20050406Ottens direct.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
b m purdy(fYhotmail. co m
Attorney for Petitioner
Community Action Partnership
Association of Idaho
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UTILI"fiES COr-li'iiSSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INC FOR THE
AUTHORITY TO CHANGES ITS RATES
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO.
CASE NO. UWI-04-
COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO
DIRECT TESTIMONY OF
TERI OTTENS
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I. INTRODUCTION
Please state your name and business address.
My name is Ted Ottens. I am the Executive Director of the Community Action
Partnership Association of Idaho headquartered at 600 N. Curtis, Suite 175, Boise, Idaho, 83706.
On whose behalf are you testifying in this proceeding?
The Community Action Partnership Association of Idaho ("CAP AI") Board of Directors
asked me to present the views of an expert on, and advocate for, low income customers of United
Water, Inc. ("United Water ) on behalf of CAP AI. CAP AI's participation in this proceeding
reflects our organization s view that low income people are an important part of United Water
customer base, and that these customers will be uniquely impacted by the proposed rate increase.
CAP AI is an association of Idaho s six Community Action Partnerships, the Idaho
Migrant Council and the Canyon County Organization on Aging, Weatherization and Human
Services, all dedicated to promoting self-sufficiency through removing the causes and conditions
of poverty in Idaho s communities.
Community Action Partnerships ("CAPs ) are private, nonprofit organizations that fight
poverty. Each CAP has a designated service area. Combining all CAPS, every county in Idaho
is served. CAPS design their various prograills to meet the unique needs of comillunities located
within their respective service areas. Not every CAP provides all of the following services, but
all work with people to promote and support increased self-sufficiency. Programs provided by
CAPS include: employment preparation and dispatch, education assistance child care, emergency
food, senior independence and support, clothing, home weatherization, energy assistance
affordable housing, health care access, and much more.
Have you testified before this Commission in other proceedings?
Yes, the Commission has resolved, or is in the case of resolving, general rate cases for
Idaho Power Company, A VISTA, PacifiCorp and United Water all in the relatively short time
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ttame of approximately a year and a half. CAP AI intervened in all of those proceedings and I
have testified, or will testify, on CAP AI's behalf in each these cases.
Why has CAP AI intervened in past cases, and in this particular proceeding?
In my opinion, though the Commission Staff, and the Commission itself, have made an
earnest attempt to address low-income concerns over the years, the Commission s legal mandate
is to ensure the fair treatment of all customers and of the utilities it regulates. To the saine extent
that a large industrial customer has the need for and right to representation before the
Commission, so do low-income utility customers. CAP AI believes that, to a certain extent, low-
income customers have not had adequate, independent, representation before the Commission in
recent years and it is CAP AI's mission to fill that void.
Specific to this case is CAP AI's desire to emphasize the impact of United Water
proposed rate increase on low-income customers and to encourage recognition of the value that
low income assistance programs play in helping our seniors, disabled and low incolne families to
become and to remain self-sufficient. This, in turn, benefits all of the utilities ratepayers.
CAP AI also seeks funding and design of applicable programs that will accomplish these
objectives. As discussed below, CAP AI is supporting the creation of programs similar in nature
to those provided by energy utilities to provide assistance with bills and help in the conservation
and use of water.
What is your relevant experience regarding matters before, or issues involving, this
Commission?
CAP AI has been involved in low income issues, including energy related issues, since
the early 1980s. CAPs have been involved in the distribution of weatherization funding,
implementation of weatherization programs, and Low Incolne Holne Energy Assistance Program
payments for more than three decades.
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What other relevant involvement or activities have you or your organization been part of?
As the Executive Director of CAP AI, I am responsible as the statewide administrator of
the federal Colnmunity Service Block Grant, the Emergency Food Assistance Program, the Idaho
Telecommunication Services Assistance Program, the statewide Weatherization program, and in
working with the six Idaho CAPs and Canyon County Organization on Aging in the distribution
of the Low Income Home Energy Assistance and the Weatherization funds. These, and other
service programs administered and/or provided by CAP AI and our CAPs all deal with the needs
of the low income in Idaho.
Previously, I worked as the Energy Director for the Association of Idaho Cities, working
with 2002 cities and 44 counties to address energy and conservation issues within their
respective jurisdictions. Prior to that, I worked with several local governlnental entities in Idaho
Wyoming and California dealing with both low income and energy related issues. Exhibit 301 to
my testimony is my curriculum vitae.
II.SUMMARY
Please summarize your testimony?
