HomeMy WebLinkAbout20150715UWI to Staff 34-37,43,49-58.pdf(208):i4$7s00
(208) 33669t2 (Far.)
McDevitt & Miller LLP
Lawyers
420 West Baonock Steet
P.O. Box ?5*83701
Boiser ldaho 83702
CheB. F. McDerritt
DeanJ. (foe) Millet
Celeste trL Millet
Yia llaad Delircty & US Mail
JeaoJeweil, Secrctary
Idaho Public Utilities Commission
472W. Washingtoa St
Boise,Idaho 83720
July 15,2015 C
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Re: [IS[I-W-15-01
Deat Ms.Jewell:
Enclosed for filing, please find an odgind and thtee (3) copies of United Watet I.laho's Third
Response to the Commission Staffs Second Production Request Nos. No. 34,35,36,37,43,49, 5A,
51,52,53,54,55, 56,57 aod 58.
Response to Request No. 52 is ptovided in electtonic fotmat oo ao enclosed disk
Kiodly tetum a file sramFed copy to me.
Very Truly Yours,
McDevitt & MillerLLP
Sauru^
DeanJ. Millet
DJM/hh
Cc: Uoited Water Idaho, Inc.
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ORIGINAL
Dean J. Miller (lSB No. 1968)
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564.-83701
Boise, lD 83702
Tel: 208.343.7500
Fax 208.336.6912
ioe@mcdevitt-m iller. com
Attomey for United Water ldaho lnc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
lN THE MATTER OF THE APPLICATION I Gase No. UW-W-15{1
OF UNITED WATER IDAHO INC. FOR
AUTHORIry TO INCREASE ITS RATES I UNITED WATER IDAHO'S THIRD
AND CHARGES FOR WATER SERVICE I RESPONSE TO SECOND
IN THE STATE OF IDAHO PRODUGTION REQUEST OF THE
COilIIUISSION STAFF
United Water ldaho lnc., ("United Wate/') by and through its undersigned
attorneys, hereby submits its Third Response to the Commission Staffs Second
Production Request Nos. No. 34, 35, 36, 37, 43, 49,50, 51, 52, 53, 54, 55, 56, 57 and
58.
DATED this \K_day of July, 2015.
UNITED WATER IDAHO'S THIRD RESPONSE TO SECOND PRODUCTION REQUEST OF THE
coiltitilsstoN STAFF - 1
Attomey for United Water ldaho lnc.
CERTIFIGATE OF SERVICE
I hereby certify that on tne -!5ftay of July,2015, I caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, lD 83720-0074
iiewell@puc.state. id. us
Donald L. Howell, ll
Daphne Huang
Deputy Attorney Genera!
ldaho Public Utilities Commission
P.O. Box 83720
Boise, ldaho 83720-0074
don. howell@ puc. idaho. sov
daphne.huano@puc. idaho.qov
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, lD 83702
bmpurdv@hotmail.com
Hand Delivered
U.S. Mail
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UNITED WATER IDAHO'S THIRD RESPONSE TO SECOND PRODUCTION REQUEST OF THE
coiriilsstoN STAFF - 2
UNITED WATER IDAHO INC.
CASE UWI-W.15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 34:
Please explain the reasons for the Company's proposed Rule 44 changes.
RESPONSE NO.34:
The Company's proposed Rule 44 change to separate all fire service line connections
from potable service lines relates to several concerns.
This change recognizes the Company's long practice of requiring service line separation
between potable and fire service functions.
The size and function of these services is quite distinct. The majority of fire service lines
in the system have been sized at a large diameter to meet required fire protection
needs. The larger size of fire service lines would rarely be appropriate for the secondary
use of potable water consumption due to meter accuracy constraints at relative
volumetric flow rates. Smaller and more appropriately sized service lines are installed
with a meter for that purpose.
Finally, in the interests of public safety, the Company will not typically turn off fire
services for any reason other than a customer needing to make repairs. ln the case of
an account requiring a shut off for non-payment, our current practice of requiring
separation on service lines allows for a potable line closure without compromising the
customer's available fire protection.
UNITED WATER IDAHO INC.
GASE UW|-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 35:
What are UWI's policies regarding disconnection and reconnection of residential fire
service customers? What policies, in particular, pertain to disconnection of residential
fire service customers for non-payment of either their residential or fire service water
bills?
RESPONSE NO.35:
The Company has no separate procedure for "residential fire service customers". The
procedures outlined here would apply to any customer, residential or othenrvise, with fire
service from the Company.
The Company will not typically turn off fire service for any reason other than a customer
needing to make repairs.
lf a customer calls to stop service because they are moving, and the same water
account includes a fire service, the Company would read the domestic water meter and
turn it off. Account billing for the fire service would be put on hold, while the physical fire
service would remain active for fire protection purposes.
The case of a fire service requiring a shut off for non-payment is quite rare. ln fact, the
Company does not have record of such an event occurring in recent memory. The
process outlined below would pertain to disconnection of a fire service customer for
non-payment of the bill for that service.
lf a fire service account required shut off due to
would be contacted to set up a payment plan.
The Company will make every effort to contact
numbers and addresses listed on the account.
non-payment, the customer
the customer given phone
1.
2.
Page 1 of 2
3.
4.
5.
UNITED WATER IDAHO INC.
cAsE uwr-w-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
lf the customer can be reached, the Company would attempt to make a payment
plan for the past due charges.
lf the event a customer cannot be reached, the Company would leave a blue tag
on the door for the customer to call the Company office by a certain date.
lf that deadline is not met, the Company would contact the Fire Marshall and
inform him/her of the proposed termination date for the property.
The Company would then put the account into the collection process and follow
rules 302.01 (Failure to Pay), 304.01 (lnitial Notice), 304.02 (Final Notice), and
304.03 (Additional Notices if applicable).
Page 2of 2
UNITED WATER IDAHO INL.
