20141016Staff 1-5 to BSWUA.pdf

KARL KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6864
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
IN THE MATTER OF UNITED WATER IDAHO
INC.'S AND BRIAN SUBDIVISION WATER
USERS ASSOCIATION'S APPLICATION TO
ALLOW UNITED WATER TO TAKE OVER
BRIAN WATER'S DOMESTIC WATER
SYSTEM.
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CASE NO. UWI-W-14-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
BRIAN SUBDIVISION WATER
USERS ASSOCIATION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl Klein, Deputy Attorney General, requests that Brian Subdivision Water Users Association
(BSWUA) provide the following documents and information as soon as possible, but no later
than THURSDAY, OCTOBER 30,2014.1
This Production Request is to be considered as continuing, and the BSWUA 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
' Staffis requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST TO
BRIAN SUBDIVISION WATER USERSASSOCIATION 1 ocToBER 16,2014
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide BSWUA's water usage data from 2010 through the
present.
REQUEST NO. 2: Please provide BSWUA's current rate schedules.
REQUEST NO. 3: As of the most recent billing schedule, please provide the number of
customers that are delinquent in paying, the amount owed by each customer, and the number of
days the customer is delinquent (Accounts Receivable Aging Report) for BSWUA.
REQUEST NO. 4: Please provide a list of all customers, including ruImes and complete
mailing addresses for all current BSWUA customers.
REQUEST NO. 5: Have all current BSWUA customers received a copy of the
Agreement for Connection and Transfer of Water Systems (Agreement) signed by UWI and
BSWUA dated September 24,2014?
FIRST PRODUCTION REQUEST TO
BRIAN SUBDIVISION WATER USERS
ASSOCIATION ocToBER 16,2014
DATED at Boise, Idaho, this I C+) auy of October 2014.
MIL
Karl Klein
Deputy Attomey General
Technical Staff: Johanna Bell/l
Joseph Terryl2-3
Chris HechV4-5
i:umisc:prodreq/uwil4.lkkjbjtch prod req I to BSWUA
FIRST PRODUCTION REQUEST TO
BRIAN SUBDIVISION WATER USERS
ASSOCIATION ocToBER 16,20t4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I6TH DAY oF OCTOBER 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO BRIAN SUBDIVISION WATER USERS ASSOCIATION,
IN CASE NO. UWI-W.I4.01, BY MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
GREGORY P WYATT
UNITED WATER IDAHO INC
PO BOX 190420
BOISE rD 83719-0420
EMAIL: [e-mail]
RICHARD JUENGLING
PRESIDENT
BRIAN SUB WATER USERS
5855 E WOOD PLACE
BOISE ID 83716
EMAIL: [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK
BOISE ID 83702
EMAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE