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HomeMy WebLinkAbout20150521Wyatt Direct.pdfDean J. Miller (lSB 1968) McDEVITT & MILLER LLP 420 West Bannock Street P.O. Box 25il-83701 Boise, lD 83702 Tel: 208.343.7500 Fax: 208.336.6912 ioe@mcdevitt-miller.com Attorneys for Applicant OF UNITED WATER IDAHO INC. FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION DIRECT TESTIMONY OF GREGORY P. WYATT MAY 201 5 I 2 J 4 5 6 7 8 9 l0 ll t2 l3 l4 l5 l6 l7 l8 l9 20 2t 22 a. A. o. A. a. Please state your name and business address. Gregory P. Wyatt. United Water ldaho, 8248 West Victory Road, Boise ldaho. What is your occupation? I am the Vice President and General Manager of United Water ldaho ("United Wate/' or "Company"). Please describe your educational background and other qualifications. I am a graduate of Bloomsburg University with a Bachelor of Arts degree in Business Administration Management. I have previously provided testimony before the !ndiana Utality Regulatory Commission, the Pennsylvania Public Utility Commission, and the ldaho Public Utilities Commission. A. Please describe your work experience. I have been employed at United Waterworks properties, formerly General Waterworks, since December 1974. Prior to assuming my current duties as General Manager of United Water ldaho in late 1999, I worked in various capacities in several states including General Manager for United Water Pennsylvania, Area Manager for the United Water lndiana operations, Assistant Manager of United Water ldaho and various accounting positions in New Jersey and Pennsylvania. a. Please describe your duties as General Manager. Wyatt, Di 1 United Water ldaho lnc. I 2 J 4 5 6 7 I 9 l0 ll t2 r3 t4 l5 l9 20 2t 22 23 l6 t7 l8 A. My duties are to oversee the Company's activities and responsibility of providing potable water to the customers of United Water ldaho. I provide general management direction and oversight to the various departments of Engineering, Production, Transmission & Distribution, Customer Service, Billing, lnformation Technology, Finance and Planning, and Administration in meeting their responsibilities for the delivery of potable water, maintaining compliance, and providing related services to customers. These functions include planning for raw water source, construction, maintenance and operation of the treatment and pumping facilities, the distribution system including mains, services, and storage tanks, responding to customer needs regarding initial service or discontinuing service by reading customer meters, processing and delivering bills, and responding to other customer needs through the C ustomer Service Representatives. My duties also include oversight and responsibility for the Company's compliance with all regulations in regard to safety, compliance with the Safe Drinking Water Act, and other similar requirements. a. What is the purpose of your testimony? A. Among other things, I will testify regarding the major reasons for the general rate relief requested in this filing, and the Company's conservation and customer service efforts. I will also be available to answer questions of a general nature. My testimony is organized as follows: Wyatt, Di 2 United Water ldaho lnc. I 2 J 4 5 6 7 8 9 r0 ll t2 0. l3 - Other Witnesses Pg. 3 - lmpact of Rate Change Pg. 4 - Tariff Design Pg. 6 - Rate lncrease Drivers Pg.6 .- Cost Management and Efficiencies Pg. 8 -- Personnel Requirements Pg.'12 - Water Conservation Pg. 13 -- Conservation Plan P9.17 - Customer Service Pg. 20 Other Witnesses Please identify the other witnesses who will testify on behalf of the Company and the topics on which they will testify. Mr. Paul Herbert, consulting expert with Gannett Fleming, lnc. will testify regarding revenue and associated adjustments. Ms. Pauline Ahern, consulting expert with AUS Consultants, will testify regarding cost of capital. Mr. Kevin Doherty, Director Regulatory Business with the United Water M&S Company, will testify regarding rate base, revenue requirement, and depreciation expense. Mr. Marshall Thompson, Operations Manager with United Water ldaho, will testify regarding the Company's overall operations, and will present testimony identifying and explaining the various proposed to the Company's Rules and Regulations on file with the Commission, excluding the revenue rate tariff pages, which are included in Witness Herbert's testimony. Wyatt, Di 3 United Water ldaho lnc. t4 A. t5 t6 t7 l8 l9 20 2t 22 23 24 25 26 I 2 J 4 5 6 7 l3 t4 l5 l6 t7 8Q. 9 r0 A. ll t2 Ms. Jarmila Cary, Finance Manager with United Water ldaho, will testify regarding operating expenses and associated adjustments, as well as all amortization expenses and associated adjustments. Mr. Roger Greaves, Senior Project Engineering with United Water ldaho, will testify regarding pro-forma capital additions and retirements, plant in service, and purchased water expense. Impact of Prooosed Rate Chanqe Generally, what is the overall revenue increase requested in this filing? The Company is seeking increased revenues in the amount of $5,881,308 or approximately 13.2o/o