CASE UWI.W.15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 36:
According to the National Fire Protection Association, 'NFPA 13D is a residential
spdnkler design standard focused on one- and two-family dwellings and manufactured
homes. The intent is to provide an affordable sprinkler system in homes while
maintaining a high level of life safety."
a. Would the Company's proposed Rule 44 change apply to multiple use
customers who wish to install an NFPA 13D compliant system? lf so, how
would the Company's proposed Rule 44 changes affect residential customers'
ability to take full advantage of the cost savings afforded under NFPA 13D?
b. For customers wishing to install sprinkler systems conforming to NFPA 13D,
what would be the incremental costs associated with the Company's proposed
rule changes?
RESPONSE NO.36:
The Company's proposed Rule 44 change would not apply to customers who wish to
install a NFPA 13D compliant fire sprinkler system in a service line size of one-inch or
smaller that could adequately provide required volumetric flow for fire protection as
determined by the Fire Marshal (ie. standard one- or two-family dwellings, or
manufactured homes).
Given that the Company's proposed rule change would not apply to NFPA 13D
compliant residential fire sprinkler systems, there would be no incremental cost
adjustment to customers from the proposed rule change.
UNITED WATER IDAHO INC.
GASE UW!-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 37:
How many residential fire service customers does the Company currently have? How
many new residential customers applied for fire service in 2012,2013,2014, and 2015
to present?
RESPONSE NO. 37:
The Company currently has 139 active service agreements for residential unmetered
fire connections.
The following list shows the count of residential customers who applied for fire service in
the years 2012to present.
Year Customer Count
2012 2
2013 26
2014 13
2015 6
UNITED WATER IDAHO INU.
GASE UWI-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Roger Greaves/Kevin Doherty
REQUEST NO. 43:
Please provide the pro-forma (i.e., as described by the Company) plant additions and
retirements on a monthly basis (See Application, Greaves Dl Exhibit 3).
RESPONSE NO. 43:
Please refer to Company Exhibit 1 1, Schedule 3.
UNITED WATER IDAHO INC.
CASE UW!-W-l5-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
EEIIUEL}!o.+II:
Please provide a summary of new service inspections showing when turn-on orders are
received for new or previously inactive service connections, including cross-connection
assembly, backflow assembly, and initial testing inspections. Also provide the number of times
the Company has turned off new water services and/or issued notifications to the Plumbing
lnspector to stop issuance of occupancy permits for the years 2013 and 2014. As part of your
response, please provide an example of this type of correspondence.
EEENM9:
This process for new service inspections takes place in two phases with minor variances
depending on service size.
For the size range one-inch and smaller, construction acceptance is performed as part of the
final sub-division job-walk review at the end of a longer period of project inspection. The
Company's review of cross connection hazard for the sub-division takes place in the early
phases of planning and design acceptance. The final job-walk confirms construction is
completed to pre-approved plan sets.
At the conclusion of the job-walk, smaller services are still not active (lacking a meter).
The second phase of the process for final service connection takes place when a customer calls
to establish service. Following this call, a field service order is issued to place a meter for final
service.
For services larger than one-inch in diameter, the service inspection is performed as part of final
construction acceptance. Services of this size are installed with a pre-set meter and padlock
locking the service valve closed position. The lock is removed when an individual a customer
call to establish service. The Company is later contacted by the local plumbing inspector for its
Cross Connection Specialist to ride-along for the final certificate of occupancy inspection.
The Company has not issued a notification to the Plumbing lnspector to stop issuance of an
occupancy permit in the years 2013 or 2014.
UNITED WATER IDAHO INL.
CASE UWI-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 50:
Please provide a summary of the Company's existing Connections Service lnspections
Program including:
a. Service area prioritization strategy and rationale;
b. Number of staff assigned;
c. When the program was first initiated, when significant process or requirement
changes were made to the program and a summary of what those changes were.
RESPONSE NO.50:
The prioritization for service inspections in the service area as determined by the local
potential for cross connection hazard. The Company requires some form of backflow
protection on all commercial service lines. Greater focus is placed on industrial,
medical, and manufacturing facilities due to their nature of use and hazard potential.
For residential connections, higher priority is given to areas with access to alternate
irrigation water sources. These alternate sources are often pressurized. Meaning, a
simple pump setting change in-excess of Company system pressure would be sufficient
to cause a reversal of flow from a non-potable source into the public water supply
without protection.
The lowest priority is placed on residential service connections supplying lawn sprinkler
systems with Company potable water service. The main concern in these locations is a
phenomena known as 'reverse siphonage' in the event of a system depressurization on
the Company side of the service due to main break or fire demand. Without adequate
backflow protection, such conditions can allow contaminants to enter the public water
supply via home plumbing or irrigation systems.
Page 1 of2
UNITED WATER IDAHO INC.
CASE UWI-W-I5-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
The Company Cross Connection Control Program currently has 5 employees assigned
to its administration in various capacities.
The program was initiated in 1980 with an initial focus on high hazard commercial
service connections. Significant changes were made to the program in 2013 following
multiple residential cross connection related incidents. The primary emphasis of the
2013 program change was a focus on premise isolation of backflow hazards from the
public water supply.
Page 2 of 2
UNITED WATER IDAHO INL.
CASE UW!-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 51:
Please provide a detailed description of the current inspection process including: annual
and long-term work planning, pressure zone or specific neighborhood selection and
prioritization, field activities, field inspection forms, customer correspondence prior to
field work, customer correspondence following field work, and the results of the
inspections program for 2013,2014, and the first half of 2015.
RESPONSE NO. 51:
Since 2013 the Company's inspection process has focused on the area South and
West of Victory Rd. between Eagle Rd. and S.Cole Rd. in our certificated area. This
area covers the previously acquired 'South Count Water System'where the existence of
a previous Cross Connection Program is not known. The area has pressurized alternate
irrigation water available to home owners, posing a cross connection threat to the public
water system if not properly protected.