My testimony will establish the following:
That United Water s proposed rate increase would have implications for the
Company s low income customers~
That these low income customers are at risk of paying a disproportionate
percentage of their income for a basic need commodity essential to human
survival, exposing them to potential payment arrears, disconnection, and even
homelessness~
That there is a significant number of residential customers who are low income
and are in need of assistance in lowering their water bills, and~
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That the negotiated Stipulation executed by CAP AI and United Water (discussed
below) will provide relief for low-income seniors and families and aid in
offsetting the impacts of a rate increase and should be approved by the
Commission.
III.STIPULATION
Have CAP AI and United Water reached a negotiated settlement of certain issues in this
proceeding?
Yes, we have. Attached to this testimony as Exhibit 302 is a copy of the Stipulation
executed by the two parties. The essential components of the Stipulation are as follows:
Residential Summer Block Rate - United Water has agreed to propose an initial
block rate for the fIrst three hundred cubic feet (3 ccf) of usage for all customers
to be priced at the Company s winter rate, throughout the year. The summer rate
will be 25% higher and will remain in effect froln May 1 through September 30 0
each year. The lost revenue ttom this block is estimated to be $100 406 and is
proposed to be spread across the entire year by adjusting both the winter and
summer rate to block revenue neutral. As explained below, the purpose of this is
to provide the bare minimum, non-discretionary (i.
, "
subsistence level) use of
water at the lower winter rate. CAP AI and United Water submit that this small
amount of initial block rate usage will provide a benefit especially to low-income
customers, but not undermine the Commission s policy and objective of sending
price signals during summer months that excessive use of water drives up rates
for all customers.
United Water Shares" - This program will be similar to Idaho Power
Project Share." Contributions to the fund will be voluntary on the part
ratepayers. United Water has agreed to fund the project in the amount of
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$10 000.00 in 2005, using shareholder funds, and would then match customer
contributions to the fund up to $20 000 in ensuing years. The money accumulated
in the fund account will remain in the possession of United Water at all times and
will be credited against the bills of qualifying low-income customers as
determined by United Water in collaboration with CAP AI's constituent groups.
Eligible customers will be those at or below 150% of the Federal Poverty
Guidelines~ the same criteria used for Idaho Power s LIW A program. Customers
will be eligible a maximum of once per year and the individual benefit cap will be
$50., though this amount may be revisited after the parties have had experience
with the program. Assuming approval by the Commission, CAP AI will
immediately commence processing applications based on United Water s initial
contribution. After the fIrst six months, monthly distributions will be based on
the average monthly collection ttom ratepayers of the previous three months
including United Water matching shareholder funds. The funds will be applied to
bills on a first come, first served basis. United Water will pay CAP AI an
administrative fee equaling 10% of the funds used, which the Company will book
as an operating expense. United Water will fund the costs of bill stuffers and
dissemination of literature by the CAPs to alert ratepayers about the program.
The estimated costs of the bill stuffers is $12 000.00 annually and will be booked
as an operating expense.
Targeted Conservation Help - CAP AI will assist in the dissemination of
conservation literature and "kits" to low-income, United Water customers who
come into direct contact with Community Action Agency staff. The literature and
kits will be provided by United Water.
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IV.NEED FOR ASSISTANCE
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What defInitions are you using to describe a "low income household" and how many of
these households are located within the service area of United Water?
The state of Idaho uses an income defmition to defme eligibility for low income
weatherization and energy assistance as 150% of the federal poverty guidelines as established by
the Federal Office of Management and Budget. Exhibit 303 to my testimony provides a chart of
incomes in relation to the poverty level.
Would you please provide the Commission information regarding the state of poverty in
Idaho and, more specifically, within United Water s service territory?
Yes. According to the Idaho Department of Commerce, 12% of Idaho s population
based on the 2002 Idaho Census, fall within federal poverty guidelines and 21 % fall within the
state guidelines set at 150% of the federal poverty level. The Idaho Census is a state update of
the Federal 2000 Census figures and is conducted by the Idaho Department of Commerce.
Specific to United Water, the poverty rate in the Company s service area is 11., based on
Idaho guidelines.The 2000 Idaho Census reveals that those living in poverty are categorized as
3% elderly, 13.8% children, 8.3% all other families, 35.3% single mothers and 34% all others.
According to United Water s website the Company serves 215 000 people in Ada and Canyon
counties. Of these, 25 370 live in poverty and 45 150 live at or below 150% of poverty.