to be applied in an across-the-board fashion to all classes of customers and all tariff sheet components. O. When was United Water ldaho's last general rate filing? A. United Water ldaho last filed for a general rate increase on August 3, 2011. The case resulted in the Commission granting the Company an overall increase of $4.0M in two phases, with $3.050M effective February 1,2012,and an additional $950,000 effective February 1,2013. O. What is the current rate per hundred cubic feet (ccf) of water (748 gallons)? A. The current volumetric rate for water is $1.4647 under the winter rate (Sep. to Apr.) and $1.8310 under the summer rate, which means one Wyatt, Di 4 United Water ldaho lnc. l8 t9 20 2t I 2 3 4 5 6 7 8 9 l0 l1 t2 r3 t4 t5 t6 t7 l8 t9 20 2l o. A. penny will buy 5.1 gallons of water in the winter and about 4.1 gallons in the summer. How much water does an average residential customer use per year and what does that equate to on a cost per day at current rates? Using the projected test year volumes, an average residential customer will use approximately 1 14,597 gallons of water annually (approximately 153.2 ccf) which equates to about 314 gallons per day. At current rates, on average that equals $383.99 per year, or $0.71 per day plus an additional $0.34 per day for the average residential customer charge. How would the Company's proposed increase impact the average residential customer? Excluding Franchise or IDEQ fees, for the average residential customer projected to use 114,597 gallons annually this would be an increase of approximately nine cents ($0.0S1 per day plus approximately five cents ($0.0S1 per day for the customer charge. The total increase at the Company's proposed rates is approximately $50.62 per year or $4.22 per month. Considering the Company's last significant increase to base rates was in February 2012and the proposed rates would not become effective until approximately mid-December 2015, United Water ldaho's customers wil! have benefitted from approximately four years of relatively stable base rates. Wyatt, Di 5 United Water ldaho lnc. o. A. I 2 3 4 5 6 7 8 9 l0 a. A. Tariff Desiqn What is the Company's proposal for adjustments to rates to recover any revenue increase that may be awarded by the Commission? As explained in more detail in the testimony of Witness Herbert, the Company is proposing increases to all rate elements, excluding miscellaneous service charges and fees, on an across the board basis. The Company is not proposing, in this case, any change to the current general tariff design and is maintaining the 25o/o differential between winter and summer volumetric rates. Rate lncrease Drivers Would you briefly explain why the Company is seeking a rate increase at this time? A. The increase is necessary for the Company to continue to provide quality service to customers and to improve service by investing in new and replacement infrastructure. For these reasons, United continues to make capital investments in utility plant. The Company's rate base of approximately $162.9 million as filed in its last rate proceeding (Case No. UWI-W-I 1-02) has increased to about $173.3 million in this proceeding or an increase of $10.4 million. Operating costs, excluding income taxes, have also increased since the last rate filing from approximately $26.3 million to approximately $29.5 million or an increase of $3.2 million. An increase in rates is also necessary in order to provide sufficient capital dollars to maintain and improve quality service to our customers, to Wyatt, Di 6 United Water ldaho lnc. no. t2 t3 t4 l5 t6 t7 l8 l9 20 2l 22 23 I 2 3Q. 4 provide adequate operating and maintenance coverage, and to maintain a sound financial position. What are the major capital investments the Company has made since the last rate case that contribute to the increase in rate base? The Company has made or will be making by the end of the post-test year period ending November 30, 2015, additional investments totaling more than $39 million. Almost $17.2 million dollars of that was invested in replacing aging water mains, services and meters; over $3.5 million in replacement treatment projects that improve water quality provided to customers; almost $1.2 million in booster station improvements that improve system reliability; almost $0.9 million for a replacement storage tank to sustain pressure and improve fire protection in the Bogus Basin Road area; more than $0.7 million in a new main to improve customer pressure in the Hill Road area; over $0.6 million has been invested in a new water supply well; and over $0.5 million dollars in auxiliary power equipment at various sites throughout the water system to ensure uninterrupted water supply to customers during electric power outages. You mentioned before that operating costs in this current filing increased by $g.Z million from the level in the Company's last filing. What are some of the major areas of operating cost increases? The largest single category of operating cost increase in this case, about $945,000, arises from increased depreciation expense related