20050406Wojcik direct.pdf

William M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
O. Box 1612
Boise, ill 83701
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fax: [phone]
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Express Mail:
1320 W. Franklin St.
Boise, ID 83702
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 - W -04-
DIRECT TESTIMONY OF DON WOJCIK
ON BEHALF OF IDAHO RIVERS UNITED
PLEASE STATE YOUR NAME, BUSINESS ADDRESS AND POSITION
WITH THE WESTERN RESOURCE ADVOCATES.
My name is Don Wojcik. My business address is Western Resource Advocates
WRA"), 2260 Baseline Road, Suite 200, Boulder, Colorado 80302. WRA is a non-
profit environmental law and policy organization dedicated to restoring and protecting
the natural environment of the Interior American West. I am employed as a water policy
analyst and technical researcher for WRA's Water Program.
PLEASE DESCRIBE YOUR EDUCATION, BUSINESS EXPERIENCE AND
RESPONSIBILITIES.
In 1995, I attained a Master of Public Affairs degree with a concentration in
environmental policy and natural resource management from Indiana University s School
of Public and Environmental Affairs. Prior to that, in 1991 , I attained a Bachelor of
Science degree in Civil and Environmental Engineering from the University of
Wisconsin College of Engineering.
I have been employed as a water policy analyst and technical researcher with
WRA since August 2002. In this position, my primary responsibility is to collect, assess
and compare data on urban water use efficiency in cities across the interior American
West. In this position, I have co-authored various urban water efficiency reports
including: Smart Water: A Comparative Study of Urban Water Use Efficiency Across
the Southwest " as well as two comparative analysis reports on water rate structures in
Colorado and Utah. The executive summaries of these three (3) reports are provided
herewith as Exhibit 401-403; the full copies can be downloaded at the WRA website
(http://www.westernresourceadvocates.org/water/).
Wojcik, Di. 1
Idaho Rivers United
Prior to working with WRA, I have nearly six years experience as a natural
resource planner for the Boulder County Parks and Open Space Department in Boulder
Colorado. I also have two years experience working as an environmental research
assistant for the Center for Urban Policy and the Environment in Indianapolis, Indiana.
Prior to my career in natural resource issues, for two years I worked as a Civil Engineer II
for the Village of Bolingbrook, Illinois in suburban Chicago.
ON WHOSE BEHALF ARE YOU TESTIFYING?
I am testifying on behalf of Idaho Rivers United.
PLEASE SUMMARIZE YOUR TESTIMONY.
United Water Idaho s ("UWI") proposed rate changes seek to recover additional
revenues through increased bi-monthly fixed charges, as well as through commodity
charge increases (i.volumetric rate increases). I recommend the Commission direct
UWI to modify its rate structure to a design that more effectively encourages efficient
water use by sending appropriate price signals to customers. This includes the adoption
of an increasing block rate design of at least three blocks during summer months: an
initial lower-cost block for the first volume of use (to cover indoor residential use for the
average household), and a minimum of two additional blocks to discourage excessive
outdoor watering and to assign current and future water development costs more fairly.
I also recommend the Commission direct UWI to expand its suite of conservation
programs in order to (a) provide customers additional options to avoid the financial
impact ofUWI's requested rate increases , and (b) enhance UWI's ability to avoid future
acquisitions of high-cost supply resources by reducing municipal demands. As a matter
offaimess to ratepayers faced with water bill increases of up to 22%, additional utility-
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Idaho Rivers United
guided and utility-incented conservation opportunities should be offered to mitigate the
impacts of such an increase. An expanded conservation program would also help UWI
avoid expensive supply-side resource acquisitions in the future. UWI's 12-year old
Conservation Plan must be updated as part of this effort.
I. Modified Rate Structure
DO YOU BELIEVE UWI'S PROPOSED RATE CHANGES COULD BE
ALTERED TO BETTER ENCOURAGE CUSTOMERS TO USE WATER
EFFICIENTLY? PLEASE EXPLAIN.
Yes, I believe the rate structure could be improved to encourage efficient use of
water. UWI's Application proposes to maintain its seasonal rate structure, with a 36%
increase in bi-monthly fixed charges to all customers, as well as a 17% increase in
commodity charges (per consumption volume). These fixed and commodity charge
increases amount to a 22% increase in the average residential water bill. (Later in this
testimony I address the proposal made by UWI and the Community Action Partnership
Association of Idaho to adopt an initial lower-cost 3 CCF consumption block.)
