20190718Comments.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLTC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
NTCEIVID
2819 JUL l8 PH 2: 52
IilAi:C' F.USLIC
J'I i LiT i :S CO[,iM ISSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORB THE IDAHO PUBLIC UTILITIBS COMMISSION
IN THE MATTER OF SUEZ WATER IDAHO )
INC.'S PETITION FOR AN EXEMPTION FROM )CASE NO. SUZ.W.19.O1
UTILITY CUSTOMER RELATIONS RULES
311(4) AND (s)
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission comments as follows on SUEZ Water
Idaho Inc.'s Amended Petition.
BACKGROUND
On April 17 ,2019, SUEZ Water Idaho Inc. ("SUEZ" or "the Company") filed a Petition
with the Commission. After consulting with Staff, SUEZ filed an Amended Petition on May 6,
2019 to clarify the scope of SUEZ's requests. The Amended Petition made four requests for
relief.
First, SUEZ petitioned the Commission for an Order exempting it from Utility Customer
Relations Rules 3l1.04 and .05 IDAPA 31.21.01.31L04 and .05. See Attachment No. l. In
summary, these rules require a utility employee to try to make face-to-face contact immediately
before terminating the customer's service for non-payment to: (l) give the customer a final
chance to avoid termination of service by paying the bill at that time (see UCRR 31 1.04); or
)
)
)
)
)
1STAFF COMMENTS JULY 18,20I9
(2) if the customer does not pay at that time, notiff the customer about how the customer can
have service reconnected (see UCRR 3l 1.05).
Second, SUEZ petitioned that the exemption not become effective sooner than four
months after the Commission issues its Order granting the exemption.
Third, SUEZ petitioned the Commission to approve SUEZ's proposal to waive all
customer Westem Union payment convenience fees, assume responsibility for payment
processing costs, and include this cost in future general rate cases. All of SUEZ's third-party
payment processing fees are shown in Attachment No. 2. SUEZ asked that it be authorized to
defer the Western Union fees costs until its next rate case and recover the deferred amount over
three years. Thereafter, the processing costs would become a normal operating expense.
Finally, SUEZ petitioned to modify Schedule 5 ("Miscellaneous Fees and Charges") to
remove the $15.00 Field Collection Trip Charge. This petition is related to SUEZ's request to
be exempted from UCRR 31 1.04 and .05 so that SUEZ personnel would no longer be required
to accept payments of past-due bills directly from a customer at the time of disconnection of
servlce.
STAFF REVIEW
Staff has reviewed the Amended Petition and supports the Company's request for an
exemption from Utility Customer Relations Rules 3l 1.04 and .05 and recommends that
customers no longer be required to pay processing fees (aka convenience fees) to the Company's
third-party vendor, Western Union. As a result, the Company will assume responsibility for the
cost of handling Western Union payment transactions. Staff recommends approval of the
Company's request to defer this cost into a regulatory asset for later recovery in rates. Staff also
recommends that the Company be allowed to discontinue accepting payments at its local office
in Boise and that the Company's $15.00 Field Collection Trip Charge be removed from its
Tariff. Additionally, Staff recommends reduction of the reconnection charge in locations where
the Company has installed meters capable of disconnection and reconnecting remotely. Finally,
Staff recommends approval of the Company's request for an effective date four months
following Commission approval.
A detailed discussion of Staff s analysis is provided below.
2STAFF COMMENTS JULY I8,2OI9
Request for Exemption from Provisions of UCRR 311.04 and .05
The Company requests the rule exemption in order to address safety issues that can arise
when its employees make face-to-face contact at a customer's premise prior to terminating
service. In its Amended Petition, the Company expresses its increased concem for the safety of
its employees and the public and maintains that the Commission's rules impose an unusual or
unreasonable hardship on the Company, thus warranting a permanent exemption from Rules
31 1.04 and .05. In support of its request, the Company submits that "[The Company]'s proposed
additional past-due and pre-disconnect 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." See Amended Petition at 2.
Specifically, Suez seeks to:
l. Discontinue its practice of knocking on the customer's door, leaving a disconnection
notice, and/or accepting payment prior to disconnection, as currently required by
UCRR 311.04 and .05;
2. Make additional attempts to notify affected customers regarding collection of past due
amounts and potential disconnection of service prior to a premise visit by a Company
employee; and
3. Deploy special smart meters that will allow the Company to disconnect and reconnect
service without actually having to make a premise visit at locations where employee
safety is at risk or there is a history of multiple disconnections due to non-payment.