to the capital investments the Company has made. Additionally, personnel Wyatt, Di 7 United Water ldaho lnc. 5 6 7 8 9 l0 ll t2 l3 14 l5 l6 t7 A. o.r8 t9 20 2t 22 23 A. I 2 3 4 5 6 7 8 expenses have increased by about $911,000, with a significant portion of that associated with medical, pension, and post-retirement health care cost increases. Energy costs have increased by more than $544,000, and amortization expenses associated with deferred pension have increased by almost $496,000. These and other expense adjustments are discussed more fully in Witness Cary's and Witness Doherty's testimony and exhibits. Cost Manaqement and Efficiencies Please discuss how United Water is managing its costs and seeking to mitigate the impact of increased costs on its customerc? United Water is continually looking for ways to reduce the costs of providing service to its customers and for ways to provide service more efficiently. An area where United Water has demonstrated efficiency in operations is in the number of employees required to operate the business. Here a common measure of efficiency is the number of customers per employee. The graph below shows the Company's average number of metered customers per employee from 2000 to 2014. Wyatt, Di 8 United Water ldaho lnc. ea. l0 ll t2 r3 t4 t5 l6 t7 A. I 2 3 4 5 6 7 8 9 l0 ll t2 l3 t4 Avg. Metered Cust/Employee 875 775 725 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 20LL 20L2 20L3 20L4 During the Great Recession (roughly from 2008 to 2010) the Company's ratio of customers per employee dipped from its high of 898 customers in 2007 to 847 in 2010. However, the ratio has improved every year thereafter and now approaches the peak from 2007. Much of this improvement is related to the renewed customer growth since 2010, while the company has been able to maintain a relatively flat staffing level since the last general rate filing. The next graph shows the ratio for a group of regulated companies for a recent period (2011), and it can be seen that United Water's ratio of 862 customers per employee was well in excess of the average of 629 for that period, bettering the average by 37o/o. And as seen in the graph above, the company's customers per employee ratio has improved even further from 201 1 to 2014. Wyatt, Di 9 United Water ldaho lnc. ?:OLL Customers per Employee nies Financial &Data for 2011 Additionally, the Company employs various technologies, including highly sophisticated SCADA and GIS systems, which enable the Company to operate its facilities without requiring all year long around the clock staffing. Additionally, these aid in controlling staff overtime as well. For example, over the three year period of 2012-2014, staff overtime pay has average just over $142,000 per year, which is an average of only 2.44o/o of average gross payrollfor the period. Please identify other areas where the Company has been able to control costs a nd/or demonstrati ng operational efficiencies. United Water ldaho, as part of a national Company, has been able to leverage our Company's size and purchase volume to negotiate favorable Wyatt, Di 10 United Water ldaho lnc. Gs2539ff3 il7 623 g $E!'= c =,3f J o 'oz 3f 33 EoIso6 =, $E=gEf; E;s;fg 2S=EgggEEE =cru I 2 3 4 5 6 7 8 a.9 l0 ll t2 A. I 2 J 4 5 6 7 8 9 l0 ll unit prices (or mitigate the magnitude of price increases) on various products and services such as chemicals, materials, insurance, health care, fleet leasing, and other products and services. A significant measure of a water utility's operational efficiency is its level of non-revenue water (NRW), or the amount of water the utility produces, treats and pumps to customers that, for various reasons, does not return revenue to the utility. ln the U.S., utilities lose on average 20 percent of their water, according to the Black & Veatch Strateqic Directions Water Report. United Water ldaho has historically maintained a substantially lower level of NRW than industry averages. Over the past two years the Company's NRW percentage has averaged about 5.5o/o. At the Company's Victory Road offices, we have taken various energy saving measures; including taking advantage of ldaho Power lighting rebates, to lower electricity use by over 13% from 2008 to 2014. Additionally, since 2009, the Company has continued its participation in a Power Demand Response Program Sales and Services Agreement with EnerNOC, lnc. that provides payments to the Company for temporarily interrupting the use of certain water pumping facilities when requested to do so by ldaho Power during high electricity demand periods in the summer. These payments go directly to reduce the Company's purchased power expense. Wyatt, Di 1',| t2 l3 t4 l5 t6 t7 l8 t9 20 2t United Water ldaho lnc. I 2 J Also, from 2008 to 2014 the Company reduced by more than 13% its total gallons of gasoline and diesel fuel purchased for use in its fleet of vehicles and equipment. Please describe efforts taken to control costs related to the Company's pension obligations. There have been two significant changes to the United Water Resources Pension Plan. The first, in 