20230215Bossard Direct with Exhibits.pdf

IN THE MATTER OF THE APPLICATION )5 PM 4:57
OF VEOLIA WATER IDAHO,INC.FOR A )CASE NO.VEOg 22-02GENERALRATECASE)MN
DIRECT TESTIMONY OF JOLENE BOSSARD
IDAHO PUBLIC UTILITIES COMMISSION
FEBRUARY 15,2023
1 Q.Please state your name and business address.
2 A.My name is Jolene Bossard.My business address
3 is 11331 W.Chinden Blvd.,BLDG 8,STE 201-A,Boise,Idaho
4 83714.
5
Q.By whom are you employed and in what capacity?6
7 A.I am employed by the Idaho Public Utilities
8 Commission ("Commission")as a Utilities Compliance
9 Investigator in the Utilities Division.
10 Q.Please describe your educational background and
11 professional experience.
12 A.My educational background and professional
13 experiences are shown in Exhibit No.136.14
Q.What is the purpose of your testimony in this15
16 proceeding?
17 A.The purpose of my testimony is to present the
18 Commission Staff's ("Staff")position on the following
19 consumer issues regarding Veolia Water Idaho,Inc.'s
20 ("Veolia"or "Company")general rate case:
21 1.The Customer Notice and Press Release filed in22
this case;
23
24 2.Reviewing the customer workshop;
25 3.Summarizing the customer comments received by the
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)102/15/23 STAFF
1 Commission regarding this case;
2 4.Discussing the complaints received by the
3 Commission for the years 2020 through 2022;
4 5.Customer Service Center performance;
5
6.Discussing Consumer Assistance Staff's stance on6
7 Veolia Cares (Low-income Assistance program);
7.Discussing Consumer Assistance Staff's stance on
9 the Cross Connection Control Program;and
10 8.Reviewing East first Bench Discolored Water &
11 Flushing Credits.
12 Q.Are you sponsoring any exhibits with your13testimony?
14
A.Yes.I am sponsoring Exhibit Nos.136,137,138,15
16 139,140,and 141.
17 Q.Please summarize Staff's recommendations as they
18 relate to consumer issues.
19 A.I recommend that the Company submit the customer
20 notice and press release to the Commission for review prior21tosubmittingitsApplicationinfuturecases.22
I reviewed the customer comments and found that23
24 the number of comments received by the Commission in this
25 case has increased from the previous case.The customers
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)202/15/23 STAFF
1 appear in their comments to be even more frustrated and
2 angry at the prospect of paying more for water.Many
3 customers object to the cost of the Eagle Water purchase
4 being imposed on all customers.
5
I reviewed complaints/inquires submitted to the6
7 Commission and recommend that in the future,the Company
communicate with the Commission when it recognizes a
9 possible issue that could generate complaints from a
10 significant number of customers.
11 I address the previous lack of record keeping in
12 the Veolia Cares program and recommend that the Company
13 continue to support the program and to increase the amount14
of the grant to reflect the increase in rates for15
16 residential customers.
17 I reviewed the status of the Company's Cross
18 Connection Control Program and recommend that it take steps
19 to improve tracking the annual certification reports and
20 follow-up with customers when they are not submitted.
21 Customer Relations
22 Customer Notification and Customer Workshop
23 Q.Does the Company's Customer Notice and Press
24 Release meet the requirements of the Commission's Rules of
25
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)302/15/23 STAFF
1 Procedure,(IDAPA 31.01.01),Rule 125?
2 A.No.The Company's Customer Notice and Press
3 Release were submitted on September 30,2022,along with
4 the Application,and were reviewed by Staff at that time.5
The customer notice failed to identify the case number,6
7 although customers could locate the information if they
8 used the Commission's website.The Press Release failed to
9 inform Customers that they could file comments on the case;
10 however,all customers received the information with the
11 Customer Notice.
12 Q.How were the Company's customers informed of the13
rate case?
14
A.Because the Company bills on a bimonthly15
16 schedule,the first group of customers were sent notice in
17 the October 2022 billing statements,and the final group of
18 customers were sent a copy of the notice enclosed in the
19 November 2022 billing statements.Customers who receive
20 their billing statements electronically have a link to the
21 notice when they open their billing statement.All22
customers should have received notice of the Application by23
24 the end of November giving them sufficient opportunity to
25 submit written comments and participate in the process.
