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Dean J. Miller (ISB 1968)
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ID 83702
Tel: 208.343.7500
Fax: 208.336.6912
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Attorneys for Applicant
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER 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-06-
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
DIRECT TESTIMONY OF GREGORY P. WYATT
Please state your name and business address.
Gregory P. Wyatt. United Water Idaho 8248 West Victory Road, Boise Idaho.
What is your occupation?
I am the General Manager of United Water Idaho ("United Water" or
Company
Please describe your educational background and other qualifications.
I am a graduate of Bloomsburg University with a Bachelor of Arts degree in
Business Administration Management.I have previously provided testimony
before the Indiana Utility Regulatory Commission, the Pennsylvania Public
Utility Commission, and the Idaho Public Utilities Commission.
Please describe your work experience.
I have been employed at United Waterworks properties, formerly General
Waterworks, since December 1974. Prior to assuming my current duties as
General Manager of United Water Idaho in late 1999, I worked in various
capacities in several states including General Manager for United Water
Pennsylvania, Area Manager for the United Water Indiana properties, Assistant
Manager of United Water Idaho and various accounting positions in New Jersey
and Pennsylvania.
Please describe your duties as General Manager.
My duties are to oversee the daily operation of providing potable water to the
customers of United Water Idaho.I supervise the various departments of
Engineering, Production, Transmission & Distribution, Customer Service, Billing,
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United Water Idaho Inc.
Information Technology,Planning and Accounting meeting their
responsibilities for the delivery of potable water and the related services in
dealing with customers.
These functions include planning ' for raw water source, construction
maintenance and operation of the treatment and pumping facilities, construction
maintenance, and operation of the distribution system including mains, services
and storage tanks, responding to customer needs regarding initial service or
discontinuing service by reading customer meters, processing and delivering bills
and responding to customer needs through the Customer Service Representatives.
My duties also include supervision of the Company s compliance with all
regulations in regard to safety, complying with the Safe Drinking Water Act, and
meeting other similar requirements.
What is the purpose of your testimony?
I will testify regarding the major reasons for the rate increase requested in this
present case, the Company s proposals regarding cost of capital and tariff design
in this present case, the operations of the Company, and the Company
conservation and customer service efforts. I will also be available to answer
questions of a general nature.
Please identify the other witnesses who will testify on behalf of the Company and
the topics on which they will testify.
Mr. Frank Gradilone III consulting expert with Pleasant Valley Analytics, Inc.
will testify regarding revenue adjustments.
Wyatt, l)i
United Water Idaho Inc.
Mr. Jeremiah J. Healy, Manager Finance and Rates, will testify regarding rate
base and expense adjustments.
Mr. Scott Rhead, Managing Engineer, will testify regarding capital additions and
plant in service.
Rate Increase Drivers
When was the last time the Company requested rate relief and what was the result
of that request?
On November 30, 2004, United Water filed an Application with the Commission
(UWI-04-04) requesting an approximate 22% increase in its rates and charges
for water service using a pro-forma test year methodology ending July 31 , 2004.
The Company subsequently reduced its request to approximately 18%. After full
hearings and deliberations, the Commission issued Order No. 29838, dated
August 2, 2005 authorizing a 7.68% increase in rates ($2.43 million).The
Company then filed a Petition for Reconsideration on August 23 2005, in which
it argued, along with other issues, that Order No. 29838, which calculated rate
base using a 13-month average methodology, produced rates that would
insufficient to allow the Company to earn its authorized return. The Commission
then issued Order No. 29871 on September 20 2005 granting an additional 0.40%
increase ($116 090), but denied the Company s arguments related to the 13-month
averaging methodology. The overall increase in rates ITom those proceedings was
$2.55 million or 8.08%. The overall outcome in these proceedings was heavily
influenced by two major adjustments; rate base due to the 13-month averaging,
and pension expense due to the Commission s decision to allow only the cash
Wyatt, l)i
United Water Idaho Inc.
contribution to the pension plan (ERISA method) rather than the accrued expense
to the pension account (F AS 87 method).
Would you briefly explain why the Company is seeking a rate increase at this
time?
