Petitioner ʻIewe Hanau O Ka Ainaʻs Reply in Support of its First Amended Petition

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,J0,:, AQUA ENGINEERS AN EMPLOYEE OWNED COMPANY 1. Introduction On September 1, 1999 Aqua Engineers Inc. signed its first contract with Punalu'u Water and Sanitation Corporation to provide operation and maintenance services for their potable water and wastewater systems. Over the next 21 years Aqua Engineers Inc. operated the Punalu'u Water and Wastewater systems within the State of Hawaii, Department of Health guidelines as supported by ownership. The scope of this report will focus on providing ownership an up to date description of operations, infrastructure and meet the Public Utility Commissions request for the following information. • A plant capacity analysis study of the water and wastewater facilities which shall, at a minimum: o (A) include an assessment of the remaining useful service lives to ensure that the existing plant capacities are sufficient to meet current customer needs;and o (B) be used to verify the existing system maps to ensure that Buyer has a verified map of all water and wastewater facilities and infrastructure used to service existing customers;and • Projected capital improvements for the water and wastewater utility operations,including Buyer's anticipated use of the amounts referenced in Paragraph No. 2.1(c)of the Amended and Restated Purchase and Sale Agreement,filed under confidential seal. 2. Description of Potable Water System Operation Punalu'u Water System is rated by the State of Hawaii, Safe Drinking Water Branch as a class 1 distribution system. System ID is PWS 114. System provides potable water to the Sea Mountain Resort, 75 individual condominiums located at the Colony One Complex, fourteen single family residences and the County of Hawaii, Black Sands Beach Park. Punalu'u water system also serves the Sea Mountain at Punalu'u golf course which has four irrigation ponds for storage. The source of water is two groundwater wells registered with the State of Hawaii, Commission on Water Resource Management. Well A "USE" is listed as municipal and Well B "USE" is listed as irrigation. Wells are located on the Makai side of Mamalahoa Hwy and Alahaki Road intersection. Daily flow readings are provided by the 12"flow tube. Both wells pump via a 16" ductile iron pipe to the 1-million-gallon concrete storage tank located at the top of Alahaki Road.Tank elevation is 305 feet above sea level. From the storage tank, water gravity feeds the distribution and fire protection systems. 2 1 P a g e Exhibit A Page 2 of 12