According the United Water, the average residential bill is $323.05 annually or $26.
monthly. However, United Water states on its website that up to one third of bill could be in two
months during the summer, placing severe burdens upon the low-income senior, disabled citizen
or family during certain times of the year. Currently, United Water does not offer level payor
monthly billing, allowing a low-income family to spread this burden throughout twelve months
resulting in shut-offs of this service.
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The proposed rate increase for residential customers will raise this monthly rate to
$395., further adding to the burden.
Please discuss the level of water service costs in relation to the ability of low income
customers to pay those costs?
More than 20% of United Water customers make less than what is considered a living
wage in Idaho (set at $14.32 an hour by the Idaho Department of Labor and Commerce). Living
wage is described as the wage needed to pay basic expenses at today s costs, and includes the
costs of transportation, child care, food, housing and utilities. These people do not make enough
wages to sufficiently pay for these basic expenses.Though low income people are more easily
described in statistical terms, in reality they are our neighbors, fi-iends and relatives. When
considering the possibilities of accidents, ill health, loss of employment, etc., they potentially
include each of us.
What are the special circumstances that low income households face?
These households pay the highest percentage of their income for all utility costs
compared to other income groups and are the most vulnerable and at risk to change in a
competitive market. They live in society s worst case housing stock, are at risk to hypothermia
and indoor air quality problems. Coupled with an array of other fmancial burdens (cost of child
care, lack of affordable housing, lack of living wage jobs, cutbacks in federal assistance of most
kinds, etc.) they are increasingly moving closer to homelessness.
EFFECT OF STIPULATED LOW-INCOME MEASURES
Please discuss how the proposed Stipulation came into being and how it will function?
United Water currently does not provide any form of low incolne assistance to ratepayers.
In recognition of this, the Company, in its prefiled direct testimony, invited the possibility of
some form of low-income assistance in light of the magnitude of the proposed rate increase.
Following proper notice, a public workshop was conducted on February 23 , 2005, including
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CAPAI, United Water, the Commission Staff, and one member of the public, to discuss the need
for, scope, and design of a low income customer assistance program for the Company.
As a result of the workshop discussion, agreement was reached regarding general
parameters and features of a low-income assistance program. Thereafter, representatives of
United Water and CAP AI continued to discuss possible program features resulting in the
Stipulation described above and attached hereto.
Residential Summer Rate Block CAP AI agrees that a two-tier inclining rate
structure for residential customers will reward those customers who dramatically limit their
summer water use. It will also provide low-incolne assistance in that the poor generally consume
much less water. Though CAP AI has stipulated to an initial block of 3 ccf priced at the
Company s winter rate, and believes that this initial lower block will assist low-income
customers whose usage is typically much less than other residential customers, the appropriate
level of an initial block is, of course, within the discretion of the Commission. CAP AI stands
fIrmly by its Stipulation with United Water but suggests revisiting the amount at some future
point in time after the effects of the block have been analyzed.
CAPAI believes that 3 ccfis at the bottom range of what could be termed a "subsistence
level of water usage." As stated in the Stipulation, based upon a report generated by the Idaho
Department of Environmental Quality, 3 ccfis barely above the amount of water necessary just
to flush toilets and take showers. United Water estimates that approximately 10% of its
customers use 3 ccf or less in a winter billing period. Because the block rate applies to all
customers, it is not discriminatory or preferential.
CAP AI believes that an initial, lower priced block rate is appropriate for United Water.
Regardless of how the commodity is priced, people require a certain amount of water to survive
and perform the most basic of tasks such as laundry, dishes and personal consumption. This
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minimum level of usage is indifferent to price signals and setting a modest initial block would
not undermine the Commission s overall objective of encouraging water conservation.
United Water Shares - CAP AI believes that establishing a voluntary giving program
that will establish a fund to assist low-income seniors, disabled citizens and families in paying
their water bills would be beneficial especially during the months when water usage increases.
Though there will be nominal costs associated with administration and awareness of the
program, CAP AI submits that these costs will be more than offset by reduced utility costs
associated with bad debt, collection, disconnections, etc.
Targeted Conservation Help - CAP AI believes that conservation education and aids are
beneficial for low-income seniors and families in lowering their water bill alnounts and is willing
to participate in the distribution of these materials and aids.
Do you believe that the low-income assistance provided by the Stipulation will address
all of United Water s low-income customer needs?
