20190417Petition.pdf

GTvENS PunsLEY,,.
Attorneys and Counselors at Law
601 W. Bonnock Street
PO Box2720
Boise, lD 83701
Telephone: 208-388- I 2@
Focsimile: 208-388-l 300
ww.givenspuEley.com
Michoel C. Creomer(M)W-1247
[e-mail]
Gory G. Allen
Christopher J. Beeson
Joson J. Blokley
Clinl R. Bolinder
Jeff W. Bower
Pres'ton N. Corler
Jeremy C. Chou
Williom C. Cole
Michoel C. Creomer
Amber N. Dino
Brodley J. Dixon
Thomos E. Dvorok
Jeffrey C. Feredoy
Deboro Krisiensen Groshom
Mortin C. Hendrickson
Bdon J. Holleron
Kersti H, Kennedy
Neol A. Koskello
Michoel P. Lowrence
Fronklin G. Lee
Dovid R. Lombordi
Kimberly D. Moloney
Kenneth R. McClure
Kelly Grene Mcconnell
Alex P. McLoughlin
Melodie A. McQuode
Chrislopher H. Meyer
L. Edword Miller
Potrick J. Miller
Judson B. Monlgomery
Emily G. Mueller
Deboroh E. Nelson
w. Hugh O'Rlordon, LL.M.
Rondoll A. Petermon
Jock W. Relf
Michoel O. Roe
Jomie Coplon Smith
P. Mork Thompson
Jeffrey A. Wor
Robert B. White
Donold E. Knickrehm (retired)
Kenneth L. Pursley {r940-20r5l
Jomes A. Mcclure (1924-2ot r)
Roymond D. Givens (r9r7-2008)
April17,2019
Via Hand Delivery
Diane Hanian, Secretary
Idaho Public Utilities Commission
472 W . Washington Street
Boise,Idaho 83720
Case Nos. SUZ-W-I9-01
SUEZ Water Idaho Inc.'s Petition for Exemption from Customer Relations Rules
3 1 I (4) and (5).
Dear Ms. Hanian:
Enclosed for filing is an original and seven (7) copies of SUEZ Water Idaho Inc.'s.
Petition for Exemption from Customer Relations Rules 311(4) and (5).
Also enclosed for filing are the original and nine (9) copies of the Direct Testimony of
Jarmila Cary. One copy of each of the Testimony has been designated as the "Reporter's Copy."
In addition, a disc containing searchable PDFs of the Application and the Testimony is
also enclosed.
An additional copy of each document is enclosed to be date stamped and returned.
Should you have any questions, please do not hesitate to contact me.
S
MCC
Enclosures
146291 l3_1.docx
,t
-o
Cr)
Cl:
Re:
C.
ORIOINAL
Michael C. Creamer, ISB #030
GIVENS PURSLEY LLP
601 W. Bannock St.
P.O. Box 2720
Boise, ldaho 83701 -2720
Telephone: [phone]
Facsimile: 208-388-1 300
m cc@q ive n s p u rsley- com
::ii:ii:it/Eil
Iii*;ii.; i T Pi,l 3: t+5
C
$S U
Attomeys for Petitioner SUEZ Water ldaho lnc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF SUEZ WATER
IDAHO INC.'S PETITION FOR AN
EXEMPTION FROM UTILITY
CUSTOMER RELATIONS RULES
311(4) AND (5)
Case No. SUZ-W-19-01
PETITION FOR EXEMPTION
SUEZ Water ldaho lnc. ("SUEZ"), through its undersigned counsel of record,
Givens Pursley LLP, and pursuant to Rule of Procedure 053 and Utility Customer
Relations Rules ("UCCR') 003.01 and 009, requests that the ldaho Public Utilities
Commission ("Commission") issue an Order exempting SUEZ from the requirements of
UCCR 31 1(4) and (5), which require utilities to attempt to make faceto-face customer
contacts and accept payments of past-due bills from a customer at the time of a
disconnection of service. SUEZ also is requesting Commission approval of SUEZ's
proposal to discontinue accepting customer payments at its central office.
I. GROUNDS FOR THE REQUESTED EXEMPTION
SUEZ submits that increased concern for the safety of its employees and the
public constitute an unusual or unreasonable hardship that warrant SUEZ's permanent
exemption from UCCR 003 and 0009. SUEZ further submits that SUEZ's proposed
PETITION FOR EXEMPTION .. 1
additional past-due and pre-disconnect customer notices, improved payment options
and its proposed plan for deployment of smart metering mitigate any perceived adverse
impacts to its customers that might be attributable to the requested exemption. The
grounds for SUEZ's request and implications of an exemption for SUEZ and its
customers are set forth in detail in the Direct Testimony of Jarmila [\I. Cary, which is
being filed contemporaneously with this Petition.
II. COMMUNICATIONS AND SERVICE OF PLEADINGS
Communications and service of pleadings in this matter should be sent to the
following.
Mr. Marshall Thompson
SUEZ Water ldaho lnc.
8284 West Victory Rd.
Boise, lD 83709
marshall.thomp son(osuez.com
ttllichael C. Creamer
Givens Pursley LLP
601 W. Bannock St.
Boise, lD 83702
P.O. Box 2720-83701
mcc@q ivensp u rsley. com
III. PRE.FILING CONFERRAL
Prior to filing this Petition SUEZ has met and conferred with members of the
Commission Staff and with the Executive Director of Community Action Partnership
Association of ldaho concerning the requested exemption.
PETITION FOR EXEMPTION .. 2
IV. REQUEST FOR MODIFIED PROCEDURE
SUEZ believes that a hearing is not necessary to consider the requested
exemption. SUEZ therefore respectfully requests that this Petition proceed under
Modified Procedure pursuant to Commission Rules of Procedure 201-204.
V. REQUEST FOR RELIEF
For the reasons set forth above and in its supporting testimony, SUEZ
respectfully requests this Commission to issue an Order approving SUEZ's exemption
from UCCR 311(4) and (5) to become effective four months after the date of issuance of
such Order to provide SUEZ an appropriate period of time to notify its customers of the
approved changes to its customer notification, payment and disconnection process.
Respectfully submitted this k^, of April, 2019.
SUEZ Water ldaho lnc.
By:
Michael C. Creamer
Givens Pursley LLP
Attorneys for SUEZ Water ldaho lnc.
PETITION FOR EXEMPTION .. 3