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Home My WebLink About20190506Amended Petition.pdfGIvENS PunsLEY,,. Attorneys and Counselors at Law 601 W. Bonnock Street PO Bax272A Boise. lD 83701 Telephone: 208-388-1 200 Focsimile: 208-388-l 300 ww.givenspumley.com Michoel C. Creomer l2o8) 388-1247 mcreomer@givenspu6ley.com Gory G. Allen Chris'lopher J. Beeson Joson J. Blokley Clint R. Bolinder Jeff W. Bower Preston N. Corter Jeremy C. Chou Williom C. Cole Michoel C. Creomer Amber N. Dino Brodley J. Dixon Thomos E. Dvorok Jeffrey C. Feredoy Deboro Kristensen Groshom Morlin C. Hendrickson Brion J. Holleron RECEIVED HffiSf;flB,*S'?H 3'az Jock W. Re f T*l?fiFf"u"r uBLrc;;,TJilXffi$ COMMIS 8r0N Kersti H, Kennedy Neol A. Koskello Michoel P. Lowrence Fronklin G. Lee Dovid R. Lombordi Kimberly D. Moloney Kennelh R. McClure Kelly Greene McConnell Alex P. McLoughlin Melodle A. McQuode Christopher H. Meyer L. Edword Miller Poirick J- Miller Judson B. Monlgomery Emily G. Mueller Deboroh E. Nelson .lelfrey A. Wotr Roberl B. White Donold E. Knickrehm lrelired) Kennelh L. Pureley (r940-2015) Jomes A. Mcclure (r924-20r r) Roymond D. Givens (1917-2008) May 6,2079 Via Hand Delivery Diane Hanian, Secretary Idaho Public Utilities Commission 472 W . Washington Street Boise, Idaho 83720 Case Nos. SUZ-W-19-01 SUEZ Water Idaho Inc.'s Petition for Exemption from Customer Relations Rules 3 1 1(4) and (s). Dear Ms. Hanian Enclosed for filing is an original and seven (7) copies of SUEZ Water Idaho Inc.'s. Amended Petition for Exemption from Customer Relations Rules 3l l(4) and (5). 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 retumed. Should you have any questions, please do not hesitate to contact me. MCC Enclosures 146291 I 3_l .docx Re Michael C. Creamer, ISB #030 GIVENS PURSLEY LLP 601 W. Bannock St. P.O. Box 2720 Boise, ldaho 83701 -2720 Telephone: 208-388-1200 Facsimile: 208-388-1300 mcc@g ivenspu rslev. com Attomeys for Petitioner SUEZ Water ldaho lnc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION RECEIVED ?0l9l,lfiY -6 plt 3: 32 ,rLHmccL?f*l8r,o* IN THE MATTER OF SUEZ WATER IDAHO INC.'S PETITION FOR AN EXEMPTION FROM UTILITY CUSTOMER RELATIONS RULES 311(41AND (5) Case No. SUZ-W-19-0f AMENDED 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, submits this Amended Petition for Exemption ("Amended Petition") in the above-captioned docket. SUEZ respectfully requests that the ldaho Public Utilities Commission ("Commission") issue an Order exempting SUEZ from the requirements of UCCR 311(4) and (5), which require utilities to attempt to make face-to-face customer contacts and accept payments of past-due bills from a customer at the time of a disconnection of service. SUEZ also requests Commission approval of SUEZ's proposal to waive customer Western Union payment processing fees, to pay those fees on behalf of its customers, and to defer those costs until its next general rate case to be included in rates and recovered over three years. SUEZ also requests Commission approval of a related housekeeping modification to AMENDED PETITION FOR EXEMPTION .. 1 Schedule 5 of SUEZs Rules and Regulations (N/iscellaneous Fees and Charges - Sheets 9-10) to eliminate reference to the current $15 Field Collection Trip Charge. 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 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 M. Cary, previously filed with SUEZ's original 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.thompson@suez. com Michael C. Creamer Givens Pursley LLP 601 W. Bannock St. Boise, lD 837A2 P.O. Box 2720-83701 m cc@o ivenspu rslev. com AMENDED PETITION FOR EXEMPTION .. 2 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. IV. REQUEST FOR MODIFIED PROCEDURE SUEZ believes that a hearing is not necessary to consider the requested exemption. SUEZ therefore respectfully requests that this matter proceed under l\4odified 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: 1. Exempting SUEZ from the provisions of Utility Customer Relations Rules 311.04 and .05 requiring its field customer service persons to attempt face-to-face contact with the customer before disconnecting service, to accept on-site payments by customer at the time of disconnection, and to post a notice on a customer's premises door at the time of disconnect where remote metering is in place; 2. Providing that the requested exemption would become effective not sooner than four months after the date of issuance of such Order to allow SUEZ an appropriate period of time to notify its customers of the approved changes to its customer notification, payment and disconnection process. 3. Approving SUEZ's proposal to waive all customer Western Union payment processing fees by paying those convenience fees on behalf of its customers, and authorizing deferral of those costs until its next rate case and recovery of the deferred AMENDED PETITION FOR EXEMPTION .. 3 amount over three years, following which the processing fees paid by SUEZ would become a normal operating expense; and 4. Approving modification of SUEZ's Schedule 5 ("Miscellaneous Fees and Charges") on file with the Commission to remove the $15.00 Field Collection Trip Charge; SUEZ to file a conforming schedule as directed by the Commission order. Respectfully submitted this 6th day of May, 2019. SUEZ Water ldaho lnc. By tvi C. Creamer Givens Pursley LLP Attomeys for SUEZ Water ldaho lnc. AMENDED PETITION FOR EXEMPTION -. 4