, but it is a welcome starting point. Along these lines, CAP AI compliments United
Water for what could legitimately be characterized as an unprecedented gesture on the part of an
Idaho public water utility to offer unsolicited assistance to the poor in the context of a general
rate case. CAP AI greatly appreciates United Water s efforts and willingness to work toward a
worthwhile goal that ultimately benefits all ratepayers.
Are there any other low-income assistance measures that could be considered in this case
or in the future?
Yes, although not included in the Stipulation, CAP AI believes that a level payor monthly
pay program would also benefit low-incolne seniors, disabled and falnilies in setting budgets and
controlling costs.
Though the largest public water utility in Idaho, United Water covers only a portion of
the state. How will this Stipulation help other low-income seniors and families around Idaho?
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The programs stipulated to by United Water and CAPAI are a good place to start in
setting examples and establishing the need for low-income customer assistance programs within
water utilities.
If the Stipulation is approved by the Commission, United Water would, presumably, be
the only regulated water utility in Idaho to have a low-income program. Because United Water
is the state s largest public water utility, it presents the greatest opportunity to assist the state
low-income citizens. Approval of the stipulation might also prove to be a catalyst for other
water utilities to implement similar measures.
VI. CONCLUSION
Could you summarize your recommendations to the Commission?
Yes. They are listed below:
Approve the Stipulation entered into between United Water and CAP AI establishing the
following programs:
Residential Summer Rate Block
Voluntary Giving Program
Targeted Conservation Help
CAP AI also believes that the Comlnission should consider a level or Inonthly pay pro grain in the
future as another tool to assist low-income seniors, disabled and families with their budgeting on
water usage costs.
Does that conclude your direct testimony?
Yes it does. I thank the Commission for the opportunity to participate in this proceeding.
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CERTIFICA TE OF SERVICE
I HEREBY CERTIFY that on the 6th day of April, 2005, I caused to be served the
foregoing DIRECT PREFILED TESTIMONY OF TERI OTTENS on the following, in
the manner indicated.
Donovan Walker
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID. 83702
() U.S. Mail, postage prepaid
'bctHand delivered
r) Facsimile
() Overnight mail
Dean J. Miller
McDevitt & Miller LLP
420 W. Bannock St.
Boise, Idaho 83702
' U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Mark Gennari
United Water
200 Old Hook Road
Harrington Park, NJ 07640-1738
()f U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Douglas Strickling
Boise City Attorney s Office
150 N. Capitol Blvd
Boise, ID. 83702
(If U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Chuck Mickelson
City of Boise
150 N. Capitol Blvd.
Boise, ID. 83702
~ U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
William M. Eddie
Advocates for the West
1320 W. Franklin St.
Boise, ID. 83702
fYI- U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Bill Sedivy
Idaho Rivers United
2600 Rose Hill, #207
Boise, ID. 83701
M U.S. Mail, postage prepaid
(J Hand delivered
(J Facsimile
() Overnight mail
DIRECT TESTIMONY OF TERI OTTENS
Sharon Ulman
9627 W. Desert Ave.
Boise, ID. 83709
Scott Campbell
101 S. Capitol Blvd., 10th Floor
Boise, ID. 83702
M U.S. Mail, postage prepaid
r) Hand delivered
() Facsimile
() Overnight mail
II) u.s. Mail, postage prepaid
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DIRECT TESTIMONY OF TERI OTTENS
04/06/2005 13: 48 2083214819 PAGE
Exhibit 301
17949 Good$On Rd.
Caldwell, Idaho 83605
TERI L. OTTENS
Work - 208-321-2389
Horne - 208-454-1259
EDUCATIONBachelor of Arts, Government, California State University at Sacramento
, 1917Completed 19 credits of Masters of Public Administration courses, University of Wyoming and
Boise State University 1983- J 990
RELATED EXPERIENCE
Executive Director Community Action Partnership Association of Idaho, 2000 to Present, Boise, IDCAP AI is a non-profit association advocating for low income issues including energy. Duties includeadministration of numerous grants and programs, staff supervision, working with eight member agenciescoordination of policies and issues, financial oversight.
Owner Association Manag~ment Solutions, 1998 to Preseat, Boisej ID. This company providesmanagement services to public and private associations. Sec-vices offered include membership recruitmentand tracking, administrative services, legislative monitoring and lobbying, desktop pubHsbing ofnewsletters~ directories and conference material; conference and event planning and other services required
by the association. The company currently manages six associations one of which has a contraCt with theNorthwest Energy Efficiency Alliance to provide energy code and efficiency education to cities andcounties.