2009, was the elimination of the Pension Plan benefit for all new employees hired into the Company. The second, which became effective in July 2011, was the introduction of a participation cap of 35 years of service for existing employees who are covered by the Company's current Pension Plan. Perconnel Requirements The pro-forma payroll related operating expense adjustments presented by Witness Cary indicate a change in headcount from the Gompany's test year in this case. Please discuss this change. ln the test year the Company had a head-count of 98 full-time employees (FTE). ln its pro forma payroll expenses the Company is proposing 99, an increase of 1 FTE. The Company has added an Environmental Health & Safety (EHS) Manager position. The new EHS Manager was hired in Apri! 2015 to lead the Company's environmental, safety and security programs, and to support management in monitoring, verifying, and strengthening compliance with regulations in these areas. Prior to hiring Wyatt, Di 12 4Q. 5 6 7 8 9 l0 ll t2 13 0. t4 l5 l6 t7 l8 l9 20 2t 22 A. United Water ldaho lnc. I 2 J 4 5 6 7 8 9 l0 ll t2 l3 t4 l5 l6 t7 l8 l9 20 o. A. the EHS Manager, the Company's EH&S programs and efforts had been under the responsibility of the Company's Production Manager, but only on a part-time basis as time allowed. The Company has placed a high commitment on environmental compliance and a high priority on ensuring the safety of each employee. Water Conservation Would you please provide an overyiew of the Company's water conservation and demand side management efforts and programs? For over 20 years the Company has developed and implemented various customer information, education and awareness programs, and outreach efforts that promote wise water use and water conservation and that assist customers in managing their water demand and consumption. Although some of these efforts have sought to inform customers about water use in the home, the majority of them have targeted customer water use outside on lawns, gardens and landscape areas. This focus is designed to enable customers who use water provided by the Company for irrigation purposes to benefit the most from the Company's efforts, since irrigation demand is the largest driver of overallwater system demand in the summer. Below is a summary of the Company's efforts in these areas: Water Efficient Landscaping Classes Historically, in February/March of each year, United Water, in partnership with the Ada County Extension Office and the City of Boise, Wyatt, Di 13 2l 22 United Water ldaho lnc. I 2 3 4 5 6 7 8 9 l0 ll t2 r3 t4 l5 l6 t7 r8 t9 20 conducted six, two-and-a-half-hour class sessions focused on the fundamentals of water efficient landscaping. The classes are now consolidated into four, two-hour class sessions in response to a more manageable time commitment for the attendees. At the recently completed 2015 series, the four sessions averaged 75 attendees per class. Summer Water Conseruation Bill lnsert As customer bills are delivered throughout the spring and summer, both paper and electronic bills include an insert that provides information on how customers can reduce their outside water demand during the summer. ln 2Q14 the Conservation insert was included in the July and August bills. ln 2015, the Conservation insert is planned to be included in the June and July bills. Water Use Management Messaging Through the Media United Water ldaho conducts a multi-media conservation campaign annually. The campaign begins in mid-June, and culminates around Labor Day. The goal is to increase customer's awareness of their water use and to provide them with concrete reminders and methods to manage their water consumption. This consists of a coordinated use of newspaper, television, online media and social media. From 2005-2013, the Company published an eight page newspaper insert, distributed in a Sunday edition of the ldaho Statesman. ln 2014, Wyatt, Di 14 2t 22 United Water ldaho lnc. I 2 J 4 5 6 7 8 9 t0 ll t2 l3 t4 t5 l6 t7 r8 t9 20 2l 22 23 the Company transitioned the guide to an online publication, reducing production and distribution costs, and allowing us to incorporate interactive features. The online guide featured text, photos and how-to videos on topics ranging from irrigation systems and lawn care to sprinkler repairs and a list of low-water plants that customers can plant in their yards. The 2014 guide was awarded First Place in the Electronic Communications category in the Pacific Northwest Section of the American Water Works Association Excellence in Communications Awards. The Guide also includes coupons which customers can use to obtain the free outdoor conservation devices mentioned below. The guide is promoted in bill messages, via online ads on leading local news websites, on social media platforms, in the Company's monthly electronic newsletter, and in print ads. The summer campaign also includes TV commercials to encourage conservation. ln 2014, the Company launched a student video contest, to engage the community in the effort. 