Staff notes that the Commission has previously granted an exemption to UCRR 3l 1.04
and .05 to Idaho Power Company, Rocky Mountain Power, and Avista. In Order No. 33229, the
Commission stated:
As discussed below, we find that the Utilities (and their customers) face
unusual or uffeasonable hardships under, and should be exempted from,
UCRR 311.04 and .05 because those sections: (l) heighten the safety risks
to utility employees; and (2) preclude the Utilities and their customers from
realizing the benefits of modern metering technologies. We believe the
Utilities and their customers will actually benefit from the exemption in
numerous ways, so long as the Utilities adhere to their new practices as
approved in this Order.
STAFF COMMENTS JULY 18,2019J
Deployment of Remote Disconnect/Reconnect Capable Meters
The Company is currently conducting a study with respect to deployment of smart meters
with additional functionality. This type of meter enables the Company to remotely connect and
disconnect service. The Company has purchased eight of these meters, and has placed one meter
where its primary use will be for remote disconnection and reconnection.
Staff recognizes that there are safety risks associated with face-to-face interactions
between Suez's employees and customers during a premise visit to disconnect service. The
elimination of the need to do a final knock on the door, leave a notice, and/or collect payment
will help mitigate this risk. If a remote connect/disconnect meter is in place, the Company will
not need to visit the premise, thus avoiding the possibility of a negative encounter. Staff
supports the use of the remote connect/disconnect meters as a means to mitigate safety risks
and/or where there is a history of disconnection for non-payment at a location.
The Company's commitment to increase the number of contact attempts prior to
disconnection provides customers more opportunities to become aware of the possibility of
disconnection for non-payment and the need to take action to prevent it from occurring. The
Company's proposed elimination of convenience fees will provide customers with more free
payment options, including the ability to pay electronically without a fee prior to disconnection,
and even allowing customers to make a payment while the Company is on the premises.
The Company's planned deployment of remote connect/disconnect meters will allow it to
schedule disconnection early in the day, which provides the customer time to make a payment
and be reconnected that same day. The Company anticipates being able to remotely reconnect
service much more quickly than it would be able to do if an employee needed to be dispatched to
the customer's premises. Cary Direct at3l-32. The use of this type of meter will also reduce the
Company's operating costs associated with field visits.
Customer Notification Prior to Disconnection
UCRR 304 requires the Company to send an initial notice at least seven days before the
scheduled date for disconnection. The rule also allows mailing of a final written notice to the
customer at least three (3) calendar days (excluding weekends and holidays) before the proposed
date of termination. The rule also requires that at least24 hours before the proposed date of
termination, the utility must diligently attempt to contact the customer affected, either in person
4STAFF COMMENTS JULY 18,2OI9
or by telephone, to advise the customer of the proposed action and steps to take to avoid or delay
termination.
The Company states that it will add an additional automated call after the bill has become
past due and prior to the initial written notice being sent to the customer. The Company
currently allows customers l5 days to pay plus an additional five-day grace period to allow for
mailing prior to starting the collections process. The Company states that it would make the
initial call on day 22 after the due date. Company's Response to Staff s Production Request No.
13.
The Company will also make additional automated calls in a final attempt to contact the
customer. The Company's automated call system will be used to make the calls, track the
outcome of the call, and notate the customer's account. The system will note the following
outcomes: l) a person answered, did not listen to the entire message, and hung up;2) a person
answered and listened to the entire message with no response; 3) a person answered and pressed
the touch-tone key to repeat the message;4) a message was delivered on an answering machine;
5) the number did not pass the metro tables (i.e., the call was not attempted or was an invalid
phone number); 6) the last call attempt had no answer; and 7) the last call attempt received busy
signal. Company Response to Staff s Production Request No. 13.
The automated calling system provides the Company with an adequate record of its
attempts to meet the requirements of the UCRR, in particular the last diligent attempt to notify
the customer and prevent disconnection for non-payment. The Company's proposal to make an
initial automated phone call prior to sending the initial written notice and making additional
attempts through its automated call system to contact the customer exceeds the requirements of
Rule 304. These actions create additional opportunities to engage the customer prior to
disconnection of service and make it less necessary to attempt to engage the customer in person
at the time of disconnection.