As mentioned above, the two major adjustments in the last case (UWI-04-04)
are the biggest drivers resulting in the Company needing to make this present
filing. The change in ratemaking methodology (use of a 13-month average of rate
base) effectively left the Company with no return on investment related to
approximately $13 million of its utility plant investments in various projects in
service to customers. And, as Witness Healy explains in his testimony, the
Company s pension expense obligation under ERISA is the largest area of
increased operating expense in this case, which is almost $1.7 million dollars
higher than the amount allowed by the Commission in the previous case.
Additionally, the increase is necessary for the Company to continue to
provide quality service to our customers, to improve service by replacing aging
inffastructure and to replace inffastructure that is in conflict with other
inffastructure renewal (such as highway and street rebuilds). For these reasons
United continues to make capital investments in utility plant. As a result of the
various inffastructure investments, the Company s rate base of $126 824 685 as
allowed in our last rate proceeding, has increased to $141 015 147 in this
proceeding or an increase of $14 190,462. In accordance with the Idaho Public
Utilities Commission Order No. 29838 in our last general rate proceeding (UWI-
04-04), the Company has applied the 13-month averaging methodology to
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United Water Idaho Inc.
plant in service and associated components in computing the Company s rate
base. This does not contradict the position taken by the Company in its appeal
(Case No. SUP-05-01) of the last case.
In addition, our operating costs before income taxes have increased ffom
$20 144 532 to $22 909 062 or an increase of $2 764 530. An increase in rates is
necessary in order to provide sufficient capital dollars to maintain and improve
quality service to our customers, to provide adequate operating and maintenance
coverage, and to maintain a sound financial position.
You mentioned that the Company used a 13-month averaging methodology in
determining rate base in this proceeding. Please explain the significance of that
rate making change on the Company s request for increased rates in this
proceeding.
In the last case (UWI-04-04), the Company requested a return on plant
service and other components of rate base as ofthe end of the test year (July 31
2004), plus known and measurable proforma plant in service additions through
May 31 , 2005. This approach was consistent with the Company s approach in its
three previous rate filings and with Commission Orders ffom those cases.
However, in that case the Commission ordered a 13-month averaging of plant in
service and related components in determining the Company s rate base on which
it may earn a return. This change in ratemaking methodology effectively left the
Company with no return on investment related to approximately $13 million of its
utility plant investments in various projects in service to customers. Since that
last proceeding the Company has continued to invest in utility plant in service to
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United Water Idaho Inc.
customers in an amount of approximately $4 million. The Company s requested
increase in rates in this proceeding is largely driven by the need to receive a
financial return on these investments in utility plant in service to customers
which were not recognized in rates in the last case and which are now eligible for
full inclusion in rates under a 13-month rate base methodology.
What kind of plant investments has the Company made that are requested to be
included in this current case?
The Company has invested over $2 million dollars in wellhead treatment at two
locations in the system, (Bali Hai and Maple Hills). The investments at Bali Hai
and Maple Hills wells have enabled the Company to improve water quality to
customers while also utilizing more of the source well water ffom those sites.
Approximately $1.5 million in water storage facilities that provide fire protection
and sustainable pressure to customers in the system, most notably in the South
County area, which was acquired ffom the South County Water Company in
1999. The Company has made investments totaling about $4.8 million dollars in
replacing aging inffastructure. The Company has replaced about 7 miles of water
mainline, 700 water services, and 12 000 meters.
What are the major areas of operating cost increases that the Company has
experienced since the last rate case?
The largest area of increased operating expense in this case is the cost to fund the
Company s pension plan, which is almost $1.7 million dollars higher than the
amount allowed by the Commission in the previous case.As discussed by
Witness Healy, pension expense in this case is calculated consistent with the
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United Water Idaho Inc.
methods required by Order No. 29838. Another significant portion of the expense
increase comes ITom depreciation expense related to the capital investments the
Company has made. Depreciation expense has increased by almost $671 000
dollars. Additionally, costs have increased by almost $300 000 dollars related to
payroll and transportation costs, including fuel. There have been cost decreases in
purchased power, property taxes and bad debt write-offs. All of the Company
operating expense adjustments are discussed more fully in Witness Healy
testimony and exhibits.
