20141028Staff 16-20 to UWI.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:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
IN THE MATTER OF UNITED WATER IDAHO
INC.'S AND BRIAN SUBDIVISION WATER
USBRS ASSOCIATION'S APPLICATION TO
ALLOW UNITED WATER TO TAKE OVER
BRIAN WATER'S DOMESTIC WATER
SYSTEM.
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?0lt 0CI 29 fiH t0: rr2
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. UWr-W-14-01
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
UNITED WATER IDAHO INC.
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Karl Klein, Deputy Attorney General, requests that United Water Idaho Inc. (United Water)
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, NOVEMBER 12, 2014.1
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 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
I Staffis requesting an expedited response. If responding by this date will be problematic, please call Staffs
attomey at [phone].
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO OCTOBER 29,2014
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. 16: How many water storage reservoirs and booster stations were
originally planned in the drinking water system master plan for the Harris Ranch subdivision?
Were any planned storage reservoirs elevated (yes/no)? Please explain and provide a map that
distinguishes between planned and existing storage reservoirs and booster stations for the Harris
Ranch subdivision.
REQUEST NO. 17: Absent a looped interconnection to serve Brian Water (i.e., as
proposed), was additional reservoir storage planned for the Harris Ranch area? If not, why not?
If so, who would have paid for the storage facility?
REQUEST NO. 18: Was a transmission line extension installed across the East Park
Center Bridge to feed the Harris Ranch Subdivision and other developments on the east and
northern side of the Barber Service Level? If so, please explain. If not, why not?
REQUEST NO. 19: Are separate irrigation systems installed to serve the Harris Ranch
subdivision or any of the other residential developments in the area? Please explain.
REQUEST NO.20: Please provide a map of the expected route for the Warm Springs
line extension and the proposed looped interconnection route.
SECOND PRODUCTION REQUEST
TO UNITED WATER IDAHO ocToBER 29,2014
DATED at Boise, Idaho, tnis l4bday of October 2014.
Karl Klein
Technical Staff: Johanna Bell
i:umisc:prodreq/uwi14.lktjb prod req 2 to UWI
Deputy Attorney General
SECOND PRODUCTION REQUEST
TO I"INITED WATER IDAHO ocroBER 29,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF OCTOBER 2014,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO T NITED WATER IDAHO, INC., IN CASE NO.
UWI-W-14.0I, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
GREGORY P WYATT
I.JNITED WATER IDAHO INC
PO BOX t90420
BOISE rD 837t9-0420
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]
SECRETA
CERTIFICATE OF SERVICE