The existing rate structure fails to proportionately assign the increasing utility
costs and future water development costs to the high-volume users who place the highest
strain on the water supply system.
First, UWI is seeking to gather most of its revenue increases via the bi-monthly
fixed service charge (36% increase) instead of the commodity charges. This type of
across the board" rate increase approach can be seen as a penalty to average or low-
volume users, and particularly to customers who have voluntarily made efforts to
conserve. High fixed charges may further weaken a customer s incentive to conserve
Wojcik, Di. 3
Idaho Rivers United
since a larger percentage of their bill cannot be changed regardless of whether they waste
water or conserve water.
Mo~e importantly, UWI's seasonal rate structure only provides a limited, and
rather blunt, conservation price signal when moving from winter to summer. However
within each summer season, UWI's rate structure does not provide a price incentive for
conservation because the unit price is constant regardless of the amount of water
consumption in each billing period. To put it another way, on a day-to-day basis during
the summer months, UWI's current rate structure essentially functions as a uniform rate
structure. As a result, this rate structure does not effectively promote efficient water use
during the period of peak use. An increasing block rate structure would send stronger
pricing signals to customers to promote more efficient use.
WHY DO YOU PROPOSE MODIFYING THE UWI SUMMER RATE
STRUCTURE INTO AN INCREASING BLOCK RATE STRUCTURE WITH
MULTIPLE TIERS/BLOCKS?
In general, of the various types of water rate structures, the increasing block rate
structure sends the strongest message of conservation. Not only can it be designed to
curb high volume use and penalize wasteful water users, but it can also reward customers
for being efficient.
The'most significant effects and biggest benefits of increasing block rate
structures occur in summer months, when discretionary outdoor water use dominates the
demand on urban water supplies. The Direct Testimony of Frank Gradilone (Exhibit 6
Schedule 3 , page 6) shows that about 76% ofUWI's total nonnalized annual
Wojcik, Di. 4
Idaho Rivers United
consumption is used in the summer months. Outdoor water use is and will be the
primary driving force behind UWI's need to expand its supply.
These system expansions, supply procurements, and infrastructure upgrades will
translate to higher utility costs, which inevitably will be passed on to UWI customers.
To minimize, delay, or possibly avoid some of these future costs, a stronger conservation
message should be sent to customers now.
To promote efficiency, water rate structures must communicate the true value of
water. Only if the price of water reflects the economic value of water will customers
know whether it is "worth it" to conserve water. The true economic value of water not
only includes the utility s operation and maintenance costs (including billing and
metering), but also includes the costs to procure and develop additional water supplies to
meet growing demands, as well as the social and environmental "opportunity costs" of
losing other benefits of the water in order to develop and consume the water (e.
ecological and recreation values of rivers, local/community economies, values of river
flows for diluting pollutants, etc.). Failing to integrate all of these direct and indirect
costs into a water rate structure is equivalent to subsidizing the cost of water.
An increasing block rate structure charges higher unit prices to customers who use
more water, and lower unit prices to customers who use less. In other words, the unit
prices reflect the strain or demand a customer (and customers like him or her) place on
the water supply system. This design is fundamentally fair, as customers are charged on
the basis of the costs they impose on the utility. Because high-volume users expedite the
need for infrastructure upgrades and new supply procurement, these relatively few high-
volume customers are more expensive for the utility to serve. It would be unfair to pass
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on the costs generated by these relatively few customers to those who use more modest
amounts.
In summary, along with other conservation and efficiency programs, increasing
block rate structures can help stretch existing water supplies further and avoid much of
the cost, delay, and controversy that result from large new water development projects.
designed appropriately, increasing block rates:
Provide water at low prices for basic and essential needs, so all customers can
afford it;
Reward efficient customers with lower unit rates for water;
Send a strong price signal to high-volume and inefficient customers to encourage
more efficient use;
Fairly assign water supply and development costs proportionately to the
customers who place the highest burden on the supply system and the natural
supply sources;
Do all of the above while still maintaining a stable flow of revenue for the utility
to cover its increasing costs.
For an increasing block rate structure to send an effective conservation message to
all customers (low-volume and high-volume), enough blocks need to be established to
cover the full volume range. I recommend a minimum of three blocks, with additional
blocks being added depending on UWI customer use patterns and volumes. The
commodity charges for these blocks need to increase at a percentage that instills a notable
price signal" to the customers.
