20051110Comments.pdf

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t;UBLICA T TOR N E Y S AT LAW jf
\ L 'j i-I !~:' ~;c Ot'H'lI S S ! 0 HMolly 0' Leary
Tel: [phone] Fax: [phone]
molly0richardsonandoleary- com
O. Box 7218 Boise. TO 83707 - 515 N. 27rh St. Boise, TO 83702
November 9 2005
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
Boise ID 83720-0074
Hand Delivered
RE: Case No. EAG-05~ (/3
Dear Ms. Jewell:
I am enclosing an original and five (5) copies of COMMENTS OF EAGLE
WATER COMPANY, INC'S. in response to the Idaho Public Utilities
Commission s Proposed Order in the above case.
Sincerely,~Cus'\~~
Nina Curtis
Richardson & O'Leary, PLLC
"'r-- I I' \' - IJ.- .
Molly O'Leary (ISB No. 4996)
Richardson & O'Leary PLLC
515 North 27th Street
O. Box 7218
Boise, Idaho 83707
Telephone: [phone]
Fax: [phone]
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:U FUGLIC
; r iiITiES Cm-jf'1!SSIOl1
Attorneys for Eagle Water Company, Inc.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTTER OF THE PETITION OF )HILL VIEW DEVELOPMENT
CORPORATION TO OBTAIN WATER
SERVICE TO COVENANT HILL
SUBDIVISION, AN AREA WITHIN THE
CERTIFICATE BOUNDARIES OF BOTH
EAGLE WATER COMPANY, INC. AND
UNITED WATER IDAHO, INC.
CASE NO. EAG-W-OS-
UWI-OS-
COMMENTS OF EAGLE WATER
COMPANY, INC.
COMES NOW, EAGLE WATER COMPANY ("Eagle Water ), and files the following
Comments in response to the Idaho Public Utilities Commission s Proposed Order granting
service of Covenant Hill Subdivision to United Water of Idaho, Inc.
CO MMENTS
Eagle Water is ready, willing and able to provide service to Covenant Hills Subdivision.
Eagle Water is currently able to provide more than adequate fire flow protection to the
subdivision. See Eagle Water Exhibit No., attached.
Eagle Water is currently negotiating with two landowners for an easement for a l2-inch
mainline from its Well No.6 to the subdivision and will have these easements executed and
recorded by February 16, 2006. Once the easements are executed and recorded, Eagle Water
COMMENTS OF EAGLE WATER COMPANY -
will begin construction of the mainline and estimates that this line will take three weeks to be
placed in service. See Eagle Water Exhibit No., attached.
Provision of service to the Covenant Hills Subdivision is critical to Eagle Water s overall
system plan. Id. Tying Eagle Water s Well No.6 into its l2-inch mainline on Floating Feather
Road will not only increase fire flow protection to the Covenant Hills Subdivision, it will also
augment the water supply from Wells 1 and 2, which will, in turn, serve to augment the water
supply from Well No.4 that can be dedicated to service of the eastern portion of Eagle Water
service area. This, in turn, will help to alleviate low pressure problems in the upper elevations of
the Eagle Springs Subdivision.
Although the Idaho Department of Environmental Quality (DEQ) sent a letter to Eagle
Water on September 7 2005, indicating that it would not authorize additional connections to the
Eagle Water system absent additional information from Eagle Water regarding the adequacy of
its supply sources to service additional connections, DEQ has since concluded, based on the
contents of Eagle Water Exhibit No., and discussions with Eagle Water s engineer, James M.
Rees, P., that Eagle Water does indeed have sufficient supply to service Covenant Hills
Subdivision. Consequently, DEQ has agreed to lift its informal service connection "moratorium
as it pertains to the Covenant Hills Subdivision area. See Eagle Water Exhibit No., attached.
DATED this 9th day of November, 2005.
Richardson & O'Leary P .L.L.C.
Water Company, Inc.
