20051121Petition to amend Order 29871.pdf

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Dean J. Miller ISB #1968
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
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Attorneys for Applicant ORIGINAL
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA TIER OF THE APPLICATION
OF UNITED WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO
Case No. UWI-O4-
PETITION TO AMEND ORDER
NO. 29871
COMES NOW United Water Idaho Inc.
, ("
United Water
, "
the Company ), pursuant to
RP 326(b), and Petitions the Commission for an order amending Final Order on Reconsideration
No. 29871 , on the grounds that new information has become available since the Order was
issued, and in support thereof respectfully shows as follows, to wit:
On September 20 2005 the Commission issued Order No. 29871 , Final Order on
Reconsideration. As part of said order the Commission directed the company to prepare a
conservation plan and submit it to the Commission for review no later than April 1 , 2006.
(Order, pg. 15).
II.
Thereafter, United Water promptly commenced a Request for Proposal (RFP) solicitation
process, establishing a RFP response date of November 14 2005. Included in the RFP was a
PETITION TO AMEND ORDER NO. 29871 -
proposed timeline of work that would enable meeting the April 1 , 2006 deadline established by
Order No. 29871.
III.
The RFP was sent to eight (8) apparently qualified consulting firms. Only one firm
submitted a responsive bid. Three of the firms indicated that the short time frame between now
and April 1 , 2006 was a significant factor in their inability to submit a responsive bid. Some of
the potential consultants indicated that a period of nine (9) to twelve (12) months is generally
required for the preparation of a comprehensive, high-quality plan.
IV.
Based on these responses, United Water has concluded that preparation of a suitable
conservation plan by April 1 , 2006 is infeasible.
United Water therefore respectfully requests that Order No. 29871 be amended to
establish the following deadlines, which would permit implementation, or partial implementation
of the conservation plan prior to the summer season of 2007:
Update to the Commission on status of the ongoing plan revision at April 1, 2006.
Submit the fmal revised conservation plan to the Commission by December 1 , 2006.
Commission completes its review of the plan by February 1 2007.
United Water begins initial implementation of the revised plan no later than June 1 2007.
VI.
In the interim, United Water will continue to operate and enhance its on-going
conservation and education efforts. The Company, for example, is planning the following
enhancements during 2006:
PETITION TO AMEND ORDER NO. 29871 - 2
Construct a Xeriscape Demonstration Garden at its office location at 8248 West Victory
Road, Boise, Idaho. The Xeriscape Garden would include information and literature for
customers on low water use and drought tolerant plants and methods.
Assists the Idaho Botanical Garden with it's Demonstration Garden and provide
conservation information literature for the public.
Establish a Customer Advisory Committee that can provide useful customer input and
feedback regarding Company messages and methods of conservation outreach to the
public.
Increase conservation displays and outreach at local gardening-type shows in the area.
WHEREFORE United Water respectfully requests that Order No. 29871 be amended to
establish December 1 , 2006 as the deadline for completion of the revised conservation plan and
submission of said plan to the Commission.
RESPECTFULL Y SUBMITTED thi t.) \ day of November, 2006.
McDEVITT & MILLER LLP
Attorneys for United Water Idaho Inc.
PETITION TO AMEND ORDER NO. 29871 - 3
CERTIFICATE OF SERVICE
I hereby certify that on the day of November, 2005, I caused to be served, via the
methodes) indicated below, true and correct copies of the foregoing document, upon:
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Brad M. Purdy
Attorney for the Community Action Partnership
Association of Idaho
2019 North 17th Street
Boise, Idaho 83702
Fax: [phone]
bmpurdv0J,hotmail.com
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William M. Eddie
Advocatesfor the West
O. Box 1612-83701
1320 West Franklin Street
Boise, Idaho 83702
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billeddie0J,rmci,net
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Bill Sedivy
idaho Rivers United
O. Box 633
Boise, Idaho 83701
Fax: [phone]
iru0J,idahorivers,org
Sharon Ullman
9627 West Desert Avenue
Boise, Idaho 83709
Fax: [phone]
sharon u0J,cab leone, net
Chuck Mickelson
Boise City Public Works
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]
cmicke Ison0J,citvofbo ise, org
Douglas K. Strickling
Boise City Attorney s Office
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]
dstrickling0J,c itvofbo ise. org
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PETITION TO AMEND ORDER NO. 29871 - 4
Scott L. Campbell
Moffatt Thomas
101 South Capitol Blvd., lOth Floor
O. Box 829-83701-0829
Boise, Idaho 83702
Fax: [phone]
slc0J,moffattcom
PETITION TO AMEND ORDER NO. 29871 - 5
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