HomeMy WebLinkAbout20070223Comments.pdfWELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0318
IDAHO BAR NO. 3283
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BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
UNITED WATER IDAHO INC. FOR APPROVAL)
OF ITS WATER CONSERVATION PLAN AND
APPROVAL OF A SURCHARGE
CASE NO. UWI-O6-
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Weldon B. Stutzman, Deputy Attorney General, in response to the Notice of
Application and Notice of Modified Procedure in Case No. UWI-06-5 issued in Order No,
30228 on January 24 2007, submits the following comments.
BACKGROUND
In the Company s last rate case, Case No. UWI-04-, the Commission directed the
Company to update its conservation plan and file it with the Commission on or before April 1
2006. Prior to that deadline, United Water asked for an extension, and the Commission
subsequently approved a new filing date of December 1 , 2006. On December 1 2006, United
Water Idaho Inc. filed an Application requesting approval of an updated water conservation plan
along with implementation of a surcharge to pay for the programs in the plan.
United Water s Application states that it evaluated 91 potential conservation measures
selecting 17 for further study and evaluation. This analysis produced a list of seven conservation
STAFF COMMENTS FEBRUARY 23, 2007
measures the Company believes are cost effective. United Water currently spends approximately
$124 200 per year on conservation measures. If the seven additional programs become part of its
conservation plan, those costs would increase to approximately $244 000 per year. The
Company proposes to implement the changes over the next three years.
United Water requests approval of a surcharge of 0.33% on amounts billed under the
Company s Tariff Schedule 1 , General Metered Service, to recover the costs of its conservation
programs. The Company estimates the surcharge would add approximately $1.20 annually to the
average residential customer s bill.
STAFF ANALYSIS
Summary
Staff reviewed United Water Idaho s Water Conservation Plan and has concerns with
both the Plan evaluation process and specific programs selected for implementation. The
screening process that eliminated many potential measures appears to be subjective, and
produced primarily educational programs that are difficult to evaluate for acquired savings. Staff
believes the two stage planning process prematurely eliminated a number of potentially good
programs from further analysis.
The Company used a marginal cost methodology that fails to reflect the true cost of
supply side options, which eliminated some programs that might produce significant savings.
The measures recommended for implementation are primarily continuations or modest
expansions of current customer information and education efforts. The Plan does not sufficiently
detail what additional activities would be accomplished with the significantly increased funding
over current efforts. Finally, Staff believes the proposed funding mechanism, a conservation
rider, is premature, given the ill-defined expansion of the informational programs and the lack of
any meaningful evaluation mechanism.
Staff does support implementation of the measures identified in this Plan, with the costs
deferred for future recovery, pending a detailed description of the actual program activities and
some evaluation of conservation impact. The Company should re-evaluate its Plan, based on a
more realistic supply side marginal cost. It should then propose a broader range of conservation
programs that can be objectively evaluated for conservation savings and supported by the
informational programs already in place.
STAFF COMMENTS FEBRUARY 23 2007
Plan Components
A. Continue Current Efforts.
The Plan advises the continuation of current conservation efforts, including:
Funding a full-time outreach/education coordinator
Creating and maintaining a web site.
Conducting summer media/advertising campaign
Participating in relevant community events
Provide information and water saving kits upon request
Continue baseline school education program
Fund Water Efficient Landscaping (WEL) classes at current levels
Maintain existing Xeriscape demonstration garden
The Company did not provide a budget that identified expenditures for each element of
the current program, indicating that it has historically varied from year to year. The total budget
for continuation of existing efforts is $124 200 per year, or $496 800 over the 5 years included in
the Plan.
B. Recommended New Measures.
The seven new recommended measures are:
1. Additional Xeriscape Demonstration Gardens.Additional gardens would be created
on UWI property and in public spaces of cooperating public agencies. In cooperation with a
partnering group, this program would also provide a limited number of grants to increase the
number of xeriscape demonstration gardens located in residential neighborhoods. By increasing
the visibility ofxeriscape landscaping techniques, this measure has a goal of influencing about
15% of single- family residents to take steps to conserve landscape irrigation water over the next
20 years. The Plan identifies a tentative budget of $87 000 to be spent over two years. This is
in addition to the funding for the maintenance and upkeep ofUWl's current demonstration
garden, located at the Company s office, which costs are part ofthe Company s current budget.