What is the current average annual residential water bill as determined in the test
year?
The current average annual residential bill, as reflected in this case after
adjustments and normalization, is $327., exclusive of IDEQ fees and ITanchise
tax.
What would be the average annual residential bill under the proposed rates in this
filing, and what is the overall increase request?
The average annual residential bill under proposed rates would be $385., or an
increase of 17.95%. The overall increase request in this present filing is 17.91 %.
Rate of Return and Capital Structure
What is the Company s proposal in this case with respect to rate of return and
capital structure?
Consistent with our desire to present a simplified rate case filing and to reduce the
time and cost oflitigation, the Company proposes to carry forward ITom Case No.
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United Water Idaho Inc.
UWI-04-04 the methodology for calculating the overall rate of return
including the cost of equity, cost of debt methodology and capital structure
adopted in Case No. UWI-04-04.
Please summarize the treatment of rate of return and capital structure in Case No.
UWI - W -04-04.
In that case the Company and Commission Staff entered into a written Settlement
of the Overall Weighted Cost of Capital (Settlement), which was accepted and
approved by the Commission in Order No. 29838.
In the Settlement, the cost rate for the equity component of the capital structure
was set at 10.3%. The rate for the debt component was established by a
compromise between the Staff and Company methods for calculating issuance
expense, discounts and premiums. The overall rate of return was based on the
consolidated capital structure of United Waterworks Inc., the Company s parent.
What is the overall weighted cost of capital that results from carrying forward the
Settlement in Case No. UWI-04-04?
Based on the capital structure of United Waterworks Inc. as of 12/31105 it is
8.427%, calculated as follows:
Long-Term Debt $224 380 000
RATIOS
51.46%
COST WEIGHTED
RATE COST
66%3.427%
10.30%000%
00%000%
8.427%
Equity $211 ,61 0 905 48.54%
Minority Interest $00%
TOTAL $435.990.905 100.00%
Wyatt, l)i
United Water Idaho Inc.
Is the cost rate for the debt component of the capital structure calculated in the
same manner as in the Stipulation?
Yes it is.
Do you believe that a cost rate for the equity component of 10.3 % is a
conservative estimate of the Company s cost of equity?
Yes. In Case No. UWI~W-04-04 the Company offered expert testimony
establishing a reasonable return on equity within a range of 10.8% and 11.2%.
The agreed rate of 10.3% was well below the rate supported by expert testimony.
Additionally, as of the time of filing this testimony, only approximately six
months have passed since Order No. 29838 established the cost of equity. The
Company is not aware of significant changes in capital markets or other relevant
factors that would indicate that cost of equity has declined in the interim.
Have there been changes in the Company s capital structure since Case No. UWI-
04-04?
Yes. There have been two relatively minor changes. First, all the shares of the
United Water Idaho s 5% Preferred Stock, which represented only .13% of the
previous capital structure, are being redeemed and by March 17, 2006 will no
longer be outstanding. Second, United Waterworks Inc. received ITom its parent
an infusion of equity capital which increased the equity ratio of the capital
structure to 48.37%, up ITom 46.6% in Case No. UWI-04-04.
In light of this proposal with respect to rate of return and capital structure, is the
Company presenting independent testimony of a cost of capital witness?
Wyatt, l)i
United Water Idaho Inc.
No. For the reasons discussed above, for the purposes of this case, a weighted cost
of capital of 8.427% represents a reasonable rate of return. To the extent that the
Commission s Rules of Procedure, 121(e), require the presentation of a cost of
capital structure analysis, the Company requests that requirement be waived for
this case. It is our intent that this approach will serve to eliminate a source of
controversy. However, we would reserve the right to present expert witness
testimony on rebuttal if substantial issues emerge on the subject.
Cost of Service and Tariff Desi2n
What is the Company s proposal for adjustments to rates to recover any revenue
increase that may be awarded by the Commission?
As explained in more detail in the testimony of Frank Gradilone III, the Company
is proposing a uniform percentage increase to all rate elements, excluding
miscellaneous service charges and fees. The Company is not proposing, in this
case, any change to the current tariff design.