HOW MUCH USAGE SHOULD BE PRICED AT THE FIRST, LOW-PRICED
BLOCK?
The first, lower-priced block should be equivalent to the average indoor
residential usage per customer. While I support the Stipulation between UWI and the
Community Action Partnership Association of Idaho in concept, I recommend that the
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Idaho Rivers United
initial block be increased to a volume that equals the average total indoor use per billing
period for a residential UWI account (i., not just toilets and showers). The proposed
CCF indoor volume block over a two-month billing period (2 244 gallons) is very low
relative to the average indoor water needs for a residential customer over the same
period. According to Attachment A to the Stipulation, this 3 CCF amount is slightly in
excess of average toilet and shower use during a bill period.
However, most families (low-income or not) use much more than 3 CCF indoors
over a two-month period, even when they re being efficient with their use. Many cities
with increasing block rates set their first block to accommodate all indoor use
(detennined by the city s average winter consumption per residential account per month).
In most cities, this volume typically falls somewhere between 3 000 and 7 000 per month
000-000 gallons bi-monthly). Widely-used studies on water usage (i.e. from the
American Water Works Association Research Foundation studies and other water use
documentation) reveal that the average American uses roughly 69 gallons per capita per
day indoors. This amounts to roughly 4 140 gallons bi-monthly, per person. With an
average U.S. indoor occupancy of2.6 people per household, roughly 10 750 gallons are
used bi-monthly per household account, substantially more than the 2 244 gallons set by
the proposed 3 CCF block. This figure corroborates with the general range of 6 000-
000 gallons bi-monthly that were reported in cities that I have assessed. The bill
frequency data provided by UWI (Exhibit 404) also confinn this range is appropriate, as
43% ofUWI winter-time bills are for less than 10 CCF (7,480 gallons bi-monthly).
Lastly, as it relates to choosing a volume for this "subsistence" use level, I
disagree with an assumption in Attachment A of the Stipulation with respect to the
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Idaho Rivers United
proposed 3 CCF consumption block, that "(iJt is reasonable to assume that low-income
users would be in this low water consumption group. . ..Based on average indoor
water needs for the average residential household, I find no reason to believe that the
10% ofUWI customers using the least amount of water correlates to UWI's low-income
customers. It is more likely that this very low use customer group is more correlated to
single-occupant households than low-income households. Low-income households with
family sizes greater than one or two will have a very difficult time staying within this
subsistence" level. Furthennore, and equally important, it is likely that low-income
customers are residing in older, less-updated housing stock that do not have ULF toilets
low-flow showerheads, or high-efficiency clothes washers. Protection of low-income
customers therefore is another strong policy basis for increasing the "subsistence" indoor
volume above 3 CCF.
WHAT USAGE LEVELS WOULD BE PRICED AT HIGHER RATE BLOCKS?
There is no one single way to set the second, third, or fourth block volumes.
Many design options and strategies exist for setting up an effective increasing block rate
structure. However, to provide a suggested answer to this question, my explanation will
use a hypothetical three-block rate structure as an example. Other options exist (e.
different volume threshold strategies, additional blocks).
I would suggest that the second block include a volume of water that would be
sufficient to allow average, efficient outdoor use in Boise. This can be done by carefully
assessing average customer use patterns in summer months. Alternatively, the second
block volume can be set by calculating an allocation of water that would sustain an
efficiently-watered average landscaped yard in UWI's service area (using
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Idaho Rivers United
evapotranspiration data for common vegetation choice(s) and average lot size or irrigable
area per customer).
Any water use that exceeds this second block volume threshold would fall into the
third block, which could be set at the point where the customer starts using indoor and
outdoor water that exceeds the average needs of UWI customers. Therefore, this is the
point where the strongest conservation price signal should be sent (assuming a three-
block structure).
However, once again, there is no "magic number" for setting block volumes and
prices. Additional blocks can be used to encourage efficient use within the range of
average outdoor water use. Or, as in some cities, an additional "penalty block" is used to
reach customers who use very excessive volumes of water (well above the average indoor
and outdoor volume thresholds).
ARE YOU CONCERNED THAT CUSTOMERS WILL NOT KNOW AT
WHICH POINT IN THE MONTH THEIR USAGE HAS MOVED INTO A HIGHER
RATE BLOCK?