The Plan does not specify how many new gardens would be completed, how or where
sites would be selected, or any other details as to how this would be implemented. The Plan
indicates it would seek Partners, such as Idaho Rivers United (IRU), in developing additional
ST AFF COMMENTS FEBRUARY 23 2007
gardens. It does not indicate how it would be integrated with the existing IRU Water Saving
Landscaping demonstration gardens grant program, which has provided grants for the
construction of nearly a dozen water saving landscaping demonstration gardens in UWl's service
area in the past two years. These details should be provided to the Commission prior to
implementation.
2. Expand Water Efficient Landscaping (WELs). The Company currently provides
Water Efficient Landscaping (WEL) workshops in partnership with Boise City Public Works
Department and the University of Idaho Extension. This program would seek to boost
attendance at these workshops, possibly by using incentives, such as plants or drip system
vouchers. The goal is 900 participants a year. The funding for the actual workshops is contained
in the current program budget, and the additional funding would go toward increasing attendance
at the workshops. The annual budget for this measure is $11 200, with a total cost of $56 000
over five years.
Details as to how this measure would be implemented were not included, but should be
provided to the Commission before implementation. No evaluation component is included in the
program.
3. Residential School Education. This is also an expansion of an existing program
providing elementary grades four to six with water conservation materials, workbooks and
teaching aids. The expansion would increase the programs so that it would reach every
elementary school once every three years. The goal is to encourage water conservation by
contact with grade school students from 1 500 families per year.
The funding for a baseline education program is contained in the current program budget.
This proposal would expand that effort with an additional $6 700 per year, or $33 500 over the
five years of the Program.
Details as to how this measure would be implemented were not included, but should be
provided to the Commission before implementation. No evaluation component is included in the
program.
4. Rain Sensor Retrofit.UWI would sponsor periodic rain sensor giveaways at regularly
held community events where UWI has an exhibition booth. Rain sensors respond to
precipitation by delaying one or more cycles in an automatic sprinkler system. Installation
would be the responsibility of the homeowner. The goal is to distribute approximately 8 000
STAFF COMMENTS FEBRUARY 23, 2007
sensors over five years. The annual budget for this program is $35 600, or $178 000 over five
years.
Details as to how this measure would be implemented were not included, but should be
provided to the Commission before implementation. Staff is particularly concerned about the
installation rate of sensors that are provided for free. No evaluation component is included in the
program. A method of monitoring and evaluating this measure should be developed and refined
before any sensors are distributed so that all information required to track sensor use and conduct
the evaluation is obtained from the customer at the time the sensors are distributed.
5. Trigger Shut Off Valves and Hose Timers. UWI would offer incentives, such as a
voucher on the purchase of a shut-off valve or timer. The devices would also be distributed free
of charge at community events, targeted to customers that water manually by hose. These
customers would not be eligible for a rain sensor, because they do not have automatic sprinklers.
The goal is to reach 10% of residential customers over a five-year period. The annual budget
900, for a five-year total of $34 500.
Details as to how this measure would be implemented were not included, but should be
provided to the Commission before implementation. The same evaluation concerns stated in the
section on rain sensors would also apply to these devices.
6. Award Program for Businesses . UWI would sponsor a periodic awards program for
businesses that significantly reduce water use. The goal would be to involve three businesses
every year or so. The annual budget for this program is $1 300, for a five-year total of $6 500.
Details as to how this measure would be implemented were not included, but should be
provided to the Commission before implementation. No follow-up evaluation is proposed as part
of the program.
7. Restaurant Low Flow SpraylRinse Nozzles. This program would provide for the free
installation of low flow spray/rinse nozzles used in the rinse and clean operations by restaurants
grocery stores and commercial kitchens. The installation would be done by a contractor and
would target only older restaurants, as all nozzles in newer restaurants must be low flow. The
goal is to install 1 000 nozzles over five years. The annual budget would be $40 900, for a five-
year total of $204 500.
This is the type of program the Company should be looking to implement in all sectors.
Because installation is part of the program, there is no question about the percentage that will
STAFF COMMENTS FEBRUARY 23, 2007
eventually be installed or used, unlike the other giveaways. By conducting the program in a high
volume, short time frame, costs are kept low and benefits are maximized.