Is the Company presenting the testimony of an independent cost of service
witness in this case?
No. Because no changes to current rate design are proposed, a separate cost of
service study would be of little value. Additionally, in Case No. UWI-04-
issues of cost of service and rate design were extensively reviewed. In that case
the Company presented a complete cost of service study, prepared by Dr. Dennis
Pesseau. Given the recent and extensive review of these issues, and consistent
with the Company s intent to simplify this case, the Company is not proposing
changes to the current rate design; rather the Company proposes that the current
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United Water Idaho Inc.
rate elements be increased by a uniform percentage. Thus, to the extent that the
Commission s Rules of Procedure, 121(e), require the presentation of a separate
cost of service study, the Company requests that requirement be waived for this
case.
Company Operations
Please describe the operations of the company.
As of December 31 , 2005, United Water Idaho provided domestic water service
and fire protection to approximately 79 000 residential, commercial, industrial
private fire protection and public authority customers within the City of Boise and
the immediate surrounding area.Over ninety-nine percent (99%) of the
customers are located in what is referred to as the core area system, which is a
totally interconnected system. Additionally, there are four (4) satellite systems
that are not interconnected with each other or to the core area system. These
satellite systems are identified as Coventry Place, DanskiniSaddle Ridge, Belmont
Heights, and M&M.The Mesa system, formerly a satellite system, was
interconnected with the main system in 2005. Currently our source of supply for
the core area is comprised of two (2) surface water treatment plants and eighty-
four (84) deep wells, which are located throughout a service area of
approximately 146 square miles. The projected delivery capacity in the year 2006
of the surface water treatment plants and the eighty-four (84) wells to the
customers in the core service area is 103.2 million gallons per day (mgd).
Coventry Place is served by one (1) well with a rated capacity of 0.4 mgd; the
DanskiniSaddle Ridge area is served by two (2) wells with a combined rated
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United Water Idaho Inc.
capacity of 2.0 mgd; the Belmont Heights system is served by two (2) wells with
a rated capacity of 1.1 mgd; and the M&M system is served by one (1) well with a
rated capacity of 0.14 mgd. The wells in the satellite areas are all currently
capable of meeting the maximum day demands in those areas.
At this time, well water treatment essentially consists of the addition of
chlorine for disinfection and system residuals as well as polyphosphate for
sequestration of iron and manganese. In addition, green sand filtration systems
treat water at two well stations in the system, (Bali Hai and Maple Hills). At the
Marden Street surface water treatment plant, the treatment ranges ITom direct
filtration to full coagulation, settling and filtration depending on the quality of the
raw water.At the Columbia surface water treatment plant, treatment
accomplished using micro-filtration membranes.
During 2005, the maximum day production ITom all sources was 91.5
million gallons; the minimum day production was 17.9 million gallons; while
average day production was approximately 40.5 million gallons. The historical
maximum day production was 92.2 million gallons in July 2003.
The distribution system consists of approximately 1 073 miles of water
main, varying in size ITom 2 inches to 30 inches in diameter. The distribution
system also is supported by 34.8 million gallons of storage capacity contained in
31 ground-level reservoirs.
Due to differences in elevation within the coverage of the service area
United Water Idaho has 10 different pressure zones in the core area.Each
satellite area also can be considered as a separate pressure zone. These zones are
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United Water Idaho Inc.
necessary to maintain a reasonable range of pressure at the customers' points of
use.Connections ITom adjacent pressure zones allow us to transport water
between some pressure zones; however, it is not possible to transport water ITom
each pressure zone to all 9 of the other pressure zones. Since we have 86 sources
(points ITom which water originates) in the core area, the customers within the
area of influence of a particular source normally will receive water ITom that
source. As the customers near the source begin to use up the water and as
distance ITom the source increases, more water will be consumed until the supply
ITom a particular source is exhausted and adjacent customers then receive water
ITom a different source.
You note that the combined delivery capacity in the core area is approximately
103.2 mgd while the maximum day production during 2005 was 91.5 million
gallons. Does this mean that you can serve significant numbers of additional
customers without adding any additional source?
