102595v3.docx

Q.Please state your name and business address for the record.
A.My name is Judy Stokes.  My business address is 472 West Washington Street, Boise, Idaho.
Q.By whom are you employed and in what capacity?
A.I am employed by the Idaho Public Utilities Commission as a Utilities Compliance Investigator in the Consumer Assistance Section.
Q.What is your educational background and relevant employment history?
A.I attended the University of Idaho majoring in education and psychology.  I have taken several continuing education classes and professional courses on consumer affairs.  I also attended the NARUC Regulatory Studies Program at Michigan State University.  I have been employed by the Commission since August 1985, and have been in my present position since March 1986.
Q.Have you previously testified before this Commission?
A.Yes, I have.
Q.What areas will you be addressing in your testimony?
A.I will discuss Capitol Water Company's customer service performance and water conservation efforts.
Q.Please describe the complaints and inquiries received by the Commission from customers of Capitol Water since the last rate case.
A.From March 1993, which is the date of the final order in the CAP-W-92-2 case, to October 1995, the Consumer Assistance Staff has received 24 complaints and inquiries regarding Capitol Water, all of which were from residential customers.  The highest number (8) concerned water quality.  Five comments and one complaint regarded objections to the rate increase.  Two inquiries concerned water pressure.
Q.What was the problem that caused the most unsatisfactory remarks by customers?
A.Eight customers complained about water quality, expressing concerns about the health effects of drinking and cooking with the water supplied by the Company.  Many were concerned about their discolored appliances, toilets, and clothes that do not come clean in their washing machines.  Customers also expressed a concern about the odor of the water.  Some customers believed that the utility's water was unsafe, causing them to use bottled water.
Q.What is the cause of these problems?
A.Jon Wroten, of the Division of Environmental Quality (DEQ), has advised me that iron and manganese appear to be the source of the discoloration.  According, to Mr. Wroten, EPA guidelines suggest the iron and  manganese poses no health threat.  In his September 25, 1995 letter to Capitol Water he stated:
[i]t appears that some of the other public water systems in the area have also experienced the rusty water problem.  Some are actually experiencing a slow increase in the level of iron and this trend is thought to be caused by higher pumping levels caused by higher demand.  If this theory is correct, the more a system is pumped, the higher the level of iron will be found.
The odor problem is caused by hydrogen sulfide.  A July 1990 article from "Opflow", a monthly publication of the American Water Works Association discussed odor problems.  The article states:
Taste and odor problems can affect hot or
cold water, but hot water problems
usually bring complaints of smells like
rotten eggs.
The rotten egg odor is caused by hydrogen
sulfide (H2S) gas.  The odor is
repulsive, but the gas is not usually
harmful at the low concentrations that
occur in a household water system.  This
is not a problem of health but
aesthetics.  It is unpleasant to take a
shower, wash clothes, or cook with water
that smells like decay.
Q.What is the Company's response?
A.When a customer complains of an odor problem, a copy of the "Opflow" article is sent to them as a way of further explanation.  Also, water quality complainants are furnishing with a powdered rust remover called "RoVer".  This helps remove rust from clothes, glassware, appliances, etc.  Written instructions are included.
Q.How did the Consumer Staff answer these concerns?
A.Staff talked with DEQ.  Recognizing that our agencies share jurisdiction with regard to water system health and safety issues, we rely on DEQ to take the lead in such matters by virtue of its greater expertise.  I requested that DEQ address these issues and prepare information for distribution to Capitol Water customers.  Unfortunately, useful information has not yet been made available.
Q.What were the concerns of the customers comments regarding rates?
A.Five inquiries and one complaint regarding rates were received.  The customers were objecting to the Company's current request for a rate increase.  However, a common theme cited for these objections was the desire for improved water quality and increased water pressure in the system before rates were raised.
Q.Do you have any comments on the low number of complaints arising solely out of concern about water  pressure?