Staff suggests the Central District Health Department as a potential partner or contractor
for this program. The District's Environmental Health Specialists visit every restaurant and
grocery store in Ada County on a regular basis.
PLANNING PROCESS
In Staff s opinion, the planning process, under the direction of the Company s consultant
Maddaus Water Management, appeared to improperly eliminate many options that should have
been more fully considered. The consultant identified a total of91 potential conservation
measures/programs that were considered in the initial screening process. Because of the
identification of essentially the same conservation measures in multiple customer categories
(single family residential, multi-family residential, commercial and public customers), the actual
number of programs was significantly less than 91. The included measures addressed all classes
of customers and essentially all of the current water conservation technologies, providing a
reasonable mix.
In the screening process, each of the 91 measures was ranked by a planning group that
included five representatives from UWI (including senior management), a single representative
from both Idaho Rivers United and the Commission Staff, and Mr. Maddaus. Each measure was
ranked on a scale of one to five in four separate areas: (1) the maturity of the technology, (2) the
match between the measure and UWl's service area , (3) the probable customer acceptance and
equity between customers, and (4) the legal authority ofUWI to implement the effort. While
each participant was provided a ranking sheet for his specific opinion, each measure was
discussed by the group for each ranking area, typically resulting in a consensus score. While
participants were free to enter a ranking other than the consensus score, that did not appear to be
the norm.
This process was highly subjective, in many respects reflecting the personal preference of
the group participants. Mr. Maddaus participated in the discussions, but primarily to explain the
technology and measures.
The results from this screening process were not actually determined during the first
phase of the process, but were calculated at a later date by Mr. Maddaus and presented to the
participants at the second stage. Seventy-four ofthe 91 measures were eliminated through this
STAFF COMMENTS FEBRUARY 23, 2007
subjective screening process, with only the remaining seventeen considered in the second phase.
Measure savings and costs were not considered in the screening process, but were developed in
the second phase, so this information has not been calculated for the 74 measures eliminated in
the initial screening process.
Thirty- four measures with scores that were within three points (out of a possible 20) of
most of the surviving measures were eliminated in the screening process. That is twice the
number of measures that survived. Given the subjective nature of the screening process, the
difference of three points appears to be insignificant and somewhat arbitrary as a point of
elimination. Staff believes many ofthese measures merited further evaluation on a more
objective basis. While the range of programs passing the screening appeared to be acceptable
nearly all of the measures with savings that could be objectively quantified were eliminated in
the second stage, leaving primarily educational programs that are notoriously difficult to evaluate
in terms of actual savings.
SAVINGS ESTIMATES
Mr. Maddaus provided estimates of the savings and costs anticipated for each ofthe
seventeen measures that survived the screening process. Although Staff believes the estimates
provided are adequate for this planning purpose, evaluation of program results is required to
determine whether the programs are cost effective.
Estimating savings from a conservation program is a difficult and imprecise process
under the best of conditions, but is especially so for educational and public information
programs. It is difficult to determine the number of real customers exposed to the information
the number of customers that actually implement a particular conservation measure, and the
amounts of water actually saved, resulting in uncertainty of the program s effectiveness. Billing
records are typically not reliable indicators of the impact of educational programs, as the level of
expected savings is relatively small and is overwhelmed by natural variations in usage caused by
weather, increases in numbers of customers, economic and other factors.
The most reliable estimates of educational programs are based upon surveys of customers
who received the promotional materials and a control group to estimate the percentage of
participants that actually take the actions being promoted. Significant concerns about these
estimates include the accuracy of the survey responses, and the persistence of the savings from
measures that rely upon customer actions rather than hardware. In most cases, the cost of such
STAFF COMMENTS FEBRUARY 23, 2007
an evaluation significantly exceeds the amount spent for the program, and thus even this
imprecise evaluation is not conducted. Historically, most educational program evaluations have
been based on the number of participants in the educational efforts or other factors that are at
least one step away from actual water saving actions.
Nonetheless, the fact that evaluation might be difficult does not mean none should be
attempted. As will be discussed in the section on evaluation, Staff believes that a more rigorous
evaluation, including at a minimum, some method of determining actual implementation rates, is
necessary to demonstrate the Company s conservation activities have been effective.