Elimination of $15 Field Collection Trip Charge
The Company seeks to eliminate its Field Collection Trip Charge. Staff agrees that the
Field Collection Trip Charge of $15.00 will become obsolete if the Commission grants the
requested rule exemption which will allow Company personnel to no longer accept payments in
the held.
5STAFF COMMENTS JULY I8,2OI9
The Company requested a modification to Tariff Schedule 5 to remove the Field
Collection Trip Charge if the petition is approved, but did not include a revised Schedule 5 in its
petition. Staff asked in a Production Request how and when the Company would file an updated
tariff to reflect removal of the Field Collection Charge. In response, the Company said it would
file a conforming tariff schedule if the exemption is approved and the Commission orders a
filing.
Staff recommends the Commission order the Company to file a conforming tariff within
60 days of approval.
Reconnection Charges
The Company is currently authorized to collect a Reconnection Charge of $20.00 for
reconnections during normal business hours and a $30 Reconnection Charge for reconnections
outside of normal business hours. The Company's normal office hours are 8:00 am to 4:30 pm
Monday through Friday. In situations where the Company has installed meters with remote
connect/disconnect capability, Staffbelieves that the reconnection charge should be reduced to
recognize the cost savings associated with no longer having to visit customer premises to
disconnect and reconnect service. In Case No. GNR-U-14-01, Order No. 33229, the
Commission approved a reduced Reconnection Charge of $ 12.00 during normal business hours
and $24 for reconnection outside of normal business for similarly situated customers. See Order
No. 33229 at 1 l.
In this case, Staff recommends that the Company's current reconnection charges be
reduced by 50% for those customers who have a meter with remote connect/disconnect
capability.
Western Union Processing Fees
Suez proposes that customers no longer be required to pay convenience fees to the
Company's third-party vendor, Western Union. As a result, the Company will assume
responsibility for the cost of handling Western Union payment transactions. Staff notes that the
Commission previously approved a similar request from Avista to eliminate customer
convenience fees and establish a fee-free payment program for its residential customers. See
Case Nos. AVU-E-16-01 and AVU-G-16-01. In its order, the Commission stated, "'W'e fuither
6STAFF COMMENTS JULY 18,2OT9
find eliminating the convenience fee for residential customers will likely improve customer
satisfaction and lead to cost savings for all customers." See Order No. 33494 at 3.
Impact of Convenience Fees on Customers and the Benefits of Eliminatinq Fees
Staff supports the elimination of convenience fees for processing payments.
Convenience fees often have the greatest impact upon society's most vulnerable population,
including low income individuals who struggle to meet the basic necessities of daily living.
Many low-income people are unbanked or underbanked. "Unbanked" people lack a savings or
checking account and do not have a financial relationship with a bank or credit union.
"Underbanked" people may have a checking or savings account. Both unbanked and
underbanked households rely on non-bank financial services for an array ofproducts such as
check-cashing services and payday loans, all of which charge high interest rates. They may also
use credit and prepaid debit cards to pay their bills. Unbanked households have limited options
to avoid paying a convenience fee since most fee-free payment options require payment from a
checking or savings account.
According to the 2011 FDIC National Survey of Unbanked and Underbanked
households,t 25.20 of U.S. households were either unbanked or underbanked. In Idaho, 2.3Yo of
households were unbanked, and 17.9% were underbanked, for a combined total of 20.2oh or
132,965 households. Nationally, about half of people between the age of I 8 and 24 are
unbanked or underbanked due to lack of established credit.2
Eliminating Western Union's convenience fees will bring the Company's payment
practices in line with other SUEZ affiliate companies and those of other businesses, and will
increase the fee free payment options available to customers in Idaho. Eliminating the fee will
not only provide customers with more options; it will help lessen the financial burden on
customers who are struggling to meet financial obligations.
It is expected to improve customer satisfaction and increase timely payments. According
to the Company, customers have expressed frustration with incurring convenience fees. The
tsee 2017 FDIC National Survey of Unbanked and Underbanked Households ovailable qt
https ://www. fdic. gov/householdsurvey/
2 See 6 Reasons to be Unbanked or Underbanked available at https'.llwww.bankrate.com/banking/6-reasons-to-be-
unbanked-or-underbanked.