This is frequently raised as a concern with respect to tiered rates. However, many
water providers throughout the interior West have recently instituted increasing block
rate structures. In the Front Range of Colorado, nine of 12 large urban water providers in
a recent sampling are using increasing block rates. In a similar recent effort in Utah
eight of 12 apply increasing block rate structures. See Exhibits 402 & 403; full reports
available at (http://www.westernresourceadvocates.org/water/).
Customers in these cities have "learned" the charging mechanisms, monitored
water use via bills, and adjusted their use accordingly. Also, as with any rate structure
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Idaho Rivers United
change, the corresponding utility holds the responsibility of preparing customers for the
change via appropriate public relations work in the months that precede the change.
Customers typically become much more attentive to their water use when a new
rate structure is enacted. In most cases, customers monitor and learn their use patterns by
viewing their billing statements on a monthly basis. Thus, with any rate structure
change, a clear and explanatory billing statement is vital. Most cities with increasing
block rates send bills that clearly define the blocks and indicate where an individual's use
is with respect to the block-volumes.
If a customer s use extends slightly into the next block, only the volume of use in
that higher block is billed at the higher block rate. Therefore, this customer s resulting
water bill will only be increased by a small amount (by the gallon or CCF amount billed
at the higher block price). Unless the commodity charge increases from block to block
are excessive, the true "price signal" of an increasing block rate structure only becomes
strong or noticeable when a customer s water use extends well into the higher block(s).
DO YOU RECOMMEND UWI ADOPT A MORE FREQUENT BILLING
CYCLE?
Yes. Bi-monthly billing cycles can be counter-productive to water conservation
efforts. As mentioned above, customers interested in conservation or saving money adjust
their home water use on an incremental basis, in response to the consumption reported in
each billing statement. This practice is particularly common during the summer irrigation
months, when urban water use peaks. With a bi-monthly billing cycle, the summer could
be half over by the time customers are notified of their recent consumption quantities.
This may preclude many customers from making more efficient water use decisions
Wojcik, Di.
Idaho Rivers United
earlier in the summer during the high water-use months. Therefore, I recommend that
UWI switch to a monthly billing process. While I recognize this will increase billing
costs, monthly billing is a reasonable and common practice across various utilities.
The bottom line, however, is that customers need to be able to better track their
usage over shorter periods of time than bi-monthly billing alloWs. Advanced meters that
allow for automated meter reading (AMR) can also provide customers with up-to-the-
minute water usage infonnation via remote electronic monitoring devices placed inside
their homes. The City of Aurora, Colorado (suburban Denver) recently implemented a
rebate program for these in-home usage monitors, which sell for about $55. Other cities
have also considered this measure. An investigation into AMR in UWI's service territory
may be warranted as an alternative, or in addition to, more frequent billing.
II. Conservation Programs
PLEASE OUTLINE THE COMPONENTS ,OF A SUCCESSFUL UTILITY
CONSERVATION PROGRAM.
For a conservation program to be effective, four types of policies, incentives, or
practices need to be in place:
Water pricing incentives (via an increasing block rate);
Rebate and retrofit incentives for indoor water saving appliances/fixtures
landscaping, and irrigation system controllers and sensors;
Regulations (e., plumbing, landscaping, and water-waste code); and
Education
Two principles should guide these types of programs. First, it is very important
for a utility to send a consistent message of efficiency. To achieve this consistency, all
attributes that affect customer end use should send a similar message that promotes
conservation, including the rate structure, conservation incentive programs, development
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Idaho Rivers United
, 12
and water use regulations, and education programs. Second, and more importantly, water
customers are human. Therefore, every customer possesses his/her own unique
behavior/action "trigger Some respond solely to pricing, or perhaps other monetary
incentives. Others may not be reachable except through regulatory controls. Yet, for
others, all it may take is an education effort to affect their water use behavior.
DO YOU BELIEVE UWI'S CONSER VA TION PROGRAM OFFERS A
REASONABLE RANGE OF OPPORTUNITIES FOR CUSTOMERS TO LOWER
THEIR USAGE, AND THEREFORE MAINTAIN OR LOWER THEIR BILLS?
PLEASE EXPLAIN.
No. In practice, UWI's current program only employs one of the four program
components I listed above: education. Based on UWI's 1993 conservation plan and
infonnation provided in this case, UWI's conservation program is insubstantial compared
to most other large interior West cities (e., Denver, Albuquerque, Santa Fe, EI Paso
Salt Lake City, Tucson, Las Vegas, Colorado Springs, and Boulder). UWI's response
Staffs Production Request Number 43, including a summary ofUWI's 1993
conservation plan, is attached hereto as Exhibit 405. UWI's response to IRU's Production
Request Number 5 , which outlines the UWI's recent resource planning efforts , is attached
hereto as Exhibit 406.
