960530v1.docx

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
STATEHOUSE MAIL
BOISE,  IDAHO  83720-6000
[phone]
ATTORNEY FOR THE COMMISSION STAFF
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION
IN THE MATTER OF THE APPLICATION OF)
UNITED WATER IDAHO, INC. FOR APPROVAL) CASE  NO.  UWI-W-95-2
OF AN AGREEMENT TO EXCHANGE)
SERVICE AREAS AND TO AMEND AND)FIRST PRODUCTION
REVISE CERTIFICATE OF CONVENIENCE)REQUEST OF THE
AND NECESSITY NO. 143.)COMMISSION STAFF
)TO THE CITY OF GARDEN
_____________________________________________)CITY, IDAHO
The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests that the City of Garden City provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before FRIDAY, JUNE 7, 1996.
This production request is to be considered as continuing, and the City of Garden City 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.
Please provide answers to each question; supporting workpapers 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. 1:  On page 10, lines 9 through 11 of his Reconsideration Testimony,
Mr. Dearden describes the need for a new pumping facility to augment flows during the peak season.  Please describe the proposed pumping facility and the estimated cost.  How does
Mr. Dearden's proposal differ from the pressure improvement pumping facility described by
Mr. Brown as part of Alternative No. 3 on page 5 of his Direct Testimony filed for the first hearing in this case?
Request No. 2:  If Garden City installs a new pumping facility and the Exchange Agreement is not approved, how will costs be allocated between in-city and North State Area customers?
Request No. 3:  Randy Dearden of Garden City and Jeremiah Healy of United Water Idaho discuss in their Reconsideration Testimony a joint meeting held by Garden City and United Water Idaho on May 16, 1996.  Please provide a copy of the announcement of this meeting.  Also, please indicate who the announcement was mailed to and whether there is a list of attendees and a transcript or other record of the proceedings.  Please provide a copy of same if they exist.  Please indicate which attendees appeared in a representative capacity.

DATED at Boise, Idaho, this              day of  May 1996.
______________________________________
Scott Woodbury
Deputy Attorney General
Technical Staff:
Randy Lobb
Engineering Section Supervisor
Judy Stokes
Utilities Compliance Investigator
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