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)402/15/23 STAFF
1 In addition to the customer notice and press
2 release,Staff hosted a virtual Customer Workshop on
3 January 31,2023.Twenty-one (21)customers attended.
4 Customer Comments Regarding the Proposed Rate Increase
5
Q.Have you reviewed the written customer comments6
7 that have been received by the Commission regarding this
case?
9 A.Yes.As of February 14,2023,134 customers have
10 submitted comments regarding the proposed increase in
11 rates.The comments are primarily from residential
12 customers who oppose any increase in rates.
13
Q.What are some of the concerns mentioned by14
customers?15
16 A.Commenters raise the same issues as have been
17 raised in prior rate cases.Many customers are low-income
18 or fixed-income customers who see basic living costs rising
19 due to increased inflation but their wages and/or social
20 security income benefits are not keeping pace.
21
Q.Are there other concerns mentioned by customers?22
A.Many comments (66 of 134)bring up the cost of23
24 the Company's acquisition of Eagle Water and the costs
25 associated with the purchase being passed on to all
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)502/15/23 STAFF
1 customers.
2 Customer Complaints and Inquiries
3 Q.Please describe how many and what type of
4 complaints and inquiries the Commission has received5
regarding the Company between 2020 and 2022.6
A.Exhibit No.137 shows the number of informal7
8 complaints and inquiries received over the past three
9 years.
10 Q.Recently,have there been any specific complaints
11 that were different than a typical complaint the Commission
12 .receives.
13
A.Yes.According to the Company,1,136 customers'14
accounts were affected when their meters were misread15
16 (underread)over several months.This equated to a little
17 over 1%of the Customer base.The Company has been
18 rebilling these customers in a manner so that the
19 adjustment of the usage on the accounts will not affect
20 their sewer billing.As of 1/24/2023,the last of the21customersmetersthatwerepreviouslymisread,now have22
verified good meter readings.In the future,I recommend23
24 that the Company notify Staff as soon as they recognize a
25 potential large-scale issue that will affect customers.
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)602/15/23 STAFF
1 Call Center Telephone Answering Standards (often referredtoas"service levels")2
3 Q.What is Veolia's performance objectives for
4 handling incoming calls?
5
A.Veolia's goal is to answer 80%of customer calls6
within 60 seconds or less.7
Q.Has Veolia met their standards of Average Speed
9 of Answer ("ASA")?
10 A.Yes,until recently.Since January 2020 Veolia
11 met their standards of Average Speed except for August,
12 September,and October 2022.Exhibit No.138.13
Q.What were Veolia's total number of incoming calls14
and emails during each of the past 3 years?15
16 A.The yearly totals were 83,994 in 2020,86,191 in
17 2021,and 96,617 in 2022.Exhibit No.139.
18 Veolia Cares
19 Q.Does Staff have any recommendations for the
20 Company in light of the customer concerns regarding higher21ratesandincomerestraints?
22
A.A review of the Veolia Cares program over the23
24 past three years indicates that the program was valuable to
25 °*¯income customers during the recent COVID pandemic.
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)702/15/23 STAFF
1 While the number of disconnections for customers who had
2 received assistance increased during the pandemic,the
3 recovery in 2022 reduced both the amount of assistance
4 provided and the number of customers who were disconnected,
5
even after assistance was received.Exhibit No.140.6
7 Recently inflation has increased costs and has
8 subsequently increased the level of benefits available to
9 low-income customers who receive benefits.Staff
10 recommends that the Company increase the amount of
11 assistance an individual customer can receive in the same
12 percentage as the rate increase for residential customers
13 granted in the final order to reduce the effects of the14
rate increase and higher inflation levels.15
16 Staff also recommends that the Company increase
17 the maximum household income level to reach more customers
18 threatened by disconnection for non-payment and prevent
19 additional disruption of customer service.The program
20 qualifies customers through El-Ada Community Action
21 Partnership,which also handles other low-income programs22
such as Energy Assistance and Crisis Funds,both of which23
24 are part of the federally sponsored LIHEAP program,meaning
25 that the agency has the means and the ability to assess the
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)802/15/23 STAFF
1 household income and determine whether it qualifies.
2 Raising the income level would allow more households with
3 marginal income to receive benefits.
4 Cross Connection Control Program
5
Q.What is the Company's Cross Connection Control6
Program.