As a standard practice, customers are not contacted prior to inspection. The Company
inspector goes to the door to notify the customer of his intent to inspect the property for
a cross connection, or verify the proper backflow assembly is present and has been
tested. lf the customer is not at home, the inspection still takes place. No further contact
is made if the property has no issues. lf an issue is found, the inspector will leave a door
tag describing the problem with details for the customer to contact the inspector. Most
issues can be corrected without service interruption, however the inspector may
immediately terminate service to a property during his inspection if a dangerous
condition to public health is found to be present.
Most customers respond by phone to set up a meeting at their property. The majority of
issues are resolved at this point without sending a formal Determination Letter.
Page 1 of2
UNITED WATER IDAHO INL.
CASE UW|-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
The inspector documents all activities using a mobile handheld computer in the
company GIS system.
Attached you will find customer correspondence examples: "2013-2015 Notice of
Determination Letters.pdf', "2013 Notice of Termination Letters.pdf', and "Cross
Connection Customer Door Tag.pdf used for scheduling follow up customer meetings.
Page 2 of 2
United Water ldaho
Case UW-W-15-01
UNITED 1q/ATER IDAHO
CROSS CONNECTION CONTROL PROGMM
PO BOX 190420
BOISE, ID 83719
WWW. U NITEDWATER.COM/I DAHO/BACKFLOW
Request No. 51 Attachment 1
Page 'l of 2
Nick Robinson
11630 W. Oneida Dr.
Boise, Idaho 83709
September 13, 2013
CROSS CONNECTION CONTROL PROGRAM
NOTICE OF INTENT TO TERMINATE SERVICE
Dear Mr. Roblnson,
You have failed to make the corrections identified in the "Notice of Determination"
dated August 13, 2013 mailed to you, The Pressure Vacuum Breaker backflow
assembly at your residence is not installed and tested according to State Plumbing
codes. It is installed below ground in a box and has not been tested. A Pressure
Vacuum Breaker must be installed above ground at a height of 12 inches above the
highest sprinkler head. You were first notified back on Tlt$lt3 with a door tag
making you aware of the corrections required.
The United Water Idaho Inc. Rules and Regulations provide United Water Idaho with
the authority to terminate servlce'In the event a backflow assembly ls required, it
shall be lnstalled, malntained and tested at the customert expense. Fallure to
properly install, maintain or test the required devise will result in termination of
serulce to the customer ln accordance the IPUC's Customer Relations Rules and
Regulatlons" or if necessary to prevent a violation of federal, state or local safety or
health codes. (Ref: IDAPA 31.21,01, Rule 303)
Your lnaction is deemed a threat to public health. As a result, water service to the
following address will be turned off after9:00 am on the date listed below.
Service Address: 11630 W. Oneida Dr. Boise, Idaho
Shut Off Date: September 23,2013
The followlng actlon can be taken to avoid termination:r Contact Unlted Water Idaho with proof of proper lnstallatlon and testlng by a state
licensed backflow tester.
r Contact United Water Idaho to verifo physical disconnectlon from the cross connection
hazard.
United Water ldaho
Case U\M-W-15-01
UNITED WATER IDA}IO
CROSS CONNECTION CONTROL PROGMM
PO BOX 190420
BOISE, ID 83719
WWW. UNITEDWATER.COM/IDAHO/BACKFLOW
Request No. 51 Attachment 1
Page 2 ol 2
If you remain unsatisfied with the Company, you may file a complalnt with the
Idaho Publlc Utllities Commlsslon, PO Box 83720, Boise, ID 83720-0369, (208) 334-
0369.
UNITED WATER IdAhO
DENNIS FICKES
PROGMM ADMINISTMTOR
CROSS CONNECTION CONTROL PROGMM
PO BOX L90420
BOISE, ID 83719
TEL 208-362-7304
WWW. U NITEDWATER. COM UDAHO\BACKFLOW
United Water ldaho
Case UW-W-15-01
UNITED X+ITATER IDAHO
CROSS CONNECTION CONTROL PROGMM
PO BOX190420
BOISE, rD,837L9
TEL 208-362-7304
WWW. U NTTEDWATER. COM\IDAHO\BACKFLOW
Nick Robinson
11630 W. Oneida Dr.
Boise, Idaho 83709
August 13, 2013
UNITED WATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
NOTICE OF DETERMINATION
Request No. 51 Attachment 2
Page 1 of8
Dear Mr. Robinson,
If has been determined by United Water ldaho the Pressure Vacuum Breaker
backflow assembly at your residence is not installed and tested according to State
Plumbing codes. A Pressure Vacuum Breaker must be installed above ground 12"
above the highest sprinkler head. If you want your backflow assembly installed
below ground in a box you would have to use a Double Check Valve Assemble. A
door tag was left at your residence on7lt8ll3 by our Cross Connection Control
Specialist making you aware of the corrections required. He revisited your property
on B/6/L3 and the corrections have not been made. This Notice of Determination is
meant to notify you of the requirement for the correct installation and testing of
your back flow assembly on your sprinkler connection from your service line.
Failure to comply with this notice will result in denial or termination of water service
to your property.
Please contact Bill Thompson our Cross Connection Control Specialist at 362-7383
or myself at 352-7382 with any questions.
Yours sincerely,
UNTTED TVATER
DENNIS FICKES
PROGRAM ADMINISTRATOR
CROSS CONNECTION CONTROL PROGRAM
PO 8OX190420
BOISE, ID, 83719
TEL 208-362-7304
WWW, UN ITEDWATER.COM\IDAHO\BACKFLOW
Page 1
United Water ldaho
Case UWI-W-15-01
UNITED I.IIATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
PO BOX190420
BOISE, ID, 83719
TEL 208-362-7304
WWW. UNITEDWATER.COM\I DAHO\BACKFLOW
Steve Cady
5120 W. Cherry Ln.
Meridian, Idaho 83642
April23,20L4
Request No. 51 Attachment 2
Page 2 of 8
UNITED WATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
NOTICE OF DETERMINATION
Dear Mr. Cady,
It has been determined by United Water Idaho that your property at 3181 W. Alpine St.
Alplne Wheel Estates is require to have premise backflow protection. This is required to
protect the public drinking water supply from contamination from potential backflow.