The education component ofUWI's water conservation program can be
considered commendable and acceptable in tenus of comprehensiveness (via website
classes, etc.). However, since customers must be rather self-motivated to seek education
on water conservation, these programs only tend to tap a small percentage of customers.
Bill flyers, m~dia campaigns, and other widespread education efforts certainly "reach"
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Idaho Rivers United
more customers, but the resulting water savings from such efforts is not easily
documented or proven. Indeed, it is inherently difficult to measure the effectiveness of
education program in actually achieving water savings.
UWI does have a water conservation kit program as well as a water audit
program, which technically falls under the category of customer education. However
based on the very low participation rates of these programs, it appears that program
promotion is not nearly adequate and/or the customers are not sufficiently aware of any
incentives to participate. UWI's response to Idaho Rivers United's Production Request
Number 2 is attached hereto as Exhibit 407. According to that response, only 23 Indoor
Conservation Kits, 29 Outdoor Conservation Kits, and 55 Precipitation Kits were
distributed in 2003, with similar results in 2004 (prior years were not tracked).It is
likely that in most cases the same customer requested the indoor and outdoor kits
simultaneously. Thus, in 2003 and 2004, only 0.06% ofUWI's 75 400 customers
14 'benefited from the indoor/outdoor conservation kit program (or, this translates to 0.07%
ofUWI's 65 210 residential accounts if these kits were only distributed to residential
customers). Relative to water use by all customers, the resulting water savings from
these programs is statistically negligible.
UWI's voluntary water audit program is also realizing low participation numbers.
As provided in response to production req~ests, only 311 water audits were perfonned
from 2000 through 2004. Exhibit 408 (UWI's response to Idaho Rivers United'
Production Request Number 3). This amounts to a participation rate of 0.4% ofUWI's
75,400 customers over this five-year period (or, 0.5% ofUWI's 65 210 residential
23 'customers). All in all, these extremely low participation numbers clearly indicate that
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Idaho Rivers United
UWI customers are not being adequately reached by the audit and conservation kit
programs.
ARE THERE ADDITIONAL CONSERVATION PROGRAMS UWI COULD
IMPLEMENT?
Yes. Some examples of other programs and policies not utilized by UWI are:
Ultra low-flush toilet rebate program
High-efficiency clothes washer rebate program
Landscape rebate program (i., for replacing turf with Xeriscaping, or installing
low-water use trees/shrubs)
Irrigation controller rebate program
Soil moisture sensor rebate (for irrigation system)
Evapotranspiration controller rebate (for irrigation system)
Water use monitoring meter rebate program
Large water user audit program (voluntary or mandatory for high-volume CII
customers)
Large water user savings incentives (e., water bill credits in return for efficiency
upgrades on high-volume CII accounts)
Water-wise landscaping ordinance for new development (would necessitate City
of Boise involvement)
Water-wise building codes and plumbing codes that exceed the requirements of
the 1992 Energy Policy Act:
The starting point for consideration of such programs would be an update and
renewal ofUWI's 1993 conservation plan. I recommend the Commission direct UWI
draft a new conservation plan (including a cost comparison between supply versus
demand-side resources) and submit the plan for the Commission s review as soon as
possible.
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Idaho Rivers United
ARE THERE ANY BARRIERS TO UWI INSTITUTING THESE PROGRAMS?
Yes. The most obvious barrier is that UWI (as an investor-owned utility) can
only lobby for regulatory changes, such as landscaping codes. Relative to other city-
owned utilities, UWI is at somewhat of a disadvantage in fonning a conservation
program that includes municipal regulatory controls on land use and development.
In addition, UWI does not have a dedicated source of funds for conservation
programs, such as a tariff rider collecting a small percentage of revenues each month.
UWI's renewed conservation plan should include an analysis of how best to cover
conservation program costs.
ARE THE CONSERVATION PROGRAMS YOU OUTLINED ABOVE COST
EFFECTIVE?
In general, yes. There is always a risk that programs can be mismanaged, or
under-advertised and simply not reach consumers. But the very nature of water supply
and water use in the West infonns us that conservation is an economically appropriate
investment. Unlike electricity supplies, which can be expanded, water supplies are finite.
