdevitt -miller .com
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Attorney for United Water Idaho Inc.
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
UNITED WATER IDAHO INC'
RESPONSE TO CITY OF EAGLE'
FIRST PRODUCTION REQUESTS
CASE NO. UWI-07-
United Water Idaho Inc
, ("
United Water ) by and through its undersigned attorneys
hereby submits its Response to the City of Eagle s First Production Request as follows:
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.
RESPONSE TO REQUEST NO.: United Water does not have any documents
responsive to this request.
Person preparing Response: Gregory P. Wyatt
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 1
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.
RESPONSE TO REQUEST NO.: The City did not solicit comment from United
Water relating to adoption of its Master Plan, and, to United Water s knowledge, the plan was
not adopted through a public process. Accordingly, United Water does not any have documents
responsive to this request.
Person preparing Response: Gregory P. Wyatt
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 2
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.
RESPONSE TO REQUEST NO.: United Water does not have any documents
responsive to this request.
Person preparing Response: Gregory P. Wyatt
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 3
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.
RESPONSE TO REQUEST NO.: See Attached.
Person preparing Response: Gregory P. Wyatt
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 4
=t~ MENT. Inc.
RECEIVED
DEC 2 7 2006
UNITED WATER
December 21 , 2006
John Lee
United Water
8248 W. Victory Road
Boise ID 83709
:Re: Letter .of serviceability for Lanewood Estates in West Ada County
Dear Mr. Lee:
We are in the process of developing 190 acres in West Ada Comity. The property is
located at the northwest corner of Floating Feather and Linder Road and is bounded by
, Umewood Road on the west and Beacon Light on the north.
We have decided to submit a subdivision application to Ada County and anticipate that
the application will be submitted early next year, possibly the first week of January.
Consequently, we are requesting that United Water annex oUr property into its
certificated area and issue. a letter of serviceability. for our project.
. ,
Please let us know ifthere is any additional information that you need in order toprocess this requst.
Sincerely,
n.M , on Y r agO , President
Capital Deve pm t, Inc. '
6200 North Meeker Place Boise, Idaho 83713
Office: [phone] Fax: [phone]
JOHN LEE
Construction Coordinator
j(J United Water
-s. "'"" UNITED WATER IDAHO lNG,
8248 West Victory Road, Boise, 10 83709
Q, Box 190420, Boise, 1083719-0420
Tel: 208,362,7329 . Fax: 208.362,3858
john,lee(1Yunitedwater.com
January 16, 2007
Mr. Dave Yorgason
Capital Development, Inc.
6200 North Meeker Place
Boise , 1083713
Subject: Water Service to lanewood Estates Subdivision
Dear Mr. Yorgason:
United Water has received your request from Capital Development, Inc. to provide water
service to the proposed lanewood Estates Subdivision. The purpose of this letter is to
advise you that United Water has the expertise and willingness to serve the proposed
lanewood Estates Subdivision located on the west side of Linder Road between Floating
Feather and Beacon Light Roads.
This proposed subdivision property is located outside United Water s approved area of
service. In order to serve this area , United Water is required to file for an extension of its
service territory, which must be approved by the Idaho Public Utilities Commission
(IPUC). You have provided United Water with all the necessary documentation to prepare
a filing for a service area expansion with the IPUC. United Water will initiate and keep
you informed though out the filing of our service area extension process.
I trust that this letter will aid you in the speedy process of this project.
Very truly yours
:Lee.--
John lee
Construction Coordinator
WWW. U N ITEDWATER ,COM
REQUEST NO.: Please provide a copy of any water needs assessments for the
Lanewood development.
RESPONSE TO REQUEST NO.: See Direct Testimony of Scott Rhead, Dated March
2007. A copy of the United Water Idaho Master Plan is in the custody of counsel for United
Water and arrangements for review the Master Plan may be made by contacting counsel for
United Water. United Water does not have any other documents responsive to this request.
Person preparing Response: Scott Rhead
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 5
REQUEST NO.: Please provide a copy of all engineering design and cost estimates or
budgets for construction and development schedules for all facilities that will be needed for UWI
to serve the Lanewood development.
RESPONSE TO REQUEST NO.: See Direct Testimony of Scott Rhead dated March
2007.
UNITED WATER IDAHO INe'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 6
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.
RESPONSE TO REQUEST NO.: See Direct Testimony of Scott Rhead, Dated
March 26 2007.
Person preparing Response: Scott Rhead
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 7
REQUEST NO.: Please identify all wells and transmission lines which UWI will use
or propose to use to serve the Lanewood development.
RESPONSE TO REQUEST NO.: See Direct Testimony of Scott Rhead dated March
, 2007
Person preparing Response: Scott Rhead
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 8
REQUEST NO.: Please provide any contracts or agreements between UWI and
Capital Development regarding the Lanewood development.
RESPONSE TO REQUEST NO.: Other than correspondence previously disclosed
United Water does not have any documents responsive to this request.
Person preparing Response: Gregory P. Wyatt
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 9
REQUEST NO. 10: With regard to the water rights, well(s), 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.
RESPONSE TO REQUEST NO. 10 : Facilities required to serve the Lanewood
development are located in United Water s Floating Feather service level. There are
approximately 790 customers in that service level.
Person preparing Response: Scott Rhead
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 10
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?
RESPONSE TO REQUEST NO. 11 : Yes, with exception of facilities not yet
constructed.
Person preparing Response: Gregory P. Wyatt
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 11
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.
RESPONSE TO REQUEST NO. 12: See Direct Testimony of Scott Rhead dated March
2007. See Response to No.
Person preparing Response: Scott Rhead
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 12
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.
RESPONSE TO REQUEST NO. 13 : Because United Water s system is fully
integrated, service to specific customers cannot usually be tied to specific water rights or wells.
Trailhead would be connected at Floating Feather and Eagle road, Lanewood would be
connected adjacent to the development on Linder road. The A vimor connection is at Dry Creek
road at the end of the Hidden Springs development.
Person preparing Response: Scott Rhead
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 13
DATED this c. day of April, 2007.
UNITED WATER IDAHO INC.
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Attorneys for United Water Idaho, Inc.
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 14
CERTIFICATE OF SERVICE
I hereby certify that on the~ay of April, 2007, I caused to be served by the method(s)
indicated below, a true and correct copy ofthe foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
11 ewell(W,puc. state.id. us
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Bruce M. Smith, Esq,
MOORE, SMITH, BUXTON & TuRKE
950 W. Bannock, Suite 520
Boise, ID 83702
Hand Delivered
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Fax
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Email
Robert B. Burns, Esq.
Moffat Thomas
101 S. Capital Blvd, 10th Floor
O. Box 829
Boise, ID 83701-0829
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Email
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McDEVI ILLE
UNITED WATER IDAHO INC'S RESPONSE TO CITY OF EAGLE'S FIRST PRODUCTION
REQUESTS- 15