7STAFF COMMENTS JULY 18,20I9
Company indicated that its customers frequently complain about convenience fees.3 Cary Direct
at23. The Commission's Consumer Assistance Staff has received similar complaints from
customers. In addition, most customers who consider paying by phone elect not to when they
hear an additional fee will be assessed. Currently, only customers with a checking or saving
account can participate in automatic bill payment.4 With approval of the free-payment program,
Staff s understanding is that customers will be able to sign-up for automatic bill payment using a
credit or debit card by the end of 2019.
With more customers paying by credit or debit card, it is probable that more customers
will choose electronic monthly billing (paperless billing). This, in turn, will reduce the
Company's printing and mailing costs. For every bill the Company sends electronically, the
Company saves $0.27. See Company's Response to Staff s Production Request No. 21.
Customers who avoid paying by credit or debit card due to the convenience fee may elect
to do so if the fee is eliminated. The customer will benefit by not having to pay a convenience
fee and avoiding a late fee. SUEZ will benefit from reduced costs associated with collection
activity. Customers who wait until the last minute to pay a bill risk having the payment not
posted by the due date, incurring a late payment fee and possible disconnection of service. If a
payment is made at apay station, the payment can take up to one to two days to process and post
Delayed posting of payment to a customer account has resulted in customer disconnections even
though the payment was made before the scheduled date of disconnection. Elimination of
convenience fees is likely to increase the number of customers who pay their bills on time,
thereby reducing the number of incurred late payment fees and disconnections.
Staff believes that any deferral of transaction costs should be offset by the potential
savings related to the program. However, many of the benefits are not readily quantifiable, as it
would be difficult to directly correlate cost savings for the items mentioned with the proposed
elimination of convenience fees. Improved customer satisfaction potentially reduces the number
of phone calls made to SUEZ's Customer Service Call Center, which would save approximately
52.26 per call in labor costs. See Company's Response to Staff s Production Request No. 23.
Because the Company has not tracked the number of calls, inquiries, or complaints regarding the
convenience fee, the benefits from reduced calls cannot be adequately quantified.
3 SUEZ recently conducted a national survey of its customers. Of the 453 responses, 103 were from Idaho. The
number one complaint was incurring payment processing fees.
a No fee is charged for processing a payment.
8STAFF COMMENTS JULY 18,2OI9
The increase in customers who reduce Company cost by receiving electronic (paperless)
billing can potentially be tracked. Staff realizes that the tracking of these customers could be a
laborious task for quantifying this potential benefit.
Staff notes that all financial mediums for payment of utility services have transaction
costs. These costs have always been a prudent cost of doing business. Staff believes it is
inappropriate to charge some individuals for their method of payment, while embedding the costs
associated with other methods into rates. Provided that the Company is able to renegotiate their
Western Union contract, and continue to minimize its transaction costs, all transactions costs
associated with receiving payment for services should be included in base rates.
Discontinuing Acceptance of Payments at Company Office
Although it is not mentioned in the Company's Amended Petition, SUEZ proposes to
stop accepting payments at its local office and removing its drop boxes on the premises.s Carey
Direct at26-28. The Company indicates that the majority of customers who pay at the local
office live nearby and pay by check. Id. at2l. However, payments can be made at over 70
Western Union locations free of charge if the Company's request to remove convenience fees is
approved. No longer accepting customer payments at the Company's local office will reduce the
risk of fraud and robbery for both customers and employees. Additionally, handling cash
payments requires more time to process than other forms of payment. By no longer accepting
payments at its office, employee time can be better utilized to address customer inquiries and
concerns. Staff supports the Company plan to no longer accept payments at its local office.
Communication Plan
Staff supports the Company's proposed communication plan to inform customers and
train employees about changes to its collection practices and elimination of convenience fees.
SUEZ will focus on communicating with customers whose payment records reflect a history of
late payment, paying at the door in order to avoid termination of service, or paying at the
Company's local office. Customers will be notified through collections notices, automated
phone calls, signage at the Company's local office, and information posted on the Company's
5 From 2014 to 201 8, just I .67oh of all customer payments were presented at the Company office. Additionally, no
requirement exists that utilities must accept walk-in or drop-box payments at its Company office. Idaho Power and
Intermountain Gas do not accept walk-in payments.