9th-12th grade students in the Boise School District and Bishop Kelly High School were eligible to submit a 30- second Public Service Announcement. The winning entry aired during the summer on local TV stations. Additionally, United Water partners with ldaho Rivers United each year on public outreach campaigns focused on conservation and preservation of the Boise River water source. Wyatt, Di 15 United Water ldaho lnc. Xeriscape Demonstration Garden I 2 J 4 5 6 7 8 9 l0 ll t2 r3 t4 15 l6 t7 l8 l9 20 2t 22 23 ln 2006, United Water installed a Xeriscape, low-water use, demonstration garden at its main office location on Victory Road. The garden contains numerous drought-tolerant plant varieties and is configured with appropriate signage in a walk-through venue. A listing of plants is available for customers at the office and on our web site, and the Company's Outreach and Education Coordinator conducts educational workshops for customer groups using the garden as the centerpiece. ln 2010, the Company financially supported the installation of a new low- water use garden located at the ldaho Botanical Garden, and a xeric garden on the Capital grounds upon completion of the Capita! expansion and restoration project. United Water works with both of these entities to coordinate messaging, signage, and water conservation educational materials. The Company is currently in discussions with the Ci$ of Boise on funding and installing a xeric demonstration garden at the Bown Crossing Library, slated to open in late 2016. Educational and Community Outreach United Water has developed various water awareness and conservation activities and presentations that are available and presented to schools, businesses, and community organizations in the area. These include PowerPoint presentations, topical lectures, and science activities. The Company has become more involved with STEM (Science, Technology, Engineering, Math) education outreach; participating in summer teacher workshops and student activities such as Explore STEM Wyatt, Di 16 United Water ldaho lnc. I 2 3 4 5 6 7 Day at Boise State University. The Company also participates in community events where conservation materials and information are provided, including Earth Day events, various company green fairs such as Citibank, Direct TV Expo, ldaho Botanical Garden Landscaping Symposium, as well as meetings with various neighborhood associations and many subdivisions throughout the service area. Gonservation Plan Please comment on the Company's efforts to implement its Conseruation PIan. As a result of the Company's 2004 case (UW|-W-04-04) the Commission, in its September 20, 2005 Order No. 29871 directed the Company to prepare an updated conservation plan and submit it to the Commission for review. United Water prepared and then filed its updated Conservation Plan with the Commission on December 1, 2006 (UW!-W-06-05), and by Order No. 30305 dated April 18,2007 and Order No. 30305 Errata dated May 22, 2007, the Commission approved implementation and associated cost deferral of four specific programs from the updated Conservation Plan; specifically Xeriscape demonstration gardens, rain sensor retrofit, trigger shut-off valves and hose timers, and restaurant low flow spray nozzles. Please describe the Company's implementation efforts regarding the four programs since Commission approval in April 2007. Wyatt, Di 17 United Water ldaho lnc. 8Q. 9 l0 ll t2 r3 t4 l5 l6 t7 l8 l9 20 2t a. 22 I 2 3 4 5 6 7 8 9 l0 lt t2 l3 t4 l5 l6 t7 l8 l9 20 2l 22 23 A. United Water began promoting the trigger shut-off valve and hose timer program via a free coupon in its 2007 Conservation Guide. In that first Guide, and annually since, customers are encouraged to bring the coupon from the Guide into the office and receive the free devices. The program is also promoted via signage at the Company's office where extra coupons are available, at public shows and displays, in the conservation bill insert, via bill messages, and on the Company's web site. During the 2014 season, Boise City Hall, the Collister Library and Hillcrest Library assisted the Company as distribution centers for the conservation device program. Supplies of the outdoor devices are also kept at El-Ada to assist our UW Cares program recipients. At the end of 2014, 5,692 hose timers and hose triggers have been provided to customers since the program inception. ln the summer of 2008, the Company began implementing the rain sensor (shut-off device) retrofit on irrigation controllers program. This program involves purchasing and providing a rain sensor device at no cost to customers. The device connects to the customer's automatic irrigation system and interrupts the scheduled watering cycle whenever sufficient rainfall is detected by the device. This program is promoted in the same way as the trigger shut-off valve and hose timer program via the annual Conservation Guide, office signage, public shows and displays, in the conservation bill insert, via bill messages, and on the Company web site. This program has been promoted in the same fashion during the summers Wyatt, Di 18 United Water ldaho