REBUTTAL TESTIMONY OF JULIA FORGUE, P.E. ON BEHALF OF THE CITY OF NEWPORT, UTILITIES DEPARTMENT, WATER DIVISION
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1 REBUTTAL TESTIMONY OF JULIA FORGUE, P.E. ON BEHALF OF THE CITY OF NEWPORT, UTILITIES DEPARTMENT, WATER DIVISION In re: City of Newport Utilities Department, Water Division Docket No. 418 March 1, 010
2 Q. Please provide your full name, title and business address for the record. A. Julia Forgue, P.E. I am employed by the City of Newport where I serve as Director of Utilities. My business address is 70 Halsey Street, Newport, RI. Q. Are you the same Julia Forgue who submitted pre-filed direct testimony in this docket? A: Yes I am. Q. What is the purpose of this testimony? A. I would like to respond to certain points or conclusions that were made in the pre-filed testimony of William McGlinn. Q. Do you agree with Mr. McGlinn s general description of the Newport Water System? A. I agree with Mr. McGlinn s general description of the interconnections between Newport Water and its wholesale customers, Portsmouth Water & Fire District and Naval Station Newport. Mr. McGlinn correctly indicates that Newport water has three (3) pressure zones. Q. Mr. McGlinn indicates that Newport Water did not correctly respond to PWFD -4, do you agree? A. As set forth in the answer to PWFD -4, the current management staff at Newport Water did not have information from 1989 available. Therefore, we don t dispute PWFD s records regarding the use of Mitchell Lane connection during this time. In addition, Newport Water did overlook the December 005 use of the Mitchell Lane connection when approximately 613,000 gallons was used by Newport Water from this connection to top off the Goulart Lane Tank while a water main break was repaired on West Main Road at Forest Avenue which required the Forest Avenue pump station to be out of service. 1
3 Q. Do you agree with Mr. McGlinn s assessment of PWFD as a customer of Newport Water? A. No I do not. I refer my pre filed testimony regarding Newport Water operating as one system rather than as two separate systems. I do agree emergency connections are just that, only used in an emergency, at which time they are invaluable. Q. Does this conclude your testimony? A. Yes it does.
4 CERTIFICATION I hereby certify that on March 1, 010, I sent a copy of the within to all parties set forth on the attached Service List by electronic mail and copies to Luly Massaro, Commission Clerk, by electronic mail and regular mail. Parties/Address Distribution Phone/Fax Julia Forgue, Director of Public Works jforgue@cityofnewport.com Newport Water Department resten@cityofnewport.com Halsey St. Newport, RI 0840 lsitrin@cityofnewport.com Jon Hagopian, Esq. Dept. of Attorney General 150 South Main St. Providence, RI 0903 Harold Smith Raftelis Financial Consulting, PA 511 East Blvd. Charlotte, NC 803 Gerald Petros, Esq. Hinckley, Allen & Snyder 1500 Fleet Center Providence, RI 0903 William McGlinn Portsmouth Water & Fire District 1944 East Main Rd. PO Box 99 Portsmouth, RI 0871 Audrey VanDyke, Esq. Naval Facilities Engineering Command Litigation Command 1314 Harwood St., SE Washington Navy Yard, DC Dr. Kay Davoodi, P.E. Utility Rates and Studies Office NAVFACHQ- Building Patterson Ave SE Washington Navy Yard, D.C Jhagopian@riag.ri.gov sscialabba@ripuc.state.ri.us pdodd@ripuc.state.ri.us Amancini@ripuc.state.ri.us dmacrae@riag.ri.gov Mtobin@riag.ri.gov Hsmith@raftelis.com Hhoover@raftelis.com gpetros@haslaw.com dmarquez@haslaw.com jmansolf@haslaw.com wmcglinn@portsmouthwater.org ext. 4 Audrey.VanDyke@navy.mil Khojasteh.davoodi@navy.mil Larry.r.allen@navy.mil Maurice Brubaker Brubaker and Associates, Inc. Jerry Mierzwa Exeter Associates, Inc. Thomas S. Catlin Exeter Associates, Inc. mbrubaker@consultbai.com Jmierzwa@exeterassociates.com tcatlin@exeterassociates.com
5 Christopher Woodcock Woodcock & Associates, Inc. 18 Increase Ward Drive Northborough, MA 0153 File an original and nine (9) copies w/: Luly E. Massaro, Commission Clerk Public Utilities Commission 89 Jefferson Blvd. Warwick, RI /s/ Joseph A. Keough, Jr., Esquire # 495 KEOUGH & SWEENEY, LTD. 100 Armistice Boulevard Pawtucket, RI 0860 (401)
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