9STAFF COMMENTS JULY I8,2OI9
website. The Company intends to modify collection notices, automated pre-recorded collection
calls (Televox), notices it provides to customers at the time of premise visits to disconnect
service, and provide employees with training on how to discuss the changes with customers. The
Company plans to hold department meetings for its employees and discuss the changes before
they are implemented.
The Company has stated that it will continue to accept payments at the door and in the
local office for four months, (two billing cycles), in order to ensure that customers are aware of
the changes in its collections process prior to implementation.
In addition to the Company's efforts to improve communication of the proposed changes
through the use of employee training and customer education, the Company's Interactive Voice
Recognition (IVR) system automatically verifies the customer's phone number on incoming
calls. The Customer Service Representatives taking incoming calls also verify the contact
information in the Company's system. The verification processes help to ensure that outgoing
calls through the automated telephone system are directed to the target group of customers.
Regardless of the customer's payment history, the Customer Service Representatives,
when assisting customers who are making a payment over the phone, will inform the customer
that a convenience fee is no longer required for processing the payment. The Company's
website will also provide information. Additionally, the on-hold recorded message played when
customers are waiting to speak to a Customer Service Representative will inform customers that
no charge is applied to payments. A similar message will be included on all bills for two
complete billing cycles (a four-month period).
Regulatory Asset and Recovery
Convenience Fees and Deferrals
The Company has requested authority to create a regulatory asset and to defer for later
recovery the costs associated with assuming financial responsibility for handling customer
payment transactions through its third-party vendor, Western Union. The Company estimates
that costs of payment transaction fees for 2019 and future years will vary based on an annual
growth trend betweenl0o/o and3}oh. In 2018, customers paid Western Union $138,461 in
convenience fees. If the Company's cost were equal to that of what individual customers paid
directly to Western Union, and assuming a growth trend of llYo, the Company would incur
approximately $152,301 in costs that would be deferred during 2019. The Company is currently
STAFF COMMENTS 10 JULY 18,2079
negotiating its contract with Western Union, however, and expects that its costs will be lower
than what customers are currently charged, which range from $1.00 to $1.99 per transaction.
Although not a financial burden to the Company, Staff finds that creating a regulatory asset is an
appropriate mechanism to allow the Company to offer fee-free payment options, which is an
opportunity to add an additional benefit to customers. Staff recommends that the Commission
allow the Company to set up a regulatory asset account, into which the costs incurred to process
payment transactions can be deferred for up to three years. This will allow the Company
adequate time to file a general rate case if cost recovery is an issue. Staff believes that the
opportunity to recover these costs at a later date is sufficient, and recommends that the Company
not be allowed a carrying charge.
Legal and Other Costs
The Company also requested that the legal expenses associated with processing this case
also be deferred in the same regulatory asset account. The Company does not employ in-house
counsel and instead relies on outside legal counsel for case filings. Legal expenses are currently
embedded in the Company's base rates it charges to customers, and without a comprehensive
audit of the Company's external legal expenses for 2019, there is a risk of double recovery. Staff
believes that the current level of legal expenses embedded in base rates is suffrcient to cover the
ordinary costs ofbusiness, such as routine case processing. Ifthe currently authorized level of
legal expenses included in base rates is no longer sufficient to cover the routine costs of
processing cases, the Company can request additional legal expenses in its next general rate case
for Staff to evaluate. Staff recommends the Commission not allow the Company to defer the
legal expenses associated with processing this case.
Amortization Period
Staff recommends that the Commission not explicitly approve an amortization period
now. Staff believes that the appropriate time to determine the amortization period is when the
Company files to recover the deferred expenses in its next general rate case.
STAFF COMMENTS ll JULY 18,2019
Reporting
With the future growth trend of fee-free payment options unknown, Staff recommends
the Company file semi-annual reports outlining the number of customers using each payment
method, the associated costs per transaction, and the deferral balance of the regulatory asset as it
accumulates. Such reports will provide a better understanding of growth for the various payment
channels used by Suez' customers and allow Staff to compare to other utilities. Staff
recommends the Commission require the Company to file semi-annual reports detailing its costs
and the payment channels customers are using.
Customer Relations
The Commission established a comment deadline of July 18,2019. As of July 15,2019,
no customer comments were filed.
