The URL can be used to link to this page

Home My WebLink About20050609Post hearing brief.pdfAD VOCATESJ~WESTPublic Interest Environmental Law June 9, 2005 ~ECEivEb FILEt ZI15JUN -"'"'2: 2. fn~' , " 'uMrlQ PUBLIC uTILITIES COH'MISSIOH Jean Jewell Commission Secretary Idaho Public Utilities Commission 472 W. Washington St. Boise, ID 83702 Re: UWI - W -04- Dear Ms. Jewell: Please find enclosed an original and seven (7) copies each of Idaho Rivers United's Post- Hearing Brief and Application for Intervenor Funding. Sincerely, William M. Ed Ie On behalf of Idaho Rivers United I certify that I served true and correct copies of Idaho Rivers United's Post-Hearing Brief and Application for Intervenor Funding on the parties listed below via U.S. Mail. Via Hand Delivery: Weldon Stutzman Donovan E. Walker Idaho Public Utilities Commission O. Box 83720 Boise, ID 83720 Mark Gennari United Water 200 Old Hook Rd. Harrington Park, NJ 07640-1738 Douglas Strickling Boise City Attorney s Office O. Box 500 Boise, ID 83701 All others via U.S. Mail: Dean J. Miller McDevitt & Miller LLP 420 W. Bannock St Boise, ID 83702 Chuck Mickelson City of Boise O. Box 500 Boise, ID 83701 p.o. Box 1612, Boise, 1083701 208-342-7024 Fax: 208-342-8286 www.AdvocatesWest.org Brad M. Purdy 2019 N. 1 ih St. Boise, ID 83702 Scott L. Campbell o. Box 829 Boise, ID 83701 Sharon Ullman 9627 W. Desert Ave. Boise, ID 83709 William M. Eddie RECEIVED :.1 r::-li , ' 1\1\, i l--' 7uu5JU~t -~ PM 12: , iDAHO PUBLIC UTIL1TIES COMMiSSION William M. Eddie (ISB# 5800) ADVOCATES FOR THE WEST O. Box 1612 Boise, ID 83701 (208) 342-7024 fax: (208) 342-8286 billeddie~rmci.net 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- IDAHO RIVERS UNITED'S POST-HEARING BRIEF Idaho Rivers United ("IRU") provides this post-hearing brief to succinctly identify key points of fact relating to: (1) IRU's request for increased conservation programs by UWI; and (2) the implementation of an inverted block rate structure for UWI, and other rate design and billing issues. The testimony presented in this case strongly confirms the need for UWI both to increase its investment in conservation programs, and to send a strong price message encouraging conservation. As UWI witness Scott Rhead described at hearing, it has been relatively difficult and expensive in 2005 for the Company to acquire sufficient water supplies to be assured of meeting its customers' needs. The general policy principles that underlie Don Wojcik's direct testimony - that water supplies are finite and IRU'S POST-HEARING BRIEF -- subject to cycles of drought, but population growth is driving increased demand - are borne out in the specific situation faced by UWI. THE COMMISSION SHOULD ORDER UWI TO COMPLETE ITS CONSERVATION PLAN FOR IMPLEMENTATION IN 2006 UWI has agreed with IRU's request for an updated and renewed conservation planning effort: "The Company believes it should undertake the task of procuring an outside consulting firm to assist in developing a new comprehensive conservation plan with the final plan and recommendations being submitted to the Commission for review. Wyatt Rebuttal at 18 , lines 2- Given the ongoing drought in Idaho, the increasing costs for water supplies from local water rental pools, the increasing difficulty in securing new or transferred water rights for municipal purposes, and UWI's very modest current conservation efforts (see Wojcik Direct Testimony at 12-14), IRU submits that the Company s "new comprehensive conservation plan" should be prepared with all due speed. Specifically, IRU requests that the plan be submitted to the Commission no later than December 15 2005 , so as to make additional conservation programs available for implementation by UWI customers prior to summer 2006. The plan should include recommendations for implementation of conservation programs, including rebate and retrofit incentives for water-saving devices, landscaping, or other measures; the plan should also evaluate educational programs on water conservation, as well as the potential to work with the City of Boise or other entities toward the establishment of water-saving regulatory measures. The plan should also evaluate and recommend to the Commission appropriate means of funding such programs. IRU'S POST-HEARING BRIEF -- 2 II.RATE DESIGN AND MONTHLY BILLING The Stipulation entered between UWI and Community Action Partnership Association of Idaho ("CAP AI") proposes to adopt a two-block rate structure, albeit with a very small first block. However, the level of usage of2 CCF/month for the first block as identified in the Stipulation and later modified in UWI testimony, does not truly represent a level of non-discretionary or "subsistence" water use by a residential customer. Wojcik Testimony at 7-8. IRU requests the Cohnnission avoid setting rates that send a "conservation message" to customers for both their discretionary and non- discretionary usage of water. Rather, the conservation message should target more discretionary usage of water, such as outdoor uses of water in the summertime. IRU requests the Commission establish an interim two-block rate structure that would apply year-round, with the first lower-priced block set at a level of average indoor use. Exhibit 404 in this matter identifies median winter time use by residential customers UWI as between 10 CCF and 15 CCF bi-monthly, or between 5 CCF and 7.5 CCF per month. This range of usage is representative of year-round indoor use by the typical UWI customer. The second block should be priced to send a distinct, but not punitive conservation signal. The current 25% differential between summer and winter rates is logical starting point for this differential. UWI should be ordered to return to the Commission within short time period with tariffs implementing this basic structure. IRU also requests the Commission open a new docket to investigate the establishment of additional higher usage blocks, intended to lead to the ultimate establishment of a rate design that is fair and equitable to all customers, and sends IRU'S POST-HEARING BRIEF -- 3 appropriate conservation signals. Wojcik Direct, 8-9. This investigative docket could also be used to fine tune an initial two-block structure, should the Commission choose to adopt that structure. IRU will agree to file an application initiating this docket, if the Commission agrees the investigation should go forward. With respect to other rate design' and billing issues, IRU request that current customer charges assessed by UWI remain the same so as to avoid diminishing customers' incentive to conserve. Sterling Direct at 52-56; Wojcik Direct at 3 , lines 19- 23 and 4, lines 1-2. In addition, both Staff and IRU recommended UWI implement monthly billing so as to provide customers with more frequent information on their usage rates. Sterling Direct at 59-61; Wojcik Direct at 10-11. CONCLUSION IRU requests the Commission (1) order UWI to file a comprehensive conservation plan no later than December 15 2005; (2) order UWI to implement a two- block rate structure, with the initial block set at average winter time use within each meter size category, and a distinct price differential in the second block; (3) order IRU to file an application initiating a new investigative docket to study the establishment of additional rate blocks designed to send appropriate conservation signal; (4) make no change to the total amount of customer charges assessed by UWI; and (5) order UWI to implement monthly billing. Dated: June 9, 2005 Respectfully submitted William M. Eddie Attorney for Idaho Rivers United IRU'S POST -HEARING BRIEF -- 4