You are required to lnstall a Double Check Valve Assembly behlnd the meter box on your
side of the water service line, With the assembly installed, it will be your responsibility to
have a state licensed Backflow Tester perform an initial test on the assembly, and send the
result to United Water Idaho. Annual testing will be an ongoing required following the initial
test.
On 4ll4l20t4 our Cross Connection Control Specialist, Stacy Stuart, contacted you by
phone making you aware of this requirement.
United Water ldaho's regulatory authority for enforcement of its Cross Connection Control
Program fall under the Idaho Rules for Public Drinking Water (IDAPA) 58.01.08 administered
by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho
Public Utilities Commission (IPUC) Rules and Regulations.
Please have the backflow assembly installed and test by 5/5/t4. Failure to comply with this
notice will result in denial or termination of water service to your property.
Please contact Stacy Stuart at 362-7383 or myself at 362-7382 with any questions.
Yours sincerely,
UNITED I',IATER
DENNIS FICKES
PROGRAM ADMINISTRATOR
CROSS CONNECTION CONTROL PROGRAM
BOISE, ID, 83719
TEL 208-362-7304
WWW. UN ITEDWATER. COMU DAHO\BACKFLOW
Page 1
United Water ldaho
Case UW-W-15-01
UNITED itrATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
PO 8OX190420
BOISE, ID, 83719
TEL 208-362-7304
WWW. UNITEDWATER.COMUDAHO\BACKFLOW
Steve Cady
5120 W. Cherry Ln.
Meridian, Idaho 83642
May 5, 2014
UNITED WATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
NOTICE OF DETERMINATION
Dear Mr. Cady,
Request No. 51 Attachment 2
Page 3 of 8
You contacted me by phone on 4/301t4 and asked for an extenslon until the end of May to
install the Double Check Valve assembly required on the servlce line of your property at
3181 W. Alplne St. ln Boise. I agreed to an extension until May 30, 2014. By this extension
date you will have the assembly installed and tested and the test results sent to Unlted
Water. You stated your contractor Mlke Rlce Excavatlon was not available until after the
middle of May because he was tied up on a project in Meridian.
United Water Idaho's regulatory authority for enforcement of its Cross Connection Control
Program fall under the Idaho Rules for Public Drinking Water (iDAPA) 58.01.08 administered
by the Idaho Department of Environmental Quallty, Uniform Plumbing Codes and the Idaho
Public Utilities Commission (IPUC) Rules and Regulations.
Please contact Stacy Stuart, Unlted Water's Cross Connection Control Specialist at 362-7383
when the backflow assembly is lnstalled and tested.
Yours slncerely,
UNTTED !^qATER
DENNIS FICKES
PROGRAM ADMINISTRATOR
CROSS CONNECTION CONTROL PROGMM
BOISE, ID, 83719
TEL 208-352-7304
WWW. U N TTEDWATER. COM\IDAHO\BACKFLOW
Page 1
United Water ldaho
Case UW-W-15-01
UNITED WATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
PO BOX190420
BOISE, ID, 83719
TEL 208-362-7304
WWW. U NITEDWATER.COMUDAHO\BACKFLOW
Request No. 5'1 Attachment 2
Page 4 of 8
Dennis Geving
5550 S. Lapwai Pl.
Boise, tdaho 83709
April t7, 2075
UNITED WATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
NOTICE OF DETERMINATION
Dear Mr. Geving,
It has been determined by Unlted Water Idaho that your property at 5550 S. Lapwai Pl. is
required to have irrlgation backflow protection or the plumbing fixture for the backflow
assembly removed. This is required to protect the public drinklng water supply from
contamination from potential backflow.
You are required to reinstall a Reduced Pressure Backflow Assembly behind the meter box on
your side of the water service line. With the assembly installed, it will be your responsiblllty
to have a state licensed Backflow Tester perform an initial test on the assembly and send the
result to Unlted Water ldaho. Annual testlng wlll be requlred followlng the lnitial test. The
second option is to dig up and remove the sprinkler maln valve, drain valve and standpipe
for the backflow assembly from the domestic water line.
On 4/28/20L4, 613/t4, 9/6/L4 and 2/7/t5 our Cross Connection Control Speclalist, Stacy
Stuart, contacted you by phone making you aware of this requirement.
United Water Idaho's regulatory authority for enforcement of its Cross Connectlon Control
Program fall under the Idaho Rules for Public Drinking Water (IDAPA) 58.01.08 administered
by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho
Public Utllltles Commlssion (IPUC) Rules and Regulations.
Please have the backflow assembly installed and tested or the plumbing fixture removed by5/tlt5. Failure to comply with thls notlce will result in denialortermination of waterserulce
to your property.
Please contact Stacy Stuart at 362-7383 or myself at362-7382 with any questions.
Yours sincerely,
UNITED VfATER
DENNIS FICKES
PROGRAM ADMINISTRATOR
CROSS CONNECTION CONTROL PROGMM
BOISE, ID, 83719
WWW. U NITEDWATER.COMUDAHO\BACKFLOW
Page 1
United Water ldaho
Case UWI-W-15-0'l
UNITED LAIATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
PO BOX190420
BOISE, ID, 83719
TEL 208-362-7304
WWW. UNITEDWATER.COM\IDAHO\BACKFLOW
Melissa Bryson
10681 W. Mohawk Pl.
Boise, Idaho 83709
April 21, 2015
Request No. 51 Attachment 2
Page 5 of 8
UNITED WATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
NOTICE OF DETERMINATION
Dear Mrs. Bryson,
It has been determined by United Water Idaho that your property at 10941 W. Mohawk Pl. is
required to have lrrigation backflow protection or the plumbing fixture for the backflow
assembly removed. This is required to protect the public drinking water supply from
contamination from potential backflow.