, it does not. That would require a perfectly balanced distribution system and
every well would have to produce 100% of capacity at the same time. This
perfect balance would have to be between the main sizes, main locations, source
locations, pumping capacity, storage size, and storage locations. History ITom
2001 , 2002 and 2003 shows maximum day demand of 93.7 million gallons, 94.
million gallons and 94.1 million gallons respectively, all of which are higher than
the maximum day production ITom 2005.
Additionally, when the need for supply redundancy is considered the
apparent surplus is reduced. The Idaho Department of Environmental Quality
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United Water Idaho Inc.
requires water suppliers to provide supply redundancy by allowing for the loss of
the largest capacity wells when determining their reliable water supply targets.
Two key operational service areas of the water system are Columbia and the West
First Bench. The largest wells serving these zones are Pleasant Valley (2.65 mgd)
and Bethel (3.55 mgd) respectively. With a combined capacity of 6.2 mgd, these
sources, if lost, decrease the difference in overall system supply vs. demand
significantly.
Customer growth is also not distributed evenly across the system. There
are areas of higher growth where new sources of supply will be needed. Most
notably the southwest and northwest areas of the system continue to experience
growth that will require future source additions.
Water Conservation
Would you please provide an overview of the Company s water conservation and
demand side management efforts and programs?
For over II years the Company has developed and implemented various customer
information, education and awareness programs and outreach efforts that promote
wise water use and water conservation and that assist customers in managing their
water demand and consumption. Although some of these efforts have sought to
inform customers about water use in the home, the majority of them have targeted
customer water use outside on lawns, gardens and landscape areas. This focus is
designed to enable customers who use water provided by the Company for
irrigation purposes to benefit the most ITom the Company s efforts, since
irrigation demand is the driver of overall water system demand in the summer.
Wyatt, l)i
United Water Idaho Inc.
Below is a brief summary of the company s efforts in these areas:
Water Efficient Landscaping Classes:
In February of each year, United and others conduct seven, two-hour class
sessions focused on the fundamentals of water efficient landscaping. In 2005, 700
adult individuals attended the classes.
Water Awareness Week
In May of each year, United participates in Water Awareness Week, which
promotes water education and conservation information for school students in
Region 3, which includes the Boise area.
Indoor Water Conservation Kit give-a-wav
Customers seeking ways to reduce their water consumption are offered a free
water conservation kit that includes a low flow showerhead, faucet aerators and
toilet dams.
Summer water conservation bill insert
As customer bills are delivered throughout the spnng and summer, the bill
includes an insert that provides information on how customers can reduce their
outside water demand during the summer.
Water use management messaging through the media
The overall media effort is designed to increase customer s awareness of their
water use and to provide them with concrete reminders and methods to manage
their water consumption. This consists of a coordinated use of newspaper, radio
Wyatt, l)i
United Water Idaho Inc.
and television to communicate wise water use and management throughout the
summer. In 2005 it included a first-ever Annual Conservation Guide, which was
placed in the Idaho Statesman as an advertising supplement in July. The Guide
included eight pages of water supply information and both indoor and outdoor
water use conservation information that customers could use to reduce their
annual water usage and cost. The supplement was designed for customers to
easily save and refer to the information year-round. In addition, daily radio spots
were featured during drive times that provided water conservation messages and
tips; and a weeknight television partnership with Channel 6 KIVI highlighting
United's daily production compared to normal and to history, along with
conservation tips and trivia.
Educational and Community outreach
United has developed various water awareness and conservation presentations
that are available to schools and community organizations in the area. These
include PowerPoint presentations, topical lectures, school skits and a video
library.
Conservation Plan
Please comment on the Company s efforts to update its existing Conservation
Plan.
As a result of the last case (UWI-04-04) the Commission, in its September 20
2005 Order No. 29871 , directed the Company to prepare an updated conservation
plan and submit it to the Commission for review no later than April 1 , 2006. The
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United Water Idaho Inc.
Company immediately began soliciting proposals ITom qualified consulting firms
for preparation of the new plan. Only one firm submitted a responsive bid
however, and some ofthe firms indicated the proposed timeITame was too short to
complete and file a conservation plan.
What did the Company do in response to this?