COMMENTS OF EAGLE WATER COMPANY - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 9th day of November, 2005, the COMMENTS
OF EAGLE WATER COMPANY, INC. was sent to the following parties as shown:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
( ) U.S. Mail, Postage Prepaid
(X) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( ) Electronic Mail
City of Eagle
City Hall
310 East State Street
O. Box 1520
Eagle, Idaho 83616
(X) U.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
( ) Electronic Mail
Hillview Development Corporation
150 E. Aikens, Suite A
Eagle, Idaho 83616
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( ) Electronic Mail
Idaho Department of Environmental Quality
1445 North Orchard
Boise, Idaho 83706
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( ) Electronic Mail
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock
Boise, Idaho 83702
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( )
Facsimile
( ) Electronic Mail
Signed ~\f\ WJ\--I1
Nina M. Curtis
CERTIFICATE OF SERVICE - 1
ll/f1:::/Lf1f1~
Cify:
Date:
TilDe;
Location:
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Clear C"eel~ Sub,
Rating Rep.
ResuHs:
Hydrant Flow:
Flow ~ 20 PSI:
Pressure (ffi 1500 GPM:
~"'--_.,
2125
2576
HyclraI1t Number
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Witnesses: Kh1: Eagle Fire Dept. Jim Rees: MTC, Inc.
Data Inpul:
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90 psi Resj(jllal 41 psi
22 P$(Diameler 4- 1/2 inches
Flowing 2125 gpln
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EAGLE WATER EXHIBIT 1
Mr'INC~
CONSULTING ENGINEERS, SURVEYORS, ANDPLA'NNERS'
707N.27THSI BOISE,IDAHO83702':3113 [phone] FAX (208) 343~8967;JII'
CONSULTING ENGINEERS FOR EAGLE WATER COMPANY
November 2, 2005
, Mr.Monty MarchusPE
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1410 N. Hilton
Hoise Idaho :83706-1255
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Dear Monty;
I'm writing this request onhehalfof Eagle Water Company for a one time waiver of the
moratorium on additional subdivisions in the area served by Eagle Water Company to
provide fo:rservice to proposed Covenant Hills Subdivision.
. '
.~ercI~Viewing.,the:PUIIl p~g,rec:ordsofthe;four ~E4~;E&g1 e CoD1.pany . .wells wecifolIDd the
'foll()wing:
- '. ---- -- -- . .
1. w,elInumoer6i1idnolpump mor~tb.ant5%0:fitsratedcapaCitydWingfb.e '
July 2005.peakperiod. '
-- --
2. ,'fhere.was"nothing.,:wrongwi,th:tbjs weUor.equip1Il,ent
3. Wellnumber.4 '~asPJ)ID,pingati~6% 'of'itsmaximum,ratedcapacity
.for/thewhqle.ho;ursthis'~ap1~" y~nns didn.ot;acco:u:ntfor peaks 'wmch
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10 .:Mostofthisproposed'Covenant Subdivisionis .ffi --the Eagle Water. Company
seIWice.area.
The ,resolution.ofthelow-pressurep!()bleminthe Northeastportion oftbesystemJies in
improving that part of the system. I111provingthesystemnetworkiilghasbeeniIit1fe
c' EAGLE WATER EXIIIBIT 2
planning for several years and one of the elements is to make a connection from well
number six (6) to the existing 12" line in Floating Feather Road. The plan is now to route
this connection thruCovenant Hill Subdivision.
. .
Production Well #6 was planned and sized to service areas in Section 7 that are no
longer in the Eagle WaterCompany service area. Production sizingforthe well included
those areas of Section ?and SectionS as wellasadditionaLcapacity for the entire service
area. At the same time, the 12'"inch interconnection with the .1J2-:-inch line in Floating
Feather was planned. The logic of this can be seen on the attached diagram, as the
comiectionwillprovidea criticalsecondconnection.of Well #6-toth,eE~gleWater
Company~ystem. The pr()Po~ed connectioIiis plannedto.continuethe,existit1g 12-inch
line North from Van Engelen;EstatesthroughBakers Acres toPrpPosed'CovenantHill
Subdivisipn thence throqghCovenantHill to -the existing line in Floatirtg iF ea:ther Road.
The .proposedadditionalnetworking of the system couldoIlly improve the
system;-S-peiformance.---------_u
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Thankyou'very much.for your consideration-of this .proposal.
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JamesM. 'Rees)PE .
