200502281st Production Request from IRU.pdf

William M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
O. Box 1612
Boise, ID 83701
[phone]
fax: [phone]
billeddie~nnci.net
r~
(""".
t~t0t- I
,-.. c
fy'
2DtiSFEB 28 JUi 8:41. I HU j)UbLIGUTILITIES COMMISSION
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-
FIRST PRODUCTION REQUESTS OF IDAHO RIVERS UNITED
Intervenor Idaho Rivers United, by and through counsel, requests that United Water
Idaho, Inc. ("UWI" or "Company ) provide the following infonnation.
This Production Request is considered to by continuing, and the Company is requested
provide, by way of supplementary responses, additional documents or infonnation that it or any
person acting on its behalf may later obtain that will augment the information or documents
..'
produced.
In answering each request, please provide the name of the person( s) preparing the
answers, along with the title and function such individual holds with the Company and the
witness who can sponsor the answer at the hearing.
FIRST PRODUCTION REQUESTS OF IDAHO RIVERS UNITED --
REQUEST NO.1: Please state the source of funding for the Company s water
conservation efforts described in the Direct Testimony of Gregory Wyatt, pages 13-15.
REQUEST NO.2: Please state the number of Indoor Water Conservation Kits
the Company has given away during 2002, 2003 and 2004.
REQUEST NO.3: Please describe the Company s marketing program
specifically to promote the availability of the Indoor Water Conservation Kits, Outdoor
Water kits, and Water Audits.
REQUEST NO.4: Has the Company prepared a Least Cost Plan, Integrated
Resource Plan, or the functional equivalent thereof, to analyze the relative costs of
acquiring supply-side versus demand-side resources so as to provide reasonable and
adequate service to customers? Please provide the same.
DATED this 24th day of February, 2005.
William M. Eddie
On behalf of Idaho Rivers United
FIRST PRODUCTION REQUESTS OF IDAHO RIVERS UNITED -- 2
CERTIFICATE OF SERVICE
. ."""""~~
I hereby certify that ~n this )41iay of February, true and correct copies of the
foregoing FIRST PRODUCTION REQUESTS were delivered to the following persons
via the method of service noted:
Via U.S. Mail:
Dean J. Miller
McDevitt & Miller LLP
420 W. Bannock St
Boise, ID 83702
Douglas Strickling
Boise City Attorney s Office
O. Box 500
Boise, ID 83701
Mark Gennari
United Water
200 Old Hook Rd.
Harrington Park, NJ 07640-1738
Chuck Mickelson
City of Boise
O. Box 500
Boise, ID 83701
Brad M. Purdy
2019 N. 1 ih St.
Boise, ill 83702
Weldon Stutzman
Donovan E. Walker
Deputy Attorneys General
Idaho Public Utilities Commission
o. Box 83720
Boise, ID 83720
Scott L. Campbell
O. Box 829
Boise, ill 83701
SharonUI1man
9627 W. Desert Ave.
Boise, ID 83709
William M. Eddie
FIRST PRODUCTION REQUESTS OF IDAHO RIVERS UNITED -- 3