STAFF RECOMMENDATIONS
Staff recommends that the Commission:
I ) Exempt Suez from Utility Customer Relations Rules 3l I .04 and .05 IDAPA
31.21.01.31 l 04 and .05, with an effective date four months following Commission
approval.
2) Approve elimination of the $15 Field Collection Trip Charge and order the Company
to file a conforming tariff within 60 days of approval.
3) Approve a reduced Reconnection Fee in locations where the Company has installed a
meter capable of disconnecting and reconnecting remotely and order the Company to
file a conforming tariff within 60 days of approval.
4) Approve the Company's request to discontinue collection of convenience fees from
customers by its third-party vendor, Western Union.
5) Approve the Company's request for an accounting order allowing deferral and
recording of the costs to handle customer payment transactions through its third-party
vendor, Western Union, until those costs can be recovered through future rates with
no carrying charge on the amount deferred.
6) Not allow the Company to defer the legal expenses associated with processing this
case.
STAFF COMMENTS t2 JULY I8,2OT9
7) Require the Company to file a report with the Commission every six months detailing
its costs and the payment channels customers are using.
8) Defer deciding on an amortization period until the Company asks to recover the
regulatory asset created by the deferral oftransaction fees.
tl,Respectfully submitted this t {day of July 2019.
Matt Hunter
Deputy Attorney General
Technical Staff: Curtis Thaden
Travis Culbertson
Chris Hecht
Kevin Keyt
i:umisc/comments/suzw I 9. I mhctcwhksktnc comments
STAFF COMMENTS 13 JULY 18,2OI9
311. TIMES WHEN SERVICE MAY BE TERMINATED - OPPORTUNITY TO
AVOID TERMINATION OF SERVICE (Rule 311).
04. Opportunity to Prevent Termination of Service. Immediately preceding termination of
service, the employee designated to terminate service shall identify himself or herself to the
customer or other responsible adult upon the premises and shall announce the purpose of the
employee's presence. This employee shall have in his or her possession the past due account
record of the customer and shall request any available verification that the outstanding bills are
satisfied or currently in dispute before this Commission. Upon presentation of evidence that
outstanding bills are satisfied or currently in dispute before this Commission, service shall not be
terminated. The employee shall be authorized to accept full payment, or, at the discretion of the
utility, partial payment, and in such case shall not terminate service. Nothing in this rule prevents
a utility from proceeding with termination of service if the customer or other responsible adult is
not on the premises.
05. Notice of Procedure for Reconnecting Service. The utility employee designated to
terminate service shall give to the customer or leave in a conspicuous location at the affected
service address, a notice showing the time of and grounds for termination, steps to be taken to
secure reconnection, and the telephone numbers of utility personnel or other authorized
representatives who are available to authorize reconnection.
Aftachment No. I
Case No. SUZ-W-19-01
staff comments
07lt8n9
SUEZ's Third-Party Payment Process Fees
*Asterisk/yellow highlight indicates what SUEZ is proposing to change.
Payment Option Current
Charge
Proposed Charge
(if Petition approved)
US Bank (downtown Boise - cash)$s.00 $s.00
*Call Western Union (credit/debit/checking/savings)$ 1.99 No cost
*SUEZ website (credit/debit/checking/savings)$ 1.99 No cost
*Western Union Quick Collect Kiosk (cash)$1.s0 No cost
*Western Union Pay Station (cash)
*Western Union Pay Station (check)
$1.s0 No cost
$1.00 No cost
US Mail (first class stamp)
US Bank (downtown Boise - check)
Victory Road office (cash/checks)
Victory Road night drop (check only)
$0.ss $0.ss
No cost
No cost
No cost
No cost
No cost No cost
E-pay direct debit (ACH) - checking No cost No cost
eBill (ACH) - checking No cost No cost
Attachment No. 2
Case No. SUZ-W-19-01
Staff Comments
07/18/19
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF JULY 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. SUZ-W-I9-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWNG:
MICHAEL C CREAMER
GIVENS PURSLEY LLP
PO BOX2720
BOISE rD 8370r-2720
E-MAIL : mcc,ld, given spursle\,. corn
MARSHALL THOMPSON
SUEZ WATER IDAHO INC
8284 W. VICTORY RD
BOISE ID 83709
E-MAIL : marshal L thompson(.}sr"rez.com
CERTIFICATE OF SERVICE