~ut)' Director 1997 to 1998, Tee ical Se ices 'rector 1994.1996, Association of Jdabo Cities,Boise, (D, AIC is a non-profit membership oa:ganiza.tion for Idaho cities. Duties included:Worked with over 100 cities and the majority of the 44 counties on planning issues fromcomprehensive planning, implementation ordinances, area of impact, open space preservationand other related issues
Worked as the Energy Coordinator for AIC and the Idaho Associa.tion of Counties to promoteenergy efficiency and address energy related CO11cems of their citizens at a statew ide level.Developed and followed through on pubHc participation/education plans
Worked with cities and counties to develop regional partnerships in meeting planning goals
Participating in the writing and preparation of AIC pub1ications, reports and articlesActing as spokesperson or liaison for the organization with many other groups, the media and
the state Jegislature
Identifying and developing fimding resources and partnerships! including extensive grant
writing and administtation
Administrative Officer.City of Caldwell, ID, 1989-1993. Dutieg incJuded:
Daily administration of all facets of city government including working with AIC and localutilities on related issues including how energy issues affected CaldweJ) citizens.
Served as Budget Officer in prepuratiol1 and management of $14 mil1ion budget
Served as Personnel Officer and the American with Disabilities Coordinator
. Preparation of meeting agendas and staff reports
Grants Officer responsible for over $250,000 in grants
hwoJved ht strategic plannb'8 at a1l1evet~ including the city comprehensive plan! area ofJlnpact
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' I 301
PAGE 132134/66/213135 13: 48 21383214819
negotiations9 in1TastructUre master plans, budgets and the Regional/Urban Design AssistanceTeam (R/UDAT) Study.
Information Officer/f..lanner.Ada County Development Services, ID, 1988.popu)ation of over 200 OOO. Duties included:
Knowledge of land use planning, zoning laws and issues
growth management.hlterpersonaJ skills in dealing with general public. governmental agencies and developers incomplaint and enforcement issues.
Ada County serves a
.Executive Director.Downtown Casper Development Corporation, 1986-1987. DCDC is a non-profitmembership agency with responsibility for downtown redevelopment.
Duties h1cluded:Business retention expansion and recruitment
All administrative functions of organization including budgeting, preparation of Board agendas
and reports, staff supervision, membership development
Fund raising for the organization~ including membership development. identifying grantresources and corporatelbusiness donors. This included preparing and making
presentationsResponding to membership needs/technical assistance
Assistant CityManag.;r.City of Lanunie, WY 1980-1986. Duties included:
Working with the City County Plauning Office to coordinate city/county growth
Preparation and management of $17 million budget as City Budget Oflicer.
Understanding and management of city risk management program, utility franchises, personnel,grant writing and contract negotiations and administration.
Public Intonnation Officer
Plan and arc City of Tracy, CA 1977-1979. Duties incJuded~Facilities and program planning and implementation
Grant administration, volunteer coordinator
OTHER RELATED EXPERIENCE
United Way Board Member, Canyon Area United Way,1988 to presentUntied Way Board Member, Wymning (Laramie and Casper), 1980-1988Member~ Idaho Community Forestry Council I 993.PresentMember, Caldwell Beautification CormuiUee 1988.1998Coordinator, 'Caldwell Area Paint the Town 1989.) 995Member, Mayor s Committee for the Disabled, Caldwell )988-
Member, IDOC Fair Housing Advisory Committee, 1996-1997Member, Middleton School District Parents Advisory Committee, J 99S.PresentUnited Way FEMA Committee - 1992
V ollinteer Member~ WaUace Institute Agricultllra,l Preservation Task Force, 1998- I 999
HONORS
. Outstanding Young Woman of America.. 1983 and 1987
. Distinguished Service Award, Laramie Jaycees 1985
. Outstanding Young Wyomingite, Wyoming Jaycees, 1986
. Friend of American Education, Natrona County School District
'" Woman of the Year, Beta Sigma Phi, 1992
REFERENCES
Deb Hemmert~ President
SEICCA
208-746-3351
Michael McEvoy
Canyon County Fanll Bureau
208-585.2277
134/135/213135 13: 48 21383214819
Sheila McGregor, President
Idaho Youth Games
208-455-4582
Dr. Kathryn Wells
Idaho Society for Protection of At-RiskChildren (ISP ARC)
PAGE 133
Sent By: MCDEVITT & MILLER LLP;
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208 336 6912;Apr-05 9:59AM;Page 2
Dean J. Mi lIer
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2.564-83701
Boise, ID 83702
Tel: [phone]
fax: 208.336,6912
joe~mcd~vitt,Aminer. com
?\tCEIVEO (~J
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~ons MAR 23 PM ta: t. I
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U TIU'rlCS COHHISSION
Altorncy.for Applicant
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE l\.1A ITER OF THE APPLlCA TION
OF UNITED WATER IDAHO INC. FOR
AUTHOIUTY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO
Case No. UWI-W..o4-
STIPULATION
COME NOW United Water Idaho Inc, ("United" or "the Company ) and Community
Action Partnership Association of Idaho e'CAPAI")~ by and through their respective counsel of
record and stipulate and agree as follows:
On February 23, 2005 representatives of United and CAPAI participatcd in a public
workshop held at the Commission offices, Members of the Commission Staff also participated.