On November 21 , 2005, the Company filed a Petition with the Commission
seeking amendment of the Commission s Order No. 29871. The Petition asserted
that preparation of a suitable conservation plan by April 1 , 2006 was not feasible
and requested that Order 29871 be amended to extend the deadline to December
, 2006.
How did the Commission rule on the Company s Petition?
On December 28, 2005, the Commission issued Order No. 29934 which amended
Order No. 29871 to extend the deadline for submittal of the final revised
conservation plan to the Commission by December 1 , 2006, provided until
February 1 , 2007 for Commission review of the plan, and set June 1 , 2007 as the
date by which United Water must begin implementation of the revised plan.
What is the current status of the Company s efforts with regard to the production
of a revised conservation plan?
The Company again solicited proposals ITom qualified consulting firms
identifying the revised timeITame for completion of the plan.To date the
Company has received valid responses from two firms and it is expected that final
consultant selection will occur in February.
Wyatt, l)i
United Water Idaho Inc.
Does the Company now anticipate being able to meet the revised timeframe?
Yes it does.
Customer Service
Please comment on the Company s customer service efforts.
United Water uses various measures and metrics to ensure that it maintains a high
level of service and responsiveness to its customers. For example, the Company
tracks customer complaints it receives relating to water quality. During 2005
water quality complaints that required a field visit to resolve have averaged only
77% of total customers.Complaints relating to high bills and disconnection
have averaged only 0.27% and 0.34% respectively as a percentage of bills
rendered.
Are there other measures used by the Company to track customer servIce
performance?
Yes. Our Customer Service group maintains various data relating to customer
calls, response time, length of call, and number of dropped calls. During 2005
the Customer Service office answered 93 249 calls with an average answer speed
of 29 seconds. The average length of calls was 2.25 minutes, and the abandoned
or dropped call rate was 4.3% of all calls. Slightly more than 44% of the dropped
calls occurred during the first 30 seconds of hold time and this would include
those customers who may have reached our office in error (i.e. wrong number)
and hung up. Assuming a caller is willing to hold more than 30 seconds, the
dropped call rate falls to 2.4%. In addition, due to the fact that virtually all
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United Water Idaho Inc.
customer meters are located in outside pits or vaults, we are able to render bills
based on actual meter readings 99.9% of the time.
Are there other things you are aware of that speak to the high level and/or quality
of service the Company provides to customers?
Yes. In early January 2006, the Company received an award ITom the Idaho
Department of Environmental Quality (IDEQ) that recognized the Marden Street
surface water treatment plant as one of only seven plants in the state of Idaho to
have achieved consistently high quality drinking water quality within the EP
Region 10, Area-Wide Optimization Program.Also, since early 2005, the
Company has worked closely with IDEQ, and the Commission Staff to provide
safe drinking water to the residences of the Terra Grande Water System, and most
recently has responded to Staffs request that the Company take over that troubled
water system.The Company has proposed making significant capital
improvements to ensure that the Terra Grande customers have long-term access to
quality drinking water and good customer service.
Low-Income Customer Assistance
Does the Company currently have a low-income customer assistance program in
place?
Yes. During the last rate preceding the Company, along with Commission Staff
and other interested parties, convened a workshop to evaluate the need for, scope
and design of such an assistance program for United's' low-income water
customers. As a result of the workshop, and in conjunction with Community
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United Water Idaho Inc.
Action Partnership Association of Idaho, the Company initiated UW Cares, which
is the first-ever water utility customer assistance program in the state.The
program, which is administered through the EI-Ada and Western Idaho
Community Action Partnership social service organizations, provides up to $50
annual water bill assistance to qualifying customers. The Company is currently
funding the program and will match customer contributions into the fund up to
$20 000 annually. Additionally, the Company provides the agencies with indoor
and outdoor water conservation kits for distribution and installation for qualified
customers in the program. Also during the last rate proceeding, the Company
supported and agreed to a proposed change in it's rate tariff whereby the first 3
hundred cubic feet (ccf) of consumption used during the summer rates period
(May through September) is priced at the 25% lower winter rate.
Does this conclude your testimony?
Yes.
Wyatt, l)i
United Water Idaho Inc.