COST ESTIMATES
The procedures for developing cost projections for conservation program proposals are
relatively consistent within the industry and the estimates provided by Mr. Maddaus for each of
the surviving measures is within the range of costs reported by other utilities implementing
similar programs. Staff believes the cost estimates provided by Mr. Maddaus to be reasonable
for use in the process of selecting which measures to include in the Plan.
However, at the time Mr. Maddaus prepared plan cost estimates, the actual mix of
program measures to be implemented were unknown. Consequently, Mr. Maddaus' cost
estimates do not appear to reflect any savings resulting from shared resources, especially
administrative resources, used in implementing measures that are similar in nature to others
selected for implementation or combined with existing efforts. While it is appropriate to exclude
such savings before the mix of plans is determined, it is reasonable to expect such savings in the
implementation of the Plan.
As many of the measures included in the Plan are expansions of existing efforts, Staff
would anticipate many overlapping tasks among these programs and significant opportunities for
resource sharing. Efficient management of these efforts should result in considerable cost
savIngs.
COST/BENEFIT RATIOS
Along with cost and savings estimates for each surviving measure, Mr. Maddaus
provided two cost/benefit ratios. One ratio looks from the utility perspective, and only compares
the costs incurred and benefits received by the utility. The other ratio looks from a society in
general perspective, and includes costs incurred and benefits received by all parties. This is
STAFF COMMENTS FEBRUARY 23 , 2007
similar to the URC (Utility Resource Cost) and TRC (Total Resource Cost) calculations used by
the electric and gas utilities in developing their conservation plans.
The resulting value is determined by a complex model that computes the value of savings
and costs expected over the projected lifetime of the conservation actions that are taken in
response to the utility s efforts. All future amounts are discounted to reflect the difference
between the time the expenditures are incurred and the savings achieved. As proposed, the
economic model utilized a real interest rate of 3 .5%. This interest rate is the result of adjusting
an assumed nominal interest rate of 6.6% and an assumed inflation rate of 3%. Staff believes the
parameters for determining the net present value of future costs and benefits considered in this
case are reasonable. Table A in Attachment 1 shows the values produced by Mr. Maddaus.
The value of the savings is based upon the costs the utility does not incur due to the
reduction in the amount of water required, or the Company s marginal cost of water. This
includes any savings in operational costs due to the lower volumes, as well as any capital costs
avoided by the Company due to water conservation. In UWl's case , the anticipated reduction in
operational costs is small ($ 1 03.80/million gallons), and the Plan identified the other cost savings
as the value of a delay in the drilling of new wells and/or expansion of water treatment facilities
planned to accommodate future growth in the Company s service area.
Marginal costs are typically calculated based upon the full cost of future production
facilities, not just the value of a delay in their construction. Limiting the potential savings to the
value of a short delay in the construction of treatment facilities resulted in a cost benefit ratio that
is approximately 1/1 0 of the marginal cost ratio obtained for similar measures identified in the
Water Conservation Potential Assessment prepared by the water utility of the City of Seattle.
Staff believes this method of evaluation is inappropriate. The use of such a methodology
reduces the value as compared to additional facilities that would otherwise be needed to do the
same job. Customers will certainly feel the full cost impact of supply side options in their bills if
load grows as predicted. They should also see the full cost savings if some of that load growth is
served by less expensive demand side options. Staff believes the full cost of the most expensive
supply options planned by the Company to serve new water demands should be used in valuing
water conservation if conservation provides a portion of that new demand.
STAFF COMMENTS FEBRUARY 23, 2007
EVALUATION
While the Plan indicates there will be some effort to evaluate the effectiveness, it does
not specify how or what will be done, nor does it provide a budget for evaluation. The Plan
mentions the high expense of effective evaluation for the types of programs included in the Plan
more often than it mentions any attempts to actually conduct an evaluation.
Staff is aware of the costs of evaluation efforts for conservation expenditures, but is also
cognizant of the importance of such evaluation when expenditures are used for acquiring
conservation, as a resource for meeting future needs. It is unlikely that UWI would spend the
amount of money required to drill a well without verifying the amount of water that it actually
produces. Prudent management requires a comparable level of verification when expenditures
for conservation are made to meet future needs.