The workf;hop was prec~ded by a public notice, issued February 3,2005.
The purpose of the workshop was to discuss the need for, scope, and design of a low~
income customer a,ssistance program for United Water customers.
As a result of the workshop discussions~ agreement was reached regarding the general
parameter; and features of a low-income a~~i~tance program. Thereafter representatives of
United ant! CAP AI contmuc:d to discuss possible program features.
Based thereon~ after extensive good faith negotiations, United and CAP Al have reached
an agreement upon a proposed low-income assistance program, for consideration by the
Commissbn. The proposed three-part program is described in Attachment A, hereto. The text of
STIPULATION-
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Sent By: MCDEVITT & MI LLER LLP;208 336 6912;Apr - 6 - 05 10: OOAM;Page 3
Attachment A has also been filed with the Commission in response to Staff Production RequeSt
No. 54,
United and CAPAI believe the low-income assistance program described in AttachmeJu
A would provide measurable benefit to low-income customers without burden to the general
body of United's ratepayers and that the program is consist~nt with and promott:s the public
inlcn:sl.
United and CAP AI respectfully request that the Commission approve the low-income
assistance progl'aln, describc:d in Attachment A , in the Commission s Final Order in this
proceeding.
Dated this day of March, 2005,
McDEVITT & MILt.~R LLP CAP AI
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Anorneys for United W aler Idaho lnc.
Brad M. Purdy
Attorneysfo,. Community Action
Partnership of Idaho
STIPULA T.ON-
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Atta.:hment A ftc1S also been filed with the Commission jn response to Staff Production Request
No. :;4,
United and CAPAI believe the low-income assi!ltance program described in Attachment
A w(tuJd provide mc3$urable benefit to low-income customers without burd~n to the geoeral
body of United's rotcpayc~ and that tbe progIam is; consistent with and promotes the public
1nterc:st.
United and CAP AI respectfully request tflat the Commission approve the low.incom~
3ssist.:lnce pr;ogram, described in Attachment At in the Commission s Final Order in Ibis
proce.~uing.
Dated this day of Mal'ch. 2005.
McDEVITT & MILLER LLP CAP AI
Dean 1. MjlJer
Attorneys for UniJed .Valer Idaho fnc.
Brad M. Purdy
Allorneys for Community Action
Partner.rhip 01 Idaho
STIPULA 1 1O~2
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Sent By: MCDEVITT & MILLER LLP;208 336 6912;Apr-05 10:00AM;
CERTIFICATE OF SERVICE
I hereby C~rt1fy that On the
~?~
ofMarch~ 2005, I caused to be s~rvcd, via th~ mcthod(s) indicatedbeJow~ true and COlTeCt copies of the foregoing document, upon;
Brad M, Pul'dy
Allorneyfo/ the CommUNity Ac:l;on Partnership
A~'sociat;o" of Idaho
2019 North 17111 Street
Boise, Idahc, 83702
Fax: [phone]S 11
hmpurdy(tp~,rmai I,com
William M. Eddie
Advo,'atesfioy the WesJ
D, Box 1612-83701
1320 West Frllnklin Street
Boise, Idaho 83702
Fax: [phone]
hi IIcddie(m.nnki.n.~
Bill Sedivy
Idaho Rill#tf:!J United
O. Box 633
Boise, Idahu 113701
fax: 208.34,9376
iru~ida~.2d'y~rs.org
Sharon Unman
9627 West Desert Avenue
Boise, Idaho 83709
j-'
ax: 362-0843
sharonuCcV,cabteonc .net
Chuck Mickdson
Boise City Pub/h,,' Works
O. Box 500--83701
150 Nonh' Capilo1 Boul~vflrd
Boise. Idaho 83702
Fax: 208.3$4,7841
~mk kc ISOT1(ii!cityofboi
Douglas K. Str~ckl~ng
Boise City A Ilorney 's OJfi"tJ
O. Box 50(1-,83701
SO Nonh C~.pitol Boulevard
Boise, Idaho 83702
ax: 208.314.4454
dstrickl~~itYofbojsc,or~
Scon L. Campbell
Moffatt Thomtlj
101 South Ce.pi1oJ Blvd., IOItt Floor
o. Box82~--83701-0829
Boise, Idaho 83702
Fax: 208.38~:5384
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Page 5
Sent By: MCDEVITT & MILLER LLP;208 336 6912;Apr-05 10:00AM;Page 6
ATTACHMENT A
United Water Idaho
Proposed Low-Income Assistance Program
A~ part of it's filing before the Idaho Public Utilities Commission fur authority to increase its
rates and t;hnrges for water service, United Water idaho (United) proposed to convene a