You are required to install a Reduced Pressure Backflow Assembly behind the meter box on
your slde of the water service line. With the assembly installed, it will be your responsibility
to have a state licensed Backflow Tester perform an initial test on the assembly and send the
result to United Water Idaho. Annual testing will be required following the initial test, The
second option is to dig up and remove the sprinkler main valve, drain valve and standpipe
for the backflow assembly from the domestic water line,
On 8/t5/20t4, 9/301t4, 7OlL3/14 and 7tl3/74 our Cross Connection Control Specialist,
Stacy Stuart, contacted you with a door hanger, in person or by phone making you aware of
this requirement.
United Water Idaho's regulatory authority for enforcement of its Cross Connection Control
Program fall under the Idaho Rules for Public Drinking Water (IDAPA) 58.01.08 administered
by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho
Public Utilities Commission (IPUC) Rules and Regulations.
Please have the backflow assembly installed and tested or the plumbing fixture removed by
514/L5, Failure to comply with this notice will result in denial or termination of water service
to your property.
Please contact Stacy Stuart at 362-7383 or myself at352-7382 with any questions.
Yours sincerely,
UNITED WATER
DENNIS FICKES
PROGMM ADMINISTRATOR
CROSS CONNECTION CONTROL PROGMM
BOISE, ID, 83719
Page 1
United Water ldaho
Case UWI-W-15-01
UNITEO TS,JATER IDA}IO
CROSS CONNECTION CONTROL PROGMM
PO BOX190420
BOISE, ID, 83719
TEL 208-362-7304
WWW. UN ITEDWATER.COMU DAHO\BACKFLOW
David Cullison
tOB74 W. Onondaga Dr.
Boise, Idaho 83709
April 21, 2015
Request No. 51 Attachment 2
Page 6 of 8
UNITED WATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
NOTICE OF DETERMINATION
Dear Mr. Cullison,
It has been determined by United Water Idaho that your property at 10874 W. Onondaga
Dr. is required to have irrigatlon backflow protection or the plumbing fixture for the backflow
assembly removed. This is required to protect the publlc drinking water supply from
contamination from potential backflow.
You are required to reinstall a Reduced Pressure Backflow Assembly behind the meter box on
your side of the water service line. With the assembly installed, it will be your responsibility
to have a state licensed Backflow Tester perform an initial test on the assembly and send the
result to United Water Idaho. Annual testing will be required following the initial test. The
second option is to dig up and remove the sprinkler main valve, draln valve and standpipe
for the backflow assembly from the domestic water line.
On 8/2812074, 9ll5lt4, 9/22/14 and 10/13/14 our Cross Connection Control Specialist,
Stacy Stuart, contacted you with a door hanger, in person or by phone making you aware of
this requirement,
United Water Idaho's regulatory authority for enforcement of its Cross Connection Control
Program fall under the Idaho Rules for Public Drinking Water (IDAPA) 58.01.08 administered
by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho
Public Utilities Commission (IPUC) Rules and Regulations.
Please have the backflow assembly installed and tested or the plumbing fixture removed by
5/4/L5. Failure to comply with this notice will result ln denial or terminatlon of water service
to your propefi.
Please contact Stacy Stuart at 362-7383 or myself at362-7382 wlth any questions,
Yours sincerely,
UNITED IO,TATER
DENNIS FICKES
PROGRAM ADMINISTMTOR
CROSS CONNECTION CONTROL PROGRAM
BOISE, ID, 83719
Page 1
United Water ldaho
Case UW-W-15-01
UNITED 11IATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
PO 8OX190420
BOISE, ID, 83719
TEt 208-362-7304
WWW. UNITEDWATER. COM\I DAHO\BACKFLOW
Kelly Rowles
10941 W. Mohawk Pl.
Boise, Idaho 83709
April 21, 2015
Request No. 51 Attachment 2
Page 7 of 8
UNITED WATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
NOTICE OF DETERMINATION
Dear Mr. Rowles,
It has been determined by United Water Idaho that your property at 10941 W. Mohawk Pl. is
required to have irrigatlon backflow protectlon orthe plumbing fixture forthe backflow
assembly removed. This is required to protect the public drinking water supply from
contamination from potential backflow.
You are requlred to lnstall a Reduced Pressure Backflow Assembly behind the meter box on
your slde of the water service line. With the assembly lnstalled, it will be your responsibility
to have a state licensed Backflow Tester perform an inltlal test on the assembly and send the
result to United Water ldaho. Annual testing will be required following the initial test. The
second optlon ls to dlg up and remove the sprinkler main valve, draln valve and standpipe
for the backflow assembly from the domestic water line.
On 8/18/2014,8127/14, and 9/L5/14 our Cross Connection Control Specialist, Stacy Stuart,
contacted you wlth a door hanger, by phone or ln person maklng you aware of this
requlrement.
Unlted Water Idaho's regulatory authority for enforcement of its Cross Connection Control
Program fall under the Idaho Rules for Public Drinking Water (IDAPA) 58.01,08 administered
by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho
Public Utllitles Commission (IPUC) Rules and Regulatlons.
Please have the backflow assembly installed and tested or the plumblng fixture removed by
5/4115, Fallure to comply with this notice wlll result in denial or termination of water service
to your property.
Please contact Stacy Stuart at 362-7383 or myself at362-73a2 with any questions.
Yours sincerely,
UNITED T"dATER
DENNIS FICKES
PROGMM ADMINISTMTOR
CROSS CONNECTION CONTROL PROGRAM
BOISE, ID, 83719
Page 1
United Water ldaho
Case UWI-W-15-01
Request No. 5 l Attachment 2
Page 8 of I
UNITED WATER IDAHO
CROSS CONNECTION CONTROL PROGRAM
PO BOX190420
BOISE, ID, 83719
TEL 208-362-7304
WWW, UNITED WATER.COM/IDAHO/BACKFLOW
Kim Sanderson
Perry Law, PC
2627 W Idaho St
Boise, Id 83702
April, Sth 2015
UNITED WATER IDAHO
CROSS GONNECTION CONTROL PROGRAM
NOTICE OF DETERMINATION
Dear Klm,
It has been determlned by Unlted Water Idaho that an approved backflow assembly
ls requlred at your servlce locatlon, Thls Notice of Determlnatlon is meant to Inform
you of state requirements to install, malntain, and annually test your requlred
backflow assembly (IDAPA 58.01. 08. 552. 05).