8 A.The Company's authority for the program falls
9 under the Idaho Rules for Public Drinking Water (IDAPA
10 58.01.08)administered by the Idaho Department of
11 Environmental Quality,Idaho's Uniform Plumbing Codes,and
12 the Commission's Rules and Regulations.The Company is13requiredtolocatecrossconnectionsanddeterminesuitable14
protection to ensure that non-potable water cannot flow15
16 back into the Company system.The Company must approve the
17 installation and requires annual inspection.To that end,
18 the customer with such a device is required to have the
19 device tested and the inspection results forwarded to the
20 Company.Should a customer fail to install and maintain
21 the proper device,including the annual inspection,the22
Company has the authority to take steps to disconnect the23
24 customer.See Order No.33436.In 2019,the Company
25 revised its Cross Connection Control Program.
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)902/15/23 STAFF
1 Q.What is the current status of the program?
2 A.Although the number of customers has increased
3 over the past three years,the number of annual inspection
4 reports received by the Company has decreased from 1,759 in
5
2020,to 1,228 in 2021,to 1,015 in 2022 (as of November).6
7 The Company does not track the total number of customers
8 with a Cross Connection Control Device (CCD)
9 electronically,maintaining only a paper data base.It
10 does not track how many customers have been disconnected
11 and does not follow up on customers who have previously
12 submitted a certificate.In addition,the Company call13
center personnel do not have access to the information14
should a customer call to make an inquiry.15
16 Q.How does the Company notify customers that they
17 need to submit an annual inspection certificate.
18 A.The Company includes a reminder to all customers
19 in its Annual Summary of Rules through billing inserts and
20 through its website because it doesn't have the ability to
21 target customers who have previously submitted a22
certificate.23
24 Q.Does the Staff have any recommendations for the
25 Company in light of the lack of recordkeeping?
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)1002/15/23 STAFF
1 A.Staff recommends that the Company create an
2 electronic database for all customers who have previously
3 submitted a certificate and all other customers,both new
4 construction and current customers,who are required to
5
maintain a CCD but may not have a device installed.The6
7 Company could then use the database to track certificates
and notify customers who have not submitted the required
9 certificate.The program has a notification process to
10 enforce the requirement or if necessary to disconnect the
11 customer.Staff recommends that it increase efforts to
12 ensure compliance and prevent cross-contamination of its
13 system.
14
Boise East First Bench Discolored Water15
16 Q.Please provide information on the discolored
17 water on the East First Bench ("EFB")for January 2020
18 through October 2022.
19 A.There was a total of 66 discolored water reports
20 with a flushing credit applied.The total amount of
21 flushing credits was $99.00.Exhibit No.141.The number22
of calls has gone down every year,with the exception of a23
24 spike in November of 2021,which was correlated to when the
25 Company was performing Ice Pigging on the lines.
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)1102/15/23 STAFF
1 Company Documents
2 Q.Have Veolia's forms required by the Utility
3 Customer Relations Rules (UCRR)(IDAPA 31.21.01)been
4 reviewed for compliance?
5
A.Yes.Veolia's forms were reviewed and determined6
7 to meet the requirements of the UCRR.
8 Q.Does Staff support the Company's proposed updates
9 to the language included in the tariffs?
10 A.Yes.Staff has reviewed the Company's proposed
11 changes and supports updating the language.The actual
12 rates to be included in the tariffs will be determined by13
the Commission.
14
Q.Does this conclude your testimony in this15
16 proceeding?
17 A.Yes,it does.
18
19
20
21
22
23
24
25
CASE NO.VEO-W-22-02 BOSSARD,J.(Di)1202/15/23 STAFF
Professional Qualifications
Of
Jolene Bossard
Utilities Compliance Investigator
Idaho Public Utilities Commission
EDUCATION
Ms.Bossard graduated with honors from the College of Western
Idaho (CWI)in 2013 with a dual Associate of Applied Science
(AAS)degree in Accounting and Administrative Support.She was
a member of the Phi Theta Kappa honor society and did herinternshipworkingasanadmininthepresident's office of CWI.
BUSINESS EXPERIENCE
Prior to joining the Idaho Public Utilities Commission (IPUC),
Ms.Bossard had twenty-nine years'experience working in privateindustryforHewlettPackardinavarietyofpositions.In the
1980's,the positions included lamination,electroless,photolab,and process mechanic in the fabrication of printed circuit
boards.She was also trained for the chemical emergency
response team.The rest of her career was working as a New and
Current Technical Product/Process Specialist in the Storage
Division.In that capacity,she was an expert in life cycle
related activities and support in systemic transactions.
