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BEFORE THE
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-04-
DIRECT TESTIMONY OF CAROL COOPER
IDAHO PUBLIC UTiliTIES COMMISSION
APRil 6,2005
Please state your name and business address
f or the record.
My name is Carol J. Cooper.My business
address is 472 West Washington Street, Boise, Idaho.
By whom are you employed and in what capaci ty?
I am employed by the Idaho Public Utilities
Commission (IPUC) as a Utilities Compliance Investigator in
the Consumer Assistance Section.
What is your relevant employment history?
I have been employed with the Public Utilities
Commission since March 1984 and have been with the Consumer
Assistance Section since August 1992.
What is the purpose of your testimony in this
proceeding?
I will address the following consumer issues:
(1) forms, bills and notices;(2) customer relations;
(3) low income assistance program;(4) proposed
miscellaneous service charges;(5) proposed tariff changes;
and (6) summary of customer comments filed in this case.
CUSTOMER FORMS
Have you reviewed customer billings, forms,
notices and letters?
I reviewed each document and found theYes.
materials to be in compliance with the Utility Customer
Relations Rules (IDAPA 31.21.01000 et seq.) and Utility
CASE NO. UWI-04-04/06/05
COOPER , C.
STAFF
(Di)
Customer Information Rules (IDAPA 31.21.02000 et seq.
) .
CUSTOMER RELATIONS
Please describe how many and what type of
complaints and inquiries the Commission has received
regarding Uni ted Water Idaho (UWI)
Exhibit No. 128 shows a three-year comparlson
of the customer contacts with the Commission.Customers
were primarily concerned about billing and disconnection of
servlce.High bills were of particular concern to
customers.With respect to disconnection of service, I
found that there are many reasons why customers do not pay
their UWI bills.
Are these customers primarily low-income
customers?
The Consumer Assistance Staff does not requlre
that piece of information , so unless a customer voluntarily
discloses his or her income to Staff , there is no way to
determine if income is a factor in inabili ty to pay the
water bills.
What are some of the other issues raised by
customers?
Rate design issues such as the summer
differential in rates and the customer charge were topics
of concern.Several customers indicated they would prefer
to have a lower customer charge and a higher consumption
CASE NO. UWI -W- 04-
04/06/05
COOPER , C.
STAFF
(Di)
charge.They also questioned why the customer charge for
United Water lS so much higher than for other utility
companles.
Do you agree wi th UWI' s proposal to increase
the customer charge by 36.4 percent?
I support Staff witness SterlingNo.
testimony to keep the existing bi-monthly customer charge
for residential customers with a %-inch meter at $14.57.
How does UWI' s performance compare to that of
other water companies?
Exhibit No. 129 shows a three-year comparlson
of customer complaints wi th those regulated companies
having more than 1000 customers.United Water has a
satisfactory ranking among those companles.
Based on my review of customer complaints and
inquiries, I find the Company s customer relations and the
quality of service to be acceptable.
Do you believe United Water provides adequate
customer assistance for non-English speaking customers?
The Company does not currently provide bills
or notices in any language other than English at this time.
The Company does have one meter reader fluent in Spanish
who assists the customer service representatives when
necessary.
Should UWI be doing more to assist its non-
CASE NO. UWI -W- 04-04/06/05 COOPER, C.
STAFF
(Di)
English speaking customers?
In Case No. RUL-04-, the Commission is
considering what steps, if any, utilities should be taking
to accommodate customers whose primary language
something other than English.There fore, I have no
recommendation to make at this time.
Is there an area of customer serVlce that you
believe United Water goes above and beyond what is required
by the Commission?
Although not required by the PublicYes.
Utilities Commission , United Water offers credit
adj ustments on high bills due to leakage if the leak is on
the customer s side of the meter and proof of repair
provided.
How would a typical customer find out that UWI
has such a policy?
Usually customers recel ve a high bill, which
results in a call to the Customer Service staff of United
Wa ter A field service person lS sent out to determine
whether or not the leak is on the customer s side of the
meter.The customer is informed at that time to provide
documentation of the repalr, such as a copy of the
plumber s bill, receipts for parts used, or a letter
stating how the leak was repaired.A final check is made
to insure there is no further leakage and an adjustment
CASE NO. UWI -W- 04-
04/06/05
COOPER , C.
STAFF
(Di)
calculated.A comparison from similar time periods from
prevlous years is used to get an average use.The customer
is sent a corrected bill , which is based on average use for
the time period in question plus one-half of the additional
usage attributable to the leak.
Is the process the same if a customer has a
sprinkler system leaking?
Yes, it is.However, if the customer is on a
pressurized irrigation system and the settings are wrong
and causing Uni ted Water backfeeds, no adj ustment is given.
The Company believes the pressurized irrigation system
within the customer s control , while leakage is usually
not.
LOW INCOME ASSISTANCE PROGRAM
Does UWI disconnect serVlce to residential
customers in the winter months?
Yes, it does.The restrictions on termination
of service to households wi th children, elderly or infirm
(Utility Customer Relations Rule IDAPA 31.21.01306) apply
only to residential gas and electric service.
According to the statistics received from the
Company, during 2002 and 2003 the highest number of
disconnections took place in the month of January.
2004 , the highest number of disconnections occurred in the
month of March.
CASE NO. UWI -W- 04-
04/06/05
COOPER, C.