A.Yes.  Low pressure complaints to the Commission are always investigated. Sometimes the problem is an accumulation of mineral deposits causing a corroded line.  Other times it is simply low water pressure during periods of high demands.  Capitol Water residential customers have never been metered and enjoy relatively cheap rates using any quantity of water they choose.  Over the years, customers have come to realize that metering of the water system is a sure way to alleviate any unsatisfactory water pressure.  Most customers are aware that complaints to the Commission might result in metering of the whole system and customers do not welcome that resolution.  They are more willing to put up with unsatisfactory water and low water pressure in order to avoid paying the cost for metering the system and possibly having to curtail their own water consumption.
Q.How does Capitol Water respond to their customers regarding complaints and inquiries?
A.The Company keeps no written records of customer complaints and inquiries.  In his response to Staff's Production Request, Robert Price stated that:
In all instances, Capitol does not keep
formal records of communications from its
customers....In all instances, Capitol
attempts to respond immediately to the
customer's comments.
Q.Does the Commission require utilities to keep records of complaints?
A.Yes.  According to Rule 403.01 of the Utility Customer Relations Rules, each utility must keep a record of complaints.  These records must be retained for a minimum of one year.  Although I do not recommend fining the Company for failure to abide by the rule at this time, it is important that the Company come into compliance with the rule.
Q.Has Capitol Water provided information to encourage their customers to use water in an effective and conservative manner?
A.Yes.  In Order No. 24789, Case No. CAP-W-92-2, the Commission made the following finding regarding water conservation:
Capitol Water's customers must be
informed of cost-effective methods of
water conservation.  A stronger water
education program should be implemented
focusing on both indoor and outdoor use.
Bill inserts, particularly in the spring,
cooperating with other groups, and
advertising conservation tips on radio,
television, etc., are elements of any
water conservation program.  Capitol
Water should implement a water
conservation program and begin promoting
it when it begins billing the summer
sprinkler rate in May.
In his response to the Fourth Production Request of the Commission Staff regarding the Company's continuation of a water conservation program, Mr. Price stated:
Capitol has, within budgetary
constraints, undertaken to comply with
the referenced Order....Capitol has not
advertised water conservation tips on
radio or television, due to the cost of
such measures.  Capitol does have a
continuing program providing its
customers with materials addressing water
conservation....In June of 1992, Capitol
mailed to its customers an IWCC
publication titled "Water Wise Gardening
Principles;" during the summer of 1993,
Capitol mailed to its customers an AWWA
publication on water conservation; and in
July of 1995, Capitol mailed to its
customers an AWWA publication titled
"What Everyone Should Do for Drinking
Water"....Capitol believes that its
efforts to promote water conservation
have increased the awareness of some of
its customers to this issue.
Q.Were the Company's efforts to promote water conservation successful?
A.It is difficult to determine consumption due to the fact that neither residential customers nor the Company's wells are metered.  Flat rate customers have no monetary incentive to conserve water as their efforts will not show up as dollars saved on their monthly bill.
Q.Should water conservation continue to be promoted for unmetered customers?
A.Yes.  The Company needs to acknowledge that these customers have little direct economic incentive to conserve water.  The Company's conservation program must focus on the long-term economic benefits and appeal to consumers' responsibility to develop good water use and management habits.
Q.Do you have any comments and recommendations?
A.Yes.  I would like to see the Company's  efforts toward promoting conservation continue.  Customers need to be aware that the cost to the Company for pumping water from its wells ultimately affects customers' rates.  Conservation and judicious use of water will reduce the amount of water the Company needs to pump and thereby reduce the costs associated with pumping, such as energy, maintenance, and repair costs.  This in turn may delay the need for future rate increases.
I recommend that Capitol Water provide information to customers on water quality issues and continue providing water conservation and wise water use information.  I also strongly encourage the Company to keep a record of complaints as required by Commission rule.
Q.Does this conclude your testimony in this proceeding?
A.Yes, it does.