At a minimum, Staff would expect the Company to conduct surveys of a representative
sample of participants in all of its programs to determine the actual conservation actions taken by
the participant. The information provided by the participant should be sufficient to estimate the
expected water savings of the program. For example, for evaluating savings from free rain
sensors, the information would probably need to include whether the sensor was actually
installed, as well as the amount of area irrigated by an automated sprinkler system controlled by
the sensor, the frequency and duration of watering cycles and verification that the system uses
potable water supplied by UWI.
PARTNERSHIPS & GRANTS
The Plan frequently mentions the use of partners and/or grants, both as a means of
reducing UWI expenditures, but also for increasing the effectiveness of the conservation efforts.
Staff supports the use of partners and agrees that they often increase the effectiveness of utility
efforts.
RATE DESIGN
The Plan did not examine rate design options as a means of achieving conservation
although tiered rate designs are a common element in many conservation efforts. Staff and the
Company are currently considering rate design issues in the context of monthly, rather than bi-
monthly billing. Accordingly, this issue will be addressed in another forum. Staff notes that the
Consultant recommended monthly billing in the Plan.
STAFF COMMENTS FEBRUARY 23, 2007
HOOKUP AND CODE REQUIREMENTS
The initial 91 measures included a number of measures that involve restrictions on the
sale, purchase and/or use of non-conserving devices or landscaping, some imposed by the local
or state government, and others imposed as a hook-up requirement by the utility. None of these
measures survived the screening process, typically ranking low in both consumer acceptance and
legal authority. While Staff agrees that UWI lacks the authority to impose or change government
codes and requirements, and such codes and requirements can be controversial, that does not
preclude the Company from proposing and supporting such changes when considered by the
entities that do have the authority. In addition, including conservation requirements in developer
agreements should also be considered. These could include turf requirements in subdivisions
and requirements for water efficient landscaping of model homes and common areas.
PROGRAM FUNDING AND CONSERVATION RIDER
Staffhas supported the use of conservation riders or surcharges to fund conservation
acquisition efforts for other utilities. Riders can reduce utility reluctance to fund conservation
efforts and help provide conservation programs with stable budgets at times when utilities have
imposed severe cost saving measures on other utility expenditures. Staff does not support
however, a rider to fund a conservation program composed of primarily public information and
educational efforts. The savings are too speculative and the expenditures typically insufficient to
justify a rider. Riders are appropriate when the expenditures are expected to change significantly
from year to year or ramp up quickly. When expenditures are expected to be stable, such as the
ongoing cost of an education and public information campaign, there is no need for a rider, as
recovery through rates is adequate.
In addition, there is considerable overlap between the existing program and the new
measures recommended for funding through a rider. Four proposed measures are simple
expansions of existing efforts, and two residential measures (rain sensors and hose valves or
timers) primarily involve providing items to give away at public events that the Company would
already participate in under the existing program plan and budget. The details provided by the
Company do not sufficiently delineate between what would be covered under existing efforts and
what would be considered new. Although the Company has developed accounting procedures
record efforts and expenditures under the existing program separate from those recommended in
STAFF COMMENTS FEBRUARY 23 , 2007
the new Plan, these efforts will likely involve the same staff at the same events working on
elements of both the existing and expanded measures. Keeping the allocation of costs accurate
will be difficult and time consuming. Funding through rates will simplify and reduce this
administrative burden. In the alternative, Staff would support deferral of excess water
conservation costs for later recovery upon a showing that the programs were effectively
delivered and evaluated.
FINANCIAL RECORD KEEPING & AUDITING
Staff reviewed the Company s responses concerning the accounting treatment of the
proposed surcharge amount of 0.33%. This review included the following areas of concern:
1. Reconciliation of funding for the rider account to ensure no redundancy of expense
treatment between expenditures currently included in rates and new expenses
associated with the rider account.
2. Amortization amounts, if any.
3. Cost effectiveness of the proposed Conservation Program.
4. Balancing account identification numbers including titles and sub-account numbers.
5. Accounting procedures that will be utilized to track Conservation Plan Income and
Expenses.