STAFF
(Di)
Why would the largest number of disconnections
take place during the winter months if the bills are
usually much lower?
Termination is allowed when the bill is two
(2) months past due or the bill is $50 or more (IDAPA
31.21.01310) Since UWI bills customers on a bi-monthly
basis, each past due bill is subj ect to collection action
regardless of the amount owed.A customer might have
service disconnected if payment arrangements for high
summer usage were spread over more than one billing cycle
and the customer failed to pay as agreed.Another factor
might be that al though the Company is allowed to disconnect
service during the months of December through February,
Uni ted Water typically does not disconnect service around
the Thanksgiving, Christmas or New Year s holidays.Once
the holidays are over , disconnections resume.
Have you reviewed the Stipulation filed by
United Water Idaho and Community Action Partnership
Association of Idaho (CAPAI) regarding a proposed low-
income assistance program?
Yes, I have.Unfortunately, Staff did not
have an opportunity to thoroughly explore the issues raised
in that filing.Staff would support a program that
encourages conservation and targets low- income customers
who are having difficulty paying their bills.
CASE NO. UWI-04-
04/06/05
COOPER, C.
STAFF
(Di)
MISCELLANEOUS SERVICE CHARGE
What is your position with respect to the
proposed increases in Miscellaneous Service Charges as
outlined in Company witness Gradilone s Exhibit No.
Schedule 3, page 19?
The Company is proposlng increases in charges
for reconnection of service , returned checks, and premise
visits to collect payment of bills.The Company has not
provided any rationale or cost support documentation
indicating a need to increase any of these non-recurring
charge s It has also listed a new reconnection fee of $80
for reconnections made from 8:01 p.m. to 7:59 a.The
currently approved reconnection fee of $30 applies to any
reconnection performed outside of normal business hours.
Staff does support the increase from $15 to $20 for
returned checks, since this is the maximum charge allowed
by statute.Other than the returned check charge, however
without cost support documentation, I recommend the
miscellaneous service charges stay at the existing rates.
I also recommend that the $80 after hours reconnection fee
from 8: 01 p. m. to 7: 59 a. m. be denied.
Why do you oppose implementing a higher fee
for reconnections done in response to customer requests
received from 8:01 p.m. to 7:59 a.
Staff supports higher after-hours reconnection
CASE NO. UWI -W- 04-04/06/05
COOPER , C.
STAFF
(Di)
fees such as those found in UWI' s existing tariff.
However , the Company has provided no cost justification or
reason for charging an $80.00 fee for late night/early
mornlng reconnect ions.If handling late night/early
mornlng reconnection requests pose a problem for United
Water , it is not clear what other policy or procedural
changes may have been explored to address the perceived
problem.Unlike other Idaho utilities that provide service
over large, sometimes difficul t to reach areas, UWI' s
servlce area is primarily urban , which would tend to
minimize the expense of responding to after-hours calls.
Another factor to be considered is the Company s relatively
short business hours of 8:00 a.m. to 4:30 p.m., which
limits customer access and the ability to pay or make
payment arrangements.I recommend that the reconnection
fee stay at $30 for reconnections performed outside of
normal business hours.
REVISED TARIFF
What comments do you have with respect to
UWI's proposed tariff revision?
UWI filed a revised verSlon of its tariff with
the Commission.Al though no Company wi tness sponsored this
document, it includes the Company s proposed changes to its
rate schedules as well as its rules and regulations
governing the rendering of water service and water main
CASE NO. UWI-04-04/06/05 COOPER , C.
STAFF
(Di)
extensions.In his testimony, Company witness Gradilone
refers to several changes made to the tariff.Howeve r ,
changes were made to the Residential, Mul tiple Family
Housing, Commercial , Industrial or Municipal Development
Water Main Extension Agreement that are not discussed in
his testimony.Staff notes that the Company is proposing
to increase the ~Umbrella Excess Liability" coverage
required of an Applicant and an Applicant's Contractor from
$2,000,000 over primary insurance to $5,000,000.The
Company is also proposing to change the provision requlrlng
a sixty-day (60) notice for cancellation or material change
In coverage to thirty (30) days.Staff Exhibi t No. 130
contains the existing approved tariff page (page 1) as well
as the proposed tariff page (page 2) .These changes appear
to be substantive, but the Company has not provided any
explanation as to why these changes should be made.
Therefore, Staff recommends that these two proposed changes
not be approved by the Commission.
CUSTOMER COMMENTS
Did the Commission recel ve any consumer
comments regarding the filing of this case?
As of April 1, 2005, the Commission hadYes.
received 102 written comments.
Please summarlze some of the comments received
from customers.
CASE NO. UWI-04-04/06/05
COOPER, C.
STAFF
(Di)
Many of the comments made (21) were regarding
new growth and questioned whether existing customers are
subsidizing new developments.Twenty (20) customers stated
they personally were on a fixed income or could not afford
such a high increase in rates as requested by Uni ted Water.
Several others indicated they were concerned about the
elderly and low income in the community being able to
afford these higher rates due to an already tight budget.
There were ten (10) comments against the summer
differential in rates and three (3) obj ecting to such a
large customer charge.
Does this conclude your direct testimony in
this proceeding?
Yes, it does.
CASE NO. UWI -W- 04-
04/06/05
COOPER, C.
STAFF
(Di)