Detprr*,inatiqn :Q3lltirements fcr vgur prem ise;
2627 W Idaho St. Boise, Id.
Instali
Double Check Valve Backflow Assembly
(Approved by USC FCCCHR)
To be installed immediately after the
domestic water line enters the premise, but
prior to any sub-premise point of service
connections,..
Ongoing Test Requirements: Annual lnspected and testing by a state
licensed tester
Failure to comply with thls notlce wlll result in denlal or termination of water service
to your property.
Yours slncerely,
/r4,4/W
UNITED WATER.
STACY STUART
CROSS CONNECTION CONTROL PROGMM
PO 8OX190420
BOISE, ID, 83719
TEL 208-362-7304
WWW. U NITEDWATER.COM/IDAH O/BACKFLOW
Premise Servlce Location :
Determination:
Required Assembly Type:
Location for Installatlon :
Page 1
United Water ldaho
Case UW-W-15-01
Request No. 51 Attachment 3
Page 'l of 1
EMPLOYEE DATE
CUSTOMER NAME
ADDRESS
A representative from United Water
Idaho visited your propefty today to
look at your lawn sprinkler system.
We found one or more of the following
problems:
Improper or no backflow assembly
, installed.
Backflow assembly not tested.
Sprinkler system back feeding the
pressure irrigation system.
Sprinkler system connection in the
meter box.
n Sprinkler system is leaking.
tr other
Please contact our office immediately to
schedule an appointment
UNITED WATER IDAHO
CROSS CONNECTION CONTROL
PROGMM
PO BOX190420
BOISE, ID, 83719
TEL 208-352-7304
WWW. U NITEDWATER.COM/IDAHO/BACKFLOW
UNITED WATER IDAHO INC.. cAsE uw.w-l$ol
SECOND PRODUGTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
EIQUE9LN@:
Please provide the results of the inspections program according to: (1) pressure zone orneighborhood;
(2) number of facilities inspected; (3) number of prohibited cross-connection devices found; (4) number of
tested cross-connection assemblies; and (5) number of cross-connection assemblies with failed tests.
RESPONSE NO.52:
Please see the file 'CrossConn_by_Pzone.xlsx' for full details. Below is a summary of required devices by
pressure zone,
36th
Barber
Bogart
Boulder
Central First
Columbia WTP
Deer Path
East First Bench
East Go! ren
East Main
El Pelar
Floating Feather
Harris Ranch
Hidden Valley
Hulls Gulch
lsland Woods
Maple Hills
Pasadena
Scenic Cove
Second Bench
Shaw Mountain
South County
Spunring
Toluka
Upper Arrowhead
West First
West Gowen
West Main
18
72
1
L9L2
4
1
29
t2
1,
85
3
7
t7
1
27
1
4
3
2
t
5
13
1
t
13
1
305
1
1
4
13
5
3
UNITED WATER IDAHO INC.
CASE UW!-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 53:
Please explain whether the service or main line's meters have the ability to detect flow
directions, including reverse flow.
RESPONSE NO. 53:
All service and main line meters have the ability to demonstrate flow direction, including
reversal of flow. Essentially, meter dials roll ahead when water flows in a forward
direction, and roll backward in the event of a flow reversal. Newer automated meter
infrastructure (AMl) capable meters offer additional features such as; 'reversal of flow'
indicator prompts, frequency of reversal events, and volumetric measurement of unique
events.
The Company's current meter reading process includes dial comparison of previous and
current dial reading to identify flow reversals event for field review. Adoption of the
current automated meter infrastructure (AMl) standard will make alerts and response to
such events timelier by replacing bi-monthly reading visits with multiple automated daily
reports.
UNITED WATER IDAHO !NC.
GASE UWr-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 54:
Please explain whether the Company has detected reverse flow from a customer's system (i.e.,
back in to the Company's system). lf so, please provide information on how often this situation
has been detected since 2012, the customer outreach and correspondence used by the
Company, and the amount of time it took the Company to address the risks of detected, active
cross-connections.
EESElISEllo.s+:
Yes, the Company has detected reverse flow from a customer's system back in to the
Company's system.
Since 2012, the company has observed one such occurrence in the Hobble Creek Subdivision.
Standard meter reading procedures found that a water meter at a vacant residence indicated
negative consumption (reversal of flow). Follow up on this discovery found that an improper
backflow assembly had been installed at the home interconnected with a pressurized alternate
irrigation system. The backflow assembly had not been inspected as required by state law.
The company was contacted separately by Central District Health authorities regarding multiple
cases of localized stomach illness in the same area. The ldaho Department of Environmental
Quality was notified, and water samples were taken before the system was flushed.
Approximately 383 residences were provided with a hand delivered notice explaining what had
happened and steps taken by the Company. A contact number was provided for further
questions.
Following confirmation of clean water samples for earlier testing, a second customer notice was
prepared and hand delivered to customer's residences. Media outlets were updated. (Please
See Files 'Request 54 - Hobble Creek Notice 1.pdf and 'Request 54 - Hobble Creek Notice
2.pdf' as reference for outreach correspondence)
The company's response to this event lasted a total of 10 days. This does not include the
unknown period of possibly repeated flow reversal that may have occurred between bi-monthly
meter reading visits.
United Water ldaho
Case UW-W-15-01
Request No. 54 Attachment 1
Page 1 of2
IMPORTANT CUSTOMER NOTICE FROM
UNITED WATER IDAHO
Potentia! backflow incident in the Hobble Creek Subdivision
June 4,2012
What happened?