Consulting Engineer for the Company
Cc-Bob'DeShazo
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.' STATE OF IDAHO
, DEPARTMENT OF
' ENVIRONMENTAL QUALITY
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Dirk Kempthorne, Governor
Toni Hardesty, Director
1445 N,Orchard. Boise, Idaho 83706. (208) 373..0550
November 9, 2005
Mr. Robert DeShazo
Eagle Water Company
O. Box 455
Eagle, ID 83616
RE:Revision to DEQ's September 7 2005 letter regarding system capacity
Dear Mr. DeShazo:
The Department of Environroental Quality s (DEQ) September 7 200S letter expressed COncerns
and conclusions about Eagle Water Company s production capacity. In summary, the letter
stated: "DEQ will not be able to approve additional connections to this water system until an
additional source or sources are provided that are large enough to meet minimum state
requirements. "
The Eagle Water Company engineer, Jim Rees, P.E. ofMTC Inc., recently presented DEQ with
information on an unusual situation. A Proposed Order is before the Idaho Public Utilities
Commission to remove part of the Covenant Hills Subdivision from the Eagle Water Company
certificated service area and place all of the subdivision within the United Water Idaho Inc.
certificate::d service area. The proposal is based. in part, on the above~referenced letter. Mr. Rees
explained that this change in service area would limit future effectiveness of Well No.6, one of
the largest wells in the system, and in turn have a negative impact on all customers served by
Eagle Water Company. The information provided by Mr. Rees is summarized below.
Well No.6 produces only 15% of the rated capacity of the pumps (2000 gpm), apparently due to
distribution system limitations (bottlenecks and an incomplete loop). This occurred even while
pressure problems plagued part ofthe system last summer. Mr. Rees also noted that ifneeded
and according to test pump data, Eagle Water Company could increase that well capacity to 2500
gpm by changing the pumps. Eagle Water Companis plan had b~en to complete the loop from
Well No.6 to the rest of the system by building a 12~inch main north to the existing 12~inch main
on Floating Feather. much of it through Covenant Hills Subdivision. However, if Covenant Hills
Subdivision is removed from the Eagle Water Company certificated service area, the needed loop
cannot be built as planned. That in turn could make permanent the reduced well capacity
described above.
DEQ believes this analysis is correct. If Covenant Hills Subdivision remains in the Eagle Water
certificated service area, the loop could be completed as planned and.there may be other benefitsas well.
' " ' '
EAGLE WATER EXHIBIT 3
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Mr. Robert DeShazo
Eagle Water Company
November 9, 2005
Page 2
1. We understand that the developer of Covenant Hills Subdivision will build approximately
55% percent of the proposed 12..,inch main, which should be a positive impact on rates for
existing customers.
2. There are seveni1 swalLpublic water systems in the vicinity of Well No.6 that have only
one source, no standtiypower, or both. It is also possible that those wells could run into
future quantity or qualityprQblems. Allowing Eagle Water Company to reach full
capacity in this area may provide options for these small public water systems should
future problems occur.
In swnmary, DEQ understand,s that the Idaho Public Utilities CotnJ11ission is considering other
factors with regard to Covenan,LHi11sSu,1;Idivision. However, w~ now believetbatwith regard to
our rules and au.thorities, Eagle Water Coi1'ip1U;iy's Well No.6 has capacity to serve Covenant
Hill Subdivision and benefit the entire system at theBaIne timebypariially alleviating the
capacity concerns stated in our September 7, 2005 letter. We will accept a Will Serve Letter for
this project under the following conditions:
1. We understand that e~ements for main construction are being negotiated at this time.
The letter must include documentation that a) all necessary e~ements have been secqred
and b) that funding h~ ;:lvailable or guaranteed in a manner consistent with a timetable for
actual service to Covenant Hill Su\)division.
2. DEQcannot accept additional Will Serve Letters until the h~sue5 mentioned in the
September 7,2005 are resolved.
Please call Monty Marchus with any questions at 373-0560 or via e..,mail at
moJlty.lnarchlls~deq.idaho.gov . You may also contact me at 373-0550.
Sincerely,
'-.
7/J~~ 1/fl ,- L-----
Michael R. McGown
Acb:ninistrator
Boise Regional Office
MGM:ve: H:\Eagle Water CompanyWmd.uction capacity 9-05 - up~te.doc
- ----'
Mr. Robert DeShazo
Eagle Water Company
November 9, 2005
Page 3
cc:Mayor Nancy Merrill, City of Eagle
Charles W. Ariss, P ., PEQ Regional Engineering Manager
Tiffany Floyd, DEQ Drinking Water Manager
Lance Nielsen, DEQ State Qrinking Water Program Manger
Monty G. Marchus, P., DEQ Staff Engineer
Randy Lobb, PUG
Jim Rees, P ., MTC Engineering
Reading File, Source File #l-eng
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