6. Billing examples of the proposed Conservation Surcharge.
The Company provided Staff with the Conservation Surcharge Balancing Account
(Sub-account 242-26), as well as a generic outline of the procedures to be used to reconcile and
track expenses and income related to this sub-account. Staff requests that the Company
demonstrate, if and when the Plan is augmented regardless of the funding mechanism, it is
adequately reconciling expenses between those expenses currently included in rates and new
expenses associated with the new Conservation Plan. Staff believes that the potential for abuse
in this area could be significant. Therefore, Staff requests that the Company provide Staff with a
detailed schedule of sub-account numbers and titles after the detailed sub-accounts for each
program are established. Staff can then use this information in its audit of the sub-accounts after
one year of operation to verify that proper reconciliation is taking place. Staff believes sufficient
information has not been provided to currently enable such verification.
STAFF COMMENTS FEBRUARY 23 , 2007
GENERAL COMMENTS
The total annual cost of continuing the Company s existing conservation efforts
($124 000) plus the new measures ($120 000) would be $244 200. The total annual savings from
the entire Plan, which would be implemented over five to ten years, is estimated as less than 2%
of current annual consumption. Implementation of the Plan would not significantly reduce the
projected growth in peak day usage, which is expected to grow by over 48 Million Gallons per
Day (MGD). The total reduction in average daily usage is estimated at only 0.71 MGD.
As a point of reference, Staff refers to the City of Seattle s Water Conservation Plan
which is designed to reduce total demand by 1 % a year for the ten years covered by the Plan, for
a 10% reduction in total use. This is after having already captured significant savings, as an
aggressive conservation effort initiated in 1990 had already reduced per capita consumption by
20%. Seattle s Plan is designed to meet 100% of the projected growth in demand over the ten-
year period.
Based upon the utility benefit/cost ratio and the Cost of Savings identified by the
Company in Table 6-2 of the Plan, Staff calculated the marginal cost of water used in developing
UWl's Plan to be approximately $225 per million gallons ($/MG). Seattle s plan includes a
number of programs that are similar to those eliminated by UWI in its initial evaluation process
including those with a cost of savings estimated to be over $2 800/MG. While Seattle s marginal
cost of supply side options may be higher than that of UWI, it is clearly not more than ten times
higher. All but three of the eliminated programs would have qualified with a marginal cost of
250, well below the reasonable marginal cost of UWI' s Columbia water treatment plant.
The Company asserts in the Plan that it does not face a water supply problem or a
shortage of water. While Staff agrees the Company s situation is not a crisis, such as that faced
by water utilities in Southern California or other areas of the Southwest, Staff does not agree that
the Company is not facing limits in the availability of water. At the very least, the costs of
acquiring new water supplies could be very high.
The Company recently constructed the Columbia treatment plant. The 2006 Master Plan
identifies additional facilities that will most likely be even more expensive. The value of
conservation resources should be based on avoiding or replacing a portion of these costly supply
side options. If properly valued, other more objective conservation measures could be
implemented to complement the subjective informational programs proposed by the Company.
STAFF COMMENTS FEBRUARY 23 , 2007
STAFF RECOMMENDATION
1. The Company should continue the existing conservation efforts and implement the
measures proposed in the Plan. The Company should work with Staff to further refine the details
of program design and implementation and in the development of procedures to better evaluate
results.
2. The Company should re-evaluate the more objective program measures using the full
supply side avoided costs to establish the value of savings.
3. The Company should use informational programs in support of objective programs.
Where appropriate, implement focused pilot programs to refine program operational details and
demonstrate the savings of objective measures.
4. The Company should pursue water saving code improvements, developer agreements
and hook-up requirements to conserve water.
5. The Commission should reject the proposed conservation tariff rider, and instead
authorize deferred accounting treatment of the additional costs for later demonstration of
reasonableness.
Respectfully submitted this 1:J r day of February 2007.
~ ?7
Weldon B. Stutzman
Deputy Attorney General
Technical Staff:Wayne Hart
Tom McKeown
Michael Darrington
i: u umisc/ commen ts/uwi wO6, 5 wstmwhmd
STAFF COMMENTS FEBRUARY 23 , 2007
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CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF FEBRUARY 2007
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF IN CASE
NO. UWI-06-, BY MAILING A COpy THEREOF, POSTAGE PREPAID , TO THE
FOLLOWING:
GREGORYP. WYATT
UNITED WATER IDAHO INC
PO BOX 190420
BOISE ID 83719-0420
DEAN J MILLER ESQ
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
"b
f 4boASECRETARY
CERTIFICATE OF SERVICE