Given the finite nature of water in the semi-arid and arid interior West, the cost of
developing and supplying this finite resource will continue to increase as demands
increase. Burgeoning urban populations in our interior West cities combined with
predictable drought cycles will continue to pressure water utilities to seek new supply
sources as long as our current per capita demands persist.
However, water conservation, and subsequent demand reduction, can playa
22,significant role in offering a solution to this finite resource problem. With urban
population growth and drought cycles being virtually inevitable in most interior West
Wojcik, Di. 15
Idaho Rivers United
urban centers, aggressive conservation efforts can serve as an alternative and more cost-
effective source for meeting the demands brought by new growth. In fact, just as
traditional procurement and development of new water ~upplies will undoubtedly
increase over time as more of the finite resource is tapped, the cost of water conservation
will likely decrease due to improved technology, more water-wise policies, and an
improved public awareness.
Various municipal water utilities around the region have reported that
conservation efforts are becoming notably more cost-effective than traditional supply
development options, when compared in dollars per acre-foot. The time and costs of
environmental pennitting, infrastructure expansion, and other displaced economies (e.
recreation, tourism, etc.) are only a few of the attributes to the increasing costs of water
supply development. Unfortunately, a lack of conservation program monitoring and a
relatively short history of water conservation implementation, has yielded a significant
data gap" in the water supply industry. Unlike with traditional supply options, accurate
and reliable cost-effectiveness data for water conservation options is rather limited.
However, more and more water utilities that see the potential water savings and
subsequent cost savings brought by active conservation are beginning to implement and
closely-monitor a wide variety of conservation measures.
The City of Albuquerque is a good example of cities that are actively utilizing a
comprehensive conservation program as a primary and cost-effective future supply
source. Although Albuquerque is experiencing steady population growth, it has managed
to address the water needs of most of this growth via demand reduction per capita. From
1995 to 2004, the City reduced its system-wide per capita demand by 28% and has set a
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Idaho Rivers United
target to reach 40% reduction by 2014. In 1995 , Albuquerque consumed over 125 000
acre-feet of water. Ten years later in 2004, the city consumed roughly 110 000 acre-feet
of water. Over this same period of time, Albuquerque s growth yielded roughly 25 000
new water accounts (from approximately 135 000 accounts to nearly 160 000 accounts).
Albuquerque s wide-reaching conservation program and water-wise development
standards played a vital role in this effort, which included indoor and outdoor rebate
programs and incentives, education efforts, and aggressive media campaigns. During
this 10-year time period when Albuquerque s conservation program took hold, the
program accounts for the installation of more than 48 500 ultra-low-flow toilets, 6 146
high-efficiency washing machines, 9 964 low-flow showerheads, 643 high-efficiency
dishwashers; and 271 hot water recirculation systems. Albuquerque utility staff
conducted 9 733 residential water use audits up to mid-2004.
WHAT IS YOUR RECOMMENDATION TO THE COMMISSION?
I recommend the Commission find that UWI should implement a variety of
modifications to its water rate structure, conservation program, billing, and long-range
planning. Instead of raising rates across the board as proposed (increases in bi-monthly
fixed charge and winter and summer commodity charges), I recommend the Commission
order UWI to do the following:
(1) Modify water rate structure to an effective increasing block rate structure, with a
minimum of three blocks/tiers and block prices that reward for conservation and
charge notably higher commodity rates for high-volume use.
(2) Set an initial low-volume indoor block at the average indoor use volume for
residential customers. Ideally, this block price should be set at or below cost to
provide a reward incentive for low-volume or conserving customers.
Wojcik, Di. 17
Idaho Rivers United
(3) Institute monthly billing to give customers more frequent opportunities to monitor
water use and make appropriate adjustments from month to month.
(4) Develop and submit for Commission approval an updated and comprehensive
conservation plan as soon as possible following this case. This plan should
, include a cost comparison between supply versus demand resources, and also
analyze means of funding additional further conservation program costs.
(5) Implement the new conservation plan to effectively encourage efficient water use
by all customers and provide incentives and opportunities for customers to
mitigate the financial impacts of increased water rates. Work with the City of
Boise Planning and Development Services Department and the Boise City
Council to consider a water-wise landscaping ordinance for new development and
establish a higher level of water-efficiency in the Boise plumbi~g code.
Q. DOES THIS CONCLUDE YOUR TESTIMONY?
A. Yes
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Idaho Rivers United