workshop(s) to evaluate the need for, scope and design of a low-income as~istancc program for
customers, (see Wyatt Direct Testimony page 16, Hne 1& through page J7, line 16). Afteradequate l)Uhlic notification, a workshop was conducted on February 23, 2005 at the
Commission offices from 10:00 A.M. until approximately noon. In addition to United and
Commission Stair, representatives of Community Action Partnership of Idaho (CAPAI) and one
individual customer participated in the workshop. A copy of the workshop agenda is attached.
Following the workshop, United and CAPAJ have continued a dialogue regarding n low-incomeassistance program resulting in the following proposal.
United's proposed low-income assistance program is comprised of three components: a lower
priced initial rate block in the summer, a fund from which customers may receive water biUpayment aisistance and targeted water conservation help.
Residentinl Summer Rate Block
United proposes implementing 8 two-tier inclining summer rate structure for residential
customers where the first 3 hundred cubic feet (ccf) of water consumed in a billing cycle is
prict:d at the winter rate, and all other water consumption priced at the 25% higher summer rate.
This inclining rate block structure would be effective May I through September 30 of each year
to coincide: with the current ~'summer rate" timing.
The ~~Iost revenue:" from 3 ccf of consumption in the summer priced at the winter rate has been
calculated to be $100,406. United recommends spreading this revenue across the entire year and
adjusting both the winter rate and the summer rate accordingly in order to make this component
of the low-income assistance program essentially revenue neutral to the Company.
The 3 eef level (2,244 gallons) was chosen based on the perception that a "subsistence" level of
water could be priced at the winter rate in order to enable residential customers to "flush the
toilet and t'1ke a shower " in the summer for the same cost as in the winter. Statistics from a 1997
Idaho Deplartment of Environmental Quality report (the most Current IDEQ data available) shows
that average daily househo1d toilet and shower use is approximately 30 gallons a day, (18 gallons
for toilet and 12 gallons for shower). For a 60-day billing period this amounts to 1.800 gallons
of water. Therefore the 3ccfthreshold accommodates a small amount of water use (444 gallons)
in excess of this "toilet and shower" use each billing period.
United a15(0 analyzed its billing data and detennined that approximately 100/0 of its customers
billed during the winter use period~ use 3ccf or less in a billing period. It is reasonable to assume
that 1ow-in.::ome users would be in this low water consumption group so it is logical to project
that, although the Jccfrate block in the summer will benefit all users, it will benefit low. income
ust'!rs the most.
Anachmcnt A
Page I of 4
Sent By: MCDEVITT & MI LLER LLP;208 336 6912;Ap r - 6 - 05 1 0 : 01 AM;Page 7/9
U Bited \\jater Shares
United proposes a volumary giving program to a .'United Water Shares" fund ,\mong itscustomers through its billing and collections process. United's shareholders would initiallysup~ort. the United Water Shares fund in an a,mollnt of$10,OOO in 2005 (assuming the programheglns In July 2005) and would then motch customer contributions Lo the fund up to $20 000 inensuing Yf:nrs. Customers would have: the option of donating to the United Water Shares fund
when paying their bill.
United would initially partner with CAPAI for customer screening and administration of the
fund. CAP A I would :)creen applicants for eligibility and to determine account credits. The
following describes the basic program parameters:
In emt
CAPAI begins to process benefits as soon as the program is authorized based on
United Water shareholder initial infusion offunds.
After the first six months. monthly distributions to be based on the average monthly
collection of the previous three months including United Water shareholder
contributions.