Ms.Bossard was responsible for assisting engineering teams,marketing,procurement,and manufacturing in setting up,implementing,and coordinating change to manufacturing processes
and products on a worldwide basis.In addition,she wasresponsiblefordevelopinganddocumentingsystems,processes,investigating issues,collecting data,managing documentation,
and communicating/coordinating change between multiple world-
wide organizations in support of the life cycle activities.
Ms.Bossard joined the Idaho Public Utilities Commission in 2014
as a Utilities Compliance Investigator.For almost 9 years she
has investigated and facilitated conflict resolution between
customers and utilities in accordance with Utility Customer
Relations Rules and Idaho State Statutes by interviewing
consumers to determine and discuss the basis of their disputes,
Exhibit No.136
Case No.VEO-W-22-02
J.Bossard,Staff
02/15/22 Page 1 of 2
suggest equitable solutions,and mediate disputes between
consumers and utilities or negotiate with utilities on behalf of
consumers.In addition,she works with agencies in helping
customers in financial crises procure funding to help pay theirutilitybills.
She has also participated in a variety of cases before theCommissionwiththeresponsibilityofadvocatingonthe
consumers behalf by reviewing issues from previous cases,reviewing previous complaints,reviewing submitted comments fromcustomers,and investigating consumer issues raised in the case.
She also reviews the company's customer facing documentation,including notices and press releases.
Exhibit No.136
Case No.VEO-W-22-02
J.Bossard,Staff02/15/22 Page 2 of 2
Veolia Water
Complaint &Inquiry Totals
2020 -2022
2020 2021 2022 Total
Credit and Collection 6 5 18 29
Line Extension/Installation 6 5 3 14
Service Outage/Repair 6 7 13 26
Billing 15 9 36 60
Rates/Policies 25 22 29 76
All Other 17 14 15 46
Total Complaints and Inquiries 75 62 114 251
Exhibit No.137
Case No.VEO-W-22-02
J.Bossard,Staff
02/15/22
Veolia's Average Speedof
Answer (ASA)
ASA
(Seconds)Period
20 20-Jan
43 20-Feb
26 20-Mar
14 20-Apr
ll 20-May
28 20-Jun
26 20-Jul
38 20-Aug
25 20-Sep
29 20-Oct
36 20-Nov
24 20-Dec
13 21-Jan
14 21-Feb
16 21-Mar
14 21-Apr
13 21-May
23 21-Jun
42 21-Jul
29 21-Aug
13 21-Sep
13 21-Oct
26 21-Nov
22 21-Dec
19 22-Jan
12 22-Feb
15 22-Mar
13 22-Apr
23 22-May
23 22-Jun
37 22-Jul
75 22-Aug
170 22-Sep
140 22-Oct
59 22-Nov
Exhibit No.138
Case No.VEO-W--22--02
J.Bossard,Staff02/15/22
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 157"DAY OF FEBRUARY 2023,SERVED THE FOREGOING DIRECT TESTIMONY OF JOLENE BOSSARD,INCASENO.VEO-W-22-02,BY E-MAILING A COPY THEREOF,TO THEFOLLOWING:
PRESTON N CARTER DAVID NJUGUNAMORGANGOODINMGR-REGULATORYBUSINESSGIVENSPURSLEYLLPVEOLIAWATERM&S INCPOBOX2720461FROMROADSTE400BOISEID83701-2720 PARAMUA NJ 07052E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
[e-mail]
LORNA K.JORGENSEN SHARON M.ULLMAN,PRO SEMEGWADDEL5991E.BLACK GOLD STREETADACOUNTYPROSECUTINGBOISE,ID 83716ATTORNEY'S E-MAIL:[e-mail]/CIVIL DIVISION
200 W.FRONT STREET,ROOM 3191
BOISE,ID 83702
E-MAIL:civilpafiles adacounty.id.cov
JIM SWIER AUSTIN RUESCHHOFFMICRONTECHNOLOGY,INC.THORVALD A.NELSON8000SOUTHFEDERALWAYAUSTINW.JENSENBOISE,ID 83707 HOLLAND &HART,LLPE-MAIL:iswier micron.co 555 17TH STREET SUITE 3200
DENVER,CO 80202
E-MAIL:[e-mail] [e-mail][e-mail]'S OFFICE [e-mail]
105 N.CAPITOL [e-mail]500
BOISE,ID 83701-0500
E-MAIL:[e-mail]
[e-mail]
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