lnc. I 2 ever since. By the end of 2014,3,291 rain sensors have been provided to customers. The restaurant low flow spray nozzle change out program began in 2009. ln this program United Water replaces commercial customer's existing rinse and clean spray nozzles with low flow units at no charge. The Company entered into an agreement with a licensed plumbing contractor in August 2009 for the installation of these devices for customers. The Company partnered with Central District Health ("CDH") to obtain their list of roughly 650 customers within our service area (such as restaurants, hospitals, and group homes) who have commercial kitchen facilities. The Company sent direct mail invitations to the list of customers received from CDH on two separate occasions. Unfortunately, the response from customers has been disappointing with 73 low flow nozzles replaced in customer's facilities at no direct additional charge to the customer. The Company's efforts regarding the fourth program approved by the Commission in 2007, Xeriscape demonstration gardens, has already been discussed above. A. Do you believe the Gompany has implemented the approved Conservation Plan programs in the way the Gommission intended? A. Yes. The Company has made a diligent effort implementing the four approved programs, while at the same time it has maintained and improved its previous conservation efforts. Wyatt, Di 19 United Water ldaho lnc. 3 4 5 6 7 8 9 l0 ll t2 l3 t4 l5 t6 t7 l8 l9 20 2t 22 23 2 3 4 5 6 7 8 9 Customer Service O. Please comment on the Company's customer service efforts. A. United Water uses various measures and metrics to ensure that it maintains a high level of service and responsiveness to its customers. For example, the Company tracks customer complaints it receives relating to water quality. During 2014, water quality complaints that required a field visit to resolve have averaged only 0.52o/o of total customers. Complaints relating to high bills and disconnection have averaged only 0.37% and 0.25o/o respectively as a percentage of bills rendered. O. Are there other measures used by the Gompany to track customer seruice performance? A. Yes. Our Customer Service group maintains various data relating to customer calls, response time, length of call, and number of dropped calls. During 2014, the Customer Service office answered 95,523 calls with an overall average answer speed of 35 seconds. The average length of calls was 3.07 minutes, and the abandoned or dropped call rate was 2.3o/o of all calls. In addition, due to the fact that virtually all customer meters are located in outside pits or vaults, we are able to render bills based on actual meter readings 98.3% of the time. a. Does United Water ldaho monitor customer satisfaction? A. Yes. The Company conducts an annual telephone customer satisfaction survey with the purpose of measuring customer satisfaction across Wyatt, Di 20 United Water ldaho lnc. t0 ll t2 l3 t4 l5 r6 t7 l8 l9 20 2t 22 I ) 3 4 5 6 7 8 various areas of service as well as overall satisfaction. A third party, Walker lnformation conducts the survey and tabulates the results. Samples of the positive satisfaction results for 2014 are: . Overallsatisfaction:97% (neutral to extremely satisfied) . Cares about customers: o Reliability of service: . Value for money: Low-lncome Customer Assistance 96% (neutral to excellent) 98% (neutral to excellent) 86% (neutral to excellent) eQ. l0 Does the Company currently have a low-income customer assistance program in place? Yes. Beginning in September 2005 the Company initiated UW Cares, which is the first, and still the only, water utility customer assistance program in the state. The program, which is administered through the El- Ada Communi$ Action Partnership social service organizations, provides up to $65 annual water bill assistance to qualifying customers. The initial program provided up to $50 annual assistance but was increased to $65 by the Company in October 2011 in response to increased customer need. Additionally, the Company provides the agencies with indoor water conservation kits for distribution and installation for qualified customers in the program. Since UW Cares began in 2005, almost $146,000 in assistance has been provided to more than 2,800 qualified customers to help pay their water bills. The Company initially sought customer Wyatt, Di 21 United Water ldaho lnc. lt t2 l3 t4 l5 l6 t7 l8 t9 20 2t 22 A. I 2 J 4 5 6 7 8 9 donations in support of UW Cares, but abandon that approach in its last general rate case (UW|-W-11-03) due to lack of customer interest and support. Also, during its 2004 rate proceeding (UW|-W-04-04), the Company supported and agreed to a proposed change in its rate tariff whereby the first 3 hundred cubic feet (ccf) of consumption used during the summer rates period (May through Septembefl is priced at the 25o/o lower winter rate. O. Does this conclude your direct testimony? A. Yes. I reserve the right to supplement my testimony as additional issues arise during the course of this proceeding. Thank you. Wyatt, Di 22 United Water ldaho lnc. l0 ll