. CAP AI free to solicit other donations to the fund if they choose.
Monthly fund amount to be made availahle to eligible customers on a first.come,
first-served basis.
CAPAI would charge United an administrative fee of 100/0 of the funds used, which
would be booked as a utility operating expense.
Eligjble customers would b~ lhusc at or below 150% of the Federal Poverty
Guidelines.
Maximum individual benefit to he capped at $50.00.
Water termination has to be imminent.
Customer eligibility limited to one time in any calendar year. This Hmitation and/or
the $50.00 cap may be revisited later based on fund utilization and balance.
Distribution:
United Water to hold the United Water Shares funds in a separate account.
CAPAI detennines applicant eHgjbilitYt gathers basic demographic information
(name address, account number, phone numb~r, etc.), and submits daily report to
United Water.
Upon notice from CAP AI, United Water credits eligible accounts and transfers
appropriate amounts from United Water Shares fund to United Water and credits
accounts receivabl~. Follow-up notice of accounts credited made back to CAPAI.
United would communicate and promote the United Water Shares program and seek customer
contributions by means of bill inserts and messages on the bill. United anticipates the annua1
eost for bill inserts to be $12,000, based on three inserts per year al $4tOOO each time, which will
be booked itS a utility operating expense.
Attachment A
Page 2 of 4
Sent By: MCDEVITT & MILLER LLP;208 336 6912;Apr- 6-05 10: 01 AM;Page 8/9
Tar2eted Conserv~tion Help
United proposes targeting water conservation information and water conservation kits (indoor
and outdoor kits) specifically to those customers who are determined eligible for assistance by
CAPAI under the United Water Shares program. CAPAI estimates they serve approximately
300 United Water Idaho customers per year through its Weatheril:C:llion program. These same
customers C:lr~ likely to have need of the United Watee Shares program and could benefit by
implementing water conservation practices. CAPAI would distribute conservation infonnation
and kits supplied by Unhed to the targeted customers.
Attachment A
Page 3 of 4
Sent By: MCDEVITT & MILLER LLP;208 336 6912;Apr-05 10:01AM;
AGENDA
UNITED WATER IDAHO
LOW-INCOME PROGRAM WORKSHOP
IDAHO PUBLIC UTILITIES COMMISSION OFFICES
10:00 A.M. FEBRUARY 23, 2005
Introduction Purposea. Introductions
b. General purpose and goals of the workshop
II.Identify Level of Need for a Low-Income Program
8. Boise demographics (CAPAI)b. LlHEAP informationc. United Water data
III.Identify Program Feature Options3. Tari ff non-tariff options
b. Budget billing (level pay) for eligible participants
c. Time of year avaiJahility
IV.Mechanics of a Low-Income Program
8. Use of a third-party to administer (i.e. Salvation Army)
b. Mechanism to assess/certify eligibility (LIHEAP cenification?)
c. funding - sources and administration
Next Steps
Page 9/9
Att.;luncnt A
Page 4 of 4
04/06/2005 13: 48 2883214819
FY 2004 FederaJ Poverty Guidelines - LllIEAP Clearinghouse
(;Qntact WJIo WeAre N ews!etter
~,
Horne
2004 HHS Poverty Guidelines
For al1 states (except Alaska and Hawaii) and for the District of Columbia
Size of 100 125 150 175 185 ZOOfamilyPereelltPercentPe,.eeat Percent I Pereent Pereent Pereentunitof Poverty or Poverty 01 Poverty or Poverty of Poverty of Poverty of Pove..ty
31 ~110,241 SII,638 SI3 96'116,293 517 224 $18 620
$12,490 SU,739 $15 613 S 18,73.5 521,858 $23, J 07 $24 980
SI5,67~$17 237 $19,588 523 505 $27 423 $28,99~$31 34C
S18,8S(j 120 735 $23 56E S28,27~532,988 $34 873 S37,70(
S22,O3~$24,233 $27 538 $33,045 $38 553 $40 756 $44 060
S25 21()$27 731 $31 513 $37 815 $44 118 S46,63~$50 420
S28,39~$31 ,22~535,488 $42 585 $49,683 $52 522 $56 780
$3) .57CJ $34 72;$39,463 $47 355 SS~248 SS8 40S S63 J4(J
For family units with more than 8 members,. add $3 180 for each additional member.
Note: For optional use in FFY 2004 and mandatory use in FFY 2005
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Page Last Updated: January 6~ 2005
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PAGE 04
Exhibit 303
2/14/2005
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