200503081st Response to IRU .pdf

ORIGINAL
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znns MAR - 7 Pi, 4: 42Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
ioe~mcqevitt-miller.com
" It;lid FUBLIC
UTILITIES COr"U1ISS10N
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-O4-
FIRST RESPONSE OF UWlD
TO IDAHO RIVERS UNITED'
PRODUCTION REQUESTS
COMES NOW United Water Idaho Inc. ("United"
, "
the Company ) and responds to
Request Numbers 1 , 3 and 4 of the Production Requests of Idaho Rivers United.
Dated this day of March, 2005.
McDEVITT & MILLER LLP
~t~
Dean . Miller
Attorneys for United Water Idaho Inc.
FIRST RESPONSE OF UWID TO IDAHO RIVERS UNITED'S PRODUCTION REQUESTS-
CERTIFICATE OF SERVICE
I hereby certify that on the ay of March, 2005, I caused to be served, via the method(s) indicated below, true and
correct copies of the foregoing document, upon:
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Fax
Fed. Express
Email
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Brad M. Purdy
Attorney for the Community Action Partnership
Association of Idaho
2019 North 17th Street
Boise, Idaho 83702
Fax: [phone]
bm urd hotmail.com
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William M. Eddie
Advocates for the West
O. Box 1612-83701
1320 West Franklin Street
Boise, Idaho 83702
Fax: [phone]
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Bill Sedivy
Idaho Rivers United
O. Box 633
Boise, Idaho 83701
Fax: [phone]
iru~id1!..hori vers. org
Sharon Ullman
9627 West Desert Avenue
Boise, Idaho 83709
Fax: [phone]
~haronu~cableone.net
Chuck Mickelson
Boise City Public Works
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]
~son~cityofboise.org
Douglas K. Strickling
Boise City Attorney s Office
O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Fax: [phone]
~ing~cityotboise.org
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Scott L. Campbell
Moffatt Thomas
101 South Capitol Blvd., 10th Floor
O. Box 829-83701-0829
Boise, Idaho 83702
Fax: [phone]
~lc~moffatt.com
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IDAH ~RODU CTION RE QUESTS--2ONSE
UNITED WATER IDAHO INC.
CASE UWI-O4-
FIRST PRODUCTION REQUEST OF IDAHO RIVERS UNITED
Preparer/Recordholder/Sponsoring Witness: Gregory P. Wyatt
Telephone: [phone]
Title: General Manager
REQUEST NO.
Please state the source of funding for the Company s water conservation efforts
described in the Direct Testimony of Gregory Wyatt, pages 13-15.
RESPONSE NO.
United Water Idaho s water conservation efforts as described in the testimony of
Company Witness Gregory P. Wyatt, pages 13-15 are necessary and legitimate
business expenses and included in the overall revenue requirement of the
Company and therefore funded out of general water revenues from customers.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FIRST PRODUCTION REQUEST OF IDAHO RIVERS UNITED
Preparer/Recordholder/Sponsoring Witness: Gregory P. Wyatt
Telephone: [phone]
Title: General Manager
REQUEST NO.
Please state the number of Indoor Water Conservation Kits and Outdoor Water
Kits the Company has given away during 2002 , 2003 and 2004.
RESPONSE NO.
United Water provides Indoor Water Conservation Kits, Outdoor Water Kits and
Precipitation Kits free of charge to all customers who request them. They can be
obtained at the Company s offices at Victory Road during normal business hours.
The number of kits distributed by year is as follows:
2002 - the number of kits given away was not tracked.
2003 - 23 Indoor Kits, 29 Outdoor Kits, 55 Precipitation Kits.
2004 - 27 Indoor Kits, 21 Outdoor Kits, 55 Precipitation Kits.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FIRST PRODUCTION REQUEST OF IDAHO RIVERS UNITED
Preparer/Recordholder/Sponsoring Witness: Gregory P. Wyatt
Telephone: [phone]
Title: General Manager
REQUEST NO.
Please state the number of Water Audits performed by the Company during
2002 2003 and 2004.
RESPONSE NO.
Due to a steady decline in customer response to direct mailers soliciting water
audits in 2000 (220 water audits) and 2001 (80 water audits), the Company
decided it would be more cost effective to target customers who called in
because of a high bill. It was believed that generally those customers were
frustrated and looking for ways to reduce their water use and would be interested
to receive help and instruction including a water audit. United Water s Customer
Service Representatives currently forward these customer calls to our Outreach
and Education Coordinator for follow-up after the normal billing related questions
are resolved.
United Water found , however, that most of the customers who called in through
this process were not interested in having a water audit performed , but requested
that water conservation brochures and flyers be mailed to them instead, which
was done. Since 2002, eleven customer water audits have been performed.
Other outreach efforts were employed more recently to help customers conserve
water on their lawns and landscaping through slide and PowerPoint
presentations at seminars, brown bag lunches , and club meetings such as
Kiwanis. United Water partnered with the Idaho Department of Water Resources
and the Bureau of Reclamation on a conservation seminar targeting large
buildings in the governmental and private sector. During the summers of 2003
and 2004 United Water offered an outdoor water conservation seminar at the
Idaho Botanical Garden where attendees learned how to measure the application
rate of their sprinkler system and received water conservation brochures and
precipitation cups that help them measure the output of their sprinkler systems.
These efforts were accompanied in 2004 with newspaper, radio and television
information specifically addressing water conservation both inside and outside
the home, and specifically focused on irrigation related conservation.
UNITED WATER IDAHO INC.
CASE UWI-O4-
FIRST PRODUCTION REQUEST OF IDAHO RIVERS UNITED
Preparer/Recordholder/Sponsoring Witness: Gregory P. Wyatt
Telephone: [phone]
Title: General Manager
REQUEST NO.
Please describe the Company s marketing program specifically to promote the
availability of the Indoor Water Conservation Kits, Outdoor Water Kits, and Water
Audits.
RESPONSE NO.
United Water promotes the availability of the free "water conservation kits
through a variety of methods. These include United Water s website, customer
contact during phone conversations with Customer Service Representations and
the Outreach and Education Coordinator, in the field when Servicemen meet with
customers during a leak check, during the annual Water Efficient Landscaping
classes, at United Water sponsored booths for the annual Earth Day Celebration
and this years Home Remodeling Show, and a variety of television interviews on
the topic of indoor and outdoor water conservation. Attached is a summary of
the Company s water conservation related events and efforts for 2002, 2003 and
2004.