On Friday, May 25th, through our standard meter reading procedures, United Water
ldaho discovered that a water meter at a vacant residence at Plumbcreek & Elmspring,
in the Hobble Creek Subdivision, indicated negative consumption since it was last read
at the end of March. The next business day, May 29, a service technician inspected the
meter and verified the reverse flow. The technician immediately shut off water to the
residence, and noted the presence of a backflow prevention device, which was
inspected by our Cross-Connection Specialist the next day, May 30. The Cross-
Connection Specialist determined that an improper backflow device had been installed
at the home, and the unit had not been inspected as required by state law.
An untested or improperly installed backflow device has the potential to allow non-
potable water to flow into the water distribution system. ln such an event, there is the
potential for contaminated water from one location to make its way into the plumbing of
other homes in the vicinity.
On Friday June 1't, a number of free chlorine residual tests were conducted on samples
taken from the water mains in the vicinity of the vacant home. Free chlorine residuals
indicate the presence of chlorine, which is used as a disinfectant in the drinking water to
protect against harmful bacteria. The results ranged from 0.7-1.0 ppm (parts per
million), well in excess of the federal drinking water standard of 0.2 ppm.
Today, June 4, six more chlorine residual tests were conducted, and those results again
fell within 0.8-1.0 ppm. ln addition, six coliform bacteria samples were taken, and we
anticipate test results by Tuesday, June 5. Our crews have also flushed water mains in
the area.
(over)
United Water ldaho
Case UW-W-15-01
Request No. 54 Attachment 1
Page 2 ol 2
What should ! do?
o United Water ldaho and the ldaho Department of Environmental Quality
recommend that you turn up your water heater to the highest temperature
possible for several hours and then flush the water heater. Remember to return
your water heater to its previous seff,ng after flushing.o You should also flush water softeners, ice makers or any other appliances
hooked to your home's water system.o lf there are any filters installed in these appliances or devices, we recommend
replacing the filters as well.
What is being done?
As a result of the free chlorine residuals and flushing in the area, we currently believe
your water is safe to drink.
United Water ldaho will continue to monitor the affected area and update you as events
warrant.
For more information, please contact United Water ldaho at362-7328.
This notice is being sent to you by United Water ldaho.
State Water System lD#: 4010016. Date distributed:614112.
United Water ldaho
Case UW-W-15-01
Request No. 54 Attachment 2
Page 1 of 1
IMPORTANT CUSTOMER NOTICE FROM
UNITED WATER IDAHO
Hobble Creek Subdivision Water Update
June 5,2012
Dear United Water ldaho Customer:
As you know, we believe a backflow event occurred in the Hobble Creek Subdivision,
originating at a vacant home at Plumcreek and W. Elmspring. The event was the result
of an improper and untested backflow assembly. The purpose of this notice is to update
you on the latest information.
We have received the test results from the six coliform bacteria samples taken in the
water distribution system in Hobble Creek on Monday, June 4. We are pleased to
inform you that every sample came back clean, with no evidence of harmful bacteria in
the water. These test results confirm that your water is safe to use for all purposes.
lf you are still concerned about possible residual effects of any non-potable water in
your home, we suggest you take the following steps:
o United Water ldaho and the ldaho Department of Environmental Quality
recommend that you turn up your water heater to the highest temperature
possible for several hours and then flush the water heater. Remember to return
your water heater to its previous seffrng after flushing.. You should also flush water softeners, ice makers or any other appliances
hooked to your home's water system.. lf there are any filters installed in these appliances or devices, we recommend
replacing the filters as well.
This event is a reminder to get your home's backflow prevention device tested annually.
State-certified testers can be found in the phone book under "Backflow." For backflow
information visit www.unitedwater.com/idaho/backflow. lf you have any questions,
please contact United Water ldaho a|362-7304.
This notice is being sent to you by United Water ldaho.
State Water System lD#:4010016. Date distributed: 6/5/12.
UNITED WATER IDAHO INC.
CASE UW|-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 55:
Testimony submitted in Thompson's Dl, page 5, lines 12 - 16 describes a Company-
proposed clarification for Rule 15 that "provides the Company with authority to
discontinue service without prior notice when a dangerous condition is present." Please
explain the following:
'a. Rule 15 states that "ln the event a backflow prevention device is required, it
shall be installed, maintained and tested at the customer's expense." Please
explain whether the current IDEQ rules require "backflow prevention devices"
or "backflow prevention assemblies," and explain under what circumstances
each (i.e., device vs. assembly) might be required.
b. Has the Company located backflow prevention devices or assemblies that are
not authorized? lf so, are these owned by the Company or by customers?
And, has the Company obtained testing data, including water main water
quality data, confirming that a cross-connection of contaminated water has
occurred? lf so, please provide the water quality test results and additional
details of the situation.
c. Has the Company issued any correspondence to customer-owners of un-
authorized backflow prevention devices or backflow prevention assemblies? lf
so, please provide example copies.
d. Has the Company developed or prepared any correspondence of other written
materials to provide to customer-owners of un-authorized backflow prevention
devices or assemblies? lf yes, please provide copies.
Page 1 of3
UNITED WATER IDAHO INC.
CASE UWI-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
e. Has the Company entered into compliance schedules with customers to repair
or replace backflow prevention devices or assemblies that are not authorized?
lf so, how are the compliance schedules developed and who, within the
Company, authorizes them?
f. Under normal water main pressure conditions, is there an immediate danger of
water main contamination due to an un-authorized backflow prevention device
or assembly? Under what conditions might an un-authorized backflow
prevention device or assembly cause an immediate danger to water main
contamination? How frequently do these situations occur? Please provide the
dates, durations, pressure zone locations, and water quality test data that
d emonstrate the occurrence of water-mai n cross-con nections contam ination.
RESPONSE NO. 55:
The terms "backflow prevention device" and "backflow prevention assembly" are used
interchangeably to describe a mechanical valve assembly (or air gap) designed to limit
the potential for flow reversal in a hydraulic fluid system. Current IDEQ rules for public
water system (http://adminrules.idaho,qov/rules/currenU5S/0108.pdf , 543 and 552)
outline facility and design standards for cross connection control. These standards
include 'list of approved assemblies' from the referenced standards body USC
Foundation.
