951201.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 Division.
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 is the purpose of your testimony?
A.The purpose of my testimony is to address customer relations issues associated with the service territory expansion applications of Eagle Water Company (EWC) and United Water Idaho (UWI).  Specifically, I will address accessibility and responsiveness to customers as well as tariff and customer education issues.
Q.How many complaints and inquires were received by the Consumer Assistance Staff from customers of EWC and UWI?
A.Over a three-year period, (October, 1992 through October, 1995), Staff was contacted by 12 of EWC's approximately 1,200 customers and 463 of UWI's approximately 55,000 customers.  This amounts to 10 complaints and inquiries per 1,000 customers of EWC and 8.4 complaints and inquiries per 1,000 customers of UWI.  The complaints were for a variety of reasons.  I rate both companies' performance in the area of customer relations as satisfactory.
EAGLE WATER COMPANY
Q.Is EWC accessible to its customers?
A.Yes.  The Company's business office is located in Eagle.  Customers generally know the staff and owner who live in the Eagle area.  According to EWC, 3% to 5% of their customers pay their monthly bills in the office.
Q.Is Eagle Water responsive to customers who have questions or problems?
A.Yes.  EWC is responsive to its customers' concerns and complaints.  In most cases, the customer's problem is resolved on the same day that it is brought to the Company's attention.
UNITED WATER IDAHO
Q.If UWI's request is granted, will it be accessible to its customers in Eagle?
A.UWI’s business office is located on Victory Road in southwest Boise.  This is a considerable drive for customers who wish to have personal contact with United Water.  UWI customers located in Eagle might perceive it as being less accessible than Eagle Water Company.  However, in response to the Staff's first production request, UWI stated that it intends to establish a paystation in Eagle to enable customers to pay locally.
Q.Is there confusion about what rates UWI intends to charge and how customers will be billed?
A.Yes.  Staff Exhibit No. 113 shows Schedule No. 1, which was filed with the Company's amended application.  It states that customers “shall be billed monthly 50% of the customer charge plus the volume charge.”  The existing customers of UWI are currently billed bi-monthly.  If the Company intends to bill its Eagle customers on a monthly basis, then its rate schedule should clearly reflect that fact.  Customer charges should be expressed directly instead of as half of the listed charge.  The Company has also omitted a meter size entry for one-inch meters, and incorrectly reflects the intended charges associated with each meter size.  The schedule also refers to a summer rate.  However, in its testimony, the Company did not propose a summer rate initially, and no actual volume rate is shown on the rate schedule.  Therefore, this reference is irrelevant and should be removed.
If the Commission approves UWI's request to provide service in Eagle, the Company will need to file a tariff that clearly identifies the rates and charges applicable to its Eagle customers as opposed to its other customers.  If the Company intends to bill its Eagle customers on a monthly basis, that in itself would require the Company to file a separate rate schedule, even if the commodity rates were to remain identical to those now in place for existing UWI customers.
Q.What other concerns do you have?
A.EM2, Inc., provides water system management and operation services on a contractual basis to the City of Eagle and several area homeowners' associations.  EM2 is owned by United Water Resources, and is a sister company of UWI.  EM2 charges end users rates equivalent to those charged by South County Water, a regulated water company that is not affiliated with either UWI or EM2.  EM2 is not a regulated water company.  The relationship between EM2 and UWI has been a source of confusion for customers and the Commission Staff.  Exhibit No. 114 shows a copy of a billing for a customer of the City of Eagle.
The billing clearly features United Water's name and logo.  However, on the top of the page customers are advised to make payments to EM2, Inc.  The telephone number listed, [phone], is UWI's number.  UWI has changed EM2's bills to clarify that EM2, not UWI, is the proper party to which complaints and inquiries can be addressed.  UWI has indicated that it intends to establish a call distribution system that will allow callers to select either UWI or EM2 when they call the telephone number listed on their bills.
My purpose in raising this issue is to point out that some degree of confusion already exists with respect to EM2 and UWI.  If the Commission decides to grant UWI's request to expand its service territory, UWI will need to take steps to explain its relationship to and differentiate itself from EM2.
Q.Do you have any comments?
A.Yes.  UWI rates, as proposed, are different than those paid by UWI's existing customers.  This inconsistency may cause confusion and frustration for UWI's customers.
On the other hand, if UWI's existing rates are applied to its Eagle customers, neighbors living in Eagle will pay rates that are considerably different from one company to the next.  This will also cause confusion and frustration.  The rationale for these differences will have to be clearly communicated to customers now and in the future.  This may not make customers happy, but at least they will know the basis for the rates they are required to pay.
Q.Please summarize your recommendations to the Commission.
A.In summary, I recommend that if UWI's request to serve Eagle is accepted, the Company file a tariff that correctly and clearly reflects the rates for its Eagle customers.  I recommend that the Company educate its customers on the rationale behind the approved rates and explaining the relationship between EM2 and UWI.  I also recommend that UWI establish a paystation in Eagle.
Q.Does that conclude your testimony in this proceeding?
A.Yes, it does.