Yes, the Company has located unauthorized backflow prevention assemblies. Please
see the Company response to Request No. 54 describing the discovery of an improper
assembly in the Hobble Creek subdivision. This includes details on the results of water
quality testing during this event.
Yes, the Company has issued correspondence to customer-owners of un-authorized
backflow prevention assemblies. Please see the Company response to Request No. 52
detailing all backflow field determinations since April2014.
Page 2 of 3
UNITED WATER IDAHO INC.
CASE UWI-W-15-01
SECOND PRODUGTION REQUEST OF THE COMMISSION STAFF
Yes, the Company has prepared correspondence to provide to customer-owners of un-
authorized backflow prevention devices or assemblies. Please see the Company
response to Request No. 51 for examples of correspondence.
Yes, the Company has entered into compliance schedules with customers to repair or
replace unauthorized backflow prevention assemblies. Please see the Company
response to Requests No. 51 and 52 detailing field agreements for correction, and
formal letters of determinations 2013-2014.
Under normal water main pressure conditions, the immediate danger of contamination
due to a cross connection hazard always exists. This would include hazards such as un-
authorized backflow prevention assemblies, along with other unprotected cross
connection hazards. The Company response to Request No. 54 describing its discovery
of an improper assembly in the Hobble Creek subdivision is an excellent example of
conditions where an un-authorized backflow prevention assembly caused immediate
danger public health. This includes details of that response include results from follow
water quality testing during this event.
Page 3 of 3
UNITED WATER IDAHO INC.
GASE UW!-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 56:
Has the Company conducted any surveys or assessments to determine how many
systems lack required cross-connection equipment? lf not, why not?
RESPONSE NO. 56:
Yes, the Company has conducted field surveys to determine if systems in various parts
of the water system lack required cross-connection equipment.
UNITED WATER IDAHO INL.
GASE UWI-W-I5-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Roger Greaves
REQUEST NO. 57:
Has the Company conducted any surveys or assessments to determine how many
cross-connection devices lack necessary testing? lf not, why not?
RESPONSE NO. 57:
Yes, the Company has conducted surveys and assessments to determine how many
cross-con nection d evices lack necessary testi ng.
UNITED WATER IDAHO INC.
CASE UW!-W-15-01
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Roger Greaves
REQUEST NO. 58:
Please provide the make, model, and price of Radio Frequency Meter (RFM) and
Automated Meter lnfrastructure (AMl) installed by the Company for each pressure zone,
including how many of each type have been installed.
RESPONSE NO. 58:
The Company has various radio frequency meter r"r,iing endpoints in the system
configured for Automated Meter Reading (AMR), also known as "walk or drive by
reading".
ITRON 60W and 100W Radio Frequencv Endpoints
Average Price $70 per Endpoint
Please see the attached file 'Request 58 - RF Endpoints by Pressure Zone.xlsx' for a
count of ltron radio endpoints by pressure zone.
The Company recently adopted a new standard for radio based meter reading without
driven collectors. lnstallation of components for this Automated Meter lnfrastructure
(AMl) system are underway in 2015. The system consists of two main components:
Radio Frequency Endpoints associated with water meters, and stationary tower-
mounted network collectors placed around the certificated area. Network collectors will
be installed this summer, followed by the first radio endpoints in the fall of 2015. Cost of
these system components are detailed here.
Sensus SmartPoint Module (520M) Radio Frequencv Endooint for Sinole Meter Settinq
Average Price $74.36 per Endpoint
Sensus SmartPoint Module (520M2) Radio Frequencv Endpoint for Dual Meter Settino
Average Price $88.14 per Endpoint
Sensus M400 Radio Frequencv Network Collectors
Each stationary collector has a unit cost of $18,000
A total of ten facility mounted M400 collectors will be needed for system meter reading.
United Water ldaho
Case No. UWI-W-OI
Request No. 58-Attachment
Pressure Zone
Radio
Endpoint
iount
36th 3
Aldape 27
Andy's Gulch 1
Avimor 1 21
Avimor 3 79
Barber 442
BIF tL2
Bitterbrush 2
Boeart 89
Bogus 25
Boulder 74
Broken Horn 7
Central First 1,7t7
Central Park 10
Chardie 1
Chuckar Butte 1 75
Chuckar Butte 2 1
Clairmont 11
Columbia WTP 101
Crestline 56
Curling 1
Deer Path 36
East First Bench 430
East Gowen 79
East Main 1,257
El Pelar 78
Eyrie 13
Federal 20
Floatins Feather 185
Pressure Zone
Radio
Endpoint
Count
Harris Ranch 281
Hidden Sprinss 2
Hidden Valley 35
Hiehland View 30
Hillsboro East 2
Hillsboro West L7
Holcomb 70
Horizon 77
Hulls Gulch 3
lsland Woods 777
Keldoon 1
Lake Forest 2
Lower Arrowhead 5
Lower Boulder Heiehts 72
Lower Braemere 45
Lower Danmor 26
Lower Ginzel 27
Lower Quail 3
Maple Hills 746
Mesa 16
Micron 35
Middle Arrowhead 2
Middle Ginzel 7
Middle Quail 4
Montclair 11
Morning Side 2
Nativa Terra 8
North Mountain 19
Old Pen Lower 1
0regon Trail 60
Pressure Zone
Radio Endpoint
3ount
)utlook 1
)asadena 18
)ierce 7
)romontory Ridt 20
Ra nch 1
Rideeline 3
Roser Heiehts 8
Scenic Cove 8
Second Bench 26s
Shaw Mountain 9
Simplot 16
Skylark 7
South County t,729
Spurwing L75
Surprise Valley 577
Ten Mile Ridge 6
Toluka 11
Iwilight 8
Upper Arrowhea 57
Upper Boulder 3
Upper Boulder F]5
Upper Braemere 8
Uooer Danmor 6
Uooer Ginzel 1
Upper Quail 2
Upper Ridge 1
West First 2,5L8
West Gowen 227
West Main 574