20190510Staff 1-47 to Suez Water.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
RECEIVED
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Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF SUEZ WATER IDAHO
INC.'S PETITION FOR AN EXEMPTION F'ROM
UTILITY CUSTOMER RELATIONS RULES
311(4) AND (s)
CASE NO. SUZ.W.I9.Ol
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
SUEZ WATER IDAHO INC.
The Staff of the Idaho Public Utilities Commission requests that SUEZ Water Idaho Inc.
(Company) provide the following documents and information as soon as possible, by FRIDAY,
MAY 31,2019.
This Production Request is continuing, and the Company is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0r.0t.228.
FIRST PRODUCTION REQUEST
TO SUEZ WATER
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In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: In testimony, the Company discusses the evaluation of remote-
capable meters. Cary Direct at 1 1. Please provide the Company's most recent remote-capable
meter study and testing documentation.
REQUEST NO. 2: For customers with remote disconnect/reconnect meters, will the
Company offer the same after-hours reconnection option currently available? How does the
Company intend to collect the reconnection fee? Does the Company intend to charge those
customers the same fees as other customers without advanced meters? If so, please provide
justification for the charge. If not, what is the Company proposing in its place?
REQUEST NO. 3: How many meters with remote disconnect/reconnect capability are
currently installed on customer premises and how many of the meters does the Company
anticipate installing over the next calendar year? Please provide a breakdown by customer class
(residential and non-residential) and selection criteria.
REQUEST NO. 4: When a customer closes an account at a location where the
Company has installed a meter with remote disconnect/reconnect capability, does the Company
allow the meter to remain in place?
REQUEST NO. 5: If the targeted customer moves to a new location within the
Company's service territory, will the Company install a meter with remote disconnect/reconnect
capability at the customer's new location?
REQUEST NO. 6: Does the Company move a meter with remote disconnect/reconnect
capability to a different location if a customer no longer meets, or a subsequent customer does
not meet, the selection criteria for this type of meter? Please explain.
FIRST PRODUCTION REQUEST
TO SUEZ WATER 2 MAY 10,2019
REQUEST NO. 7: Please provide the Company's unit cost for a meter with remote
disconnect/reconnect capability with documentation. Please provide the Company's unit cost for
a meter without remote disconnect/reconnect capability with documentation.
REQUEST NO. 8: For the calendar year 2018, please provide the number of scheduled
disconnections that were cancelled by an on-site employee who had concerns about the impact of
disconnection on the customer's health and/or safety.
REQUEST NO. 9: If the requested rule exemption is approved, please identify any
circumstances under which the Company's employees will allow a customer the choice to make
an electronic payment during the employee's visit to the customer's premises.
REQUEST NO. 10: Does the Company electronically notify customers of a pending
disconnection of service? If so, please explain: ( 1) how the notification occurs (timing, whether
by e-mail or text message, etc.); and (2) whether electronic notification is in addition to, or in
lieu of, sending written notices via US Mail.
REQUEST NO. 11: Please clarify and identify when the $15 Field Collection Trip
Charge still applies to those that have the advanced meters that have the ability to remotely turn
on/off meters.
REQUEST NO. 12: In testimony, the Company states that eliminating field payment
collection should help offset costs. Cary Direct at 19.
a. Please provide all analysis the Company has conducted in this area.
b. If the Company has not done any analysis, please provide assumptions used to make
the assertion that costs could be offset.
REQUEST NO. 13: Please explain in detail how the current calling system is used to
notify customers. Does it track whether the call was completed or not, whether the customer
answered the phone or the call went to voicemail? Does it track whether the call was blocked or
otherwise not allowed to complete the message?
FIRST PRODUCTION REQUEST
TO SUEZ WATER J MAY 10,2019
REQUEST NO. 14: What steps does the Company take to validate the telephone
numbers it has on file for customers?
REQUEST NO. 15: Please provide a copy of the Company's current contract with
Western Union for handling payment transactions.
REQUEST NO. 16: What is the estimated cost per transaction that the Company will
pay if its request to eliminate Western Union processing fees is approved?
REQUEST NO. 17: Please explain whether the Company has had discussions with
Western Union to reduce its convenience fees. If discussions have taken place, please provide a
summary of the discussions, and the implications of the convenience fee cost reduction. If
discussions have not taken place, please explain why not.
REQUEST NO. 18: Please provide the number of customer payments made by each of
the following payment methods in 2018:
a. Call Western Union
b. Western Union pay station (cash)
c. Western Union pay station (check)
d. Pay on SUEZ website (credit card)
e. Pay through ebill (credit card)
REQUEST NO. 19: Per Cary Direct page2l,line2l-22; and page 29,line 18, is the
Company also proposing to defer convenience fees for 'Pay on SUEZ website' and 'Pay through
ebill' by credit card?
REQUEST NO. 20: Does the Company anticipate, that by offering additional fee-free
payment options, the amount of customers who do not pay on time will decrease? If yes, please
explain.
FIRST PRODUCTION REQUEST
TO SUEZ WATER 4 MAY 10,2019
REQUEST NO.2l: For every bill that is sent electronically, what is the cost savings
when compared to printing and mailing a bill?
REQUEST NO. 22: Does the Company anticipate that the number of electronic
(paperless) bills will increase if more customers make payments with credit or debit cards?
Please explain.
REQUEST NO. 23: What is the Company's cost for handling a customer call?
REQUEST NO.24: Does the Company anticipate the number of customer phone calls
regarding fees to decrease if processing fees are eliminated? Please explain.
REQUEST NO. 25: Please provide the annual number of calls, inquiries, complaints,
and suggestions the Company received regarding convenience fees in 2018.
REQUEST NO. 26: What is the current transaction limit for each customer class for
credit, debit, savings and checking account payments made through Western Union? If the
exemption is approved would the current transaction limit remain the same? If not, what limit
would be established?
REQUEST NO. 27: Does the Company's proposal to eliminate Western Union payment
processing fees include all customer classes? If no, please explain.
REQUEST NO.28: Please provide by customer class the number of customers that paid
with debit or credit cards in 2018.
REQUEST NO. 29: Under the proposal to eliminate Western Union processing fees,
will residential customers still be charged for paying by phone or online using a checking or
saving account?
FIRST PRODUCTION REQUEST
TO SUEZ WATER 5 MAY t0,2019
REQUEST NO.30: Under the Company's proposal, will residential customers be able
to set up automatic bill payment using a credit or debit card? Please explain.
REQUEST NO. 31: Please explain the difference between a Western Union Quick
Collect location and a Western Union pay station.
REQUEST NO. 32: After payment is made through Western Union, are those
customers with a pending disconnection still required to contact the Company with the payment
confirmation number to cancel the disconnection? If so, how can this step be eliminated in order
to avoid disconnecting service for customers who have paid their bills?
REQUEST NO.33: What is the current lag time between when a customer makes a
Western Union payment and (a) when the Company is notified of payment, and (b) when the
payment is posted to a customer's account? Additionally, does the Company expect the payment
processing/posting time will increase, decrease, or stay the same as a result of the Company
paying the costs associated with the transactions?
REQUEST NO.34: If the Company's proposal is approved, what percentage of
residential customers does the Company expect will make debit card payments within the f,rrst
year and second year?
REQUEST NO.35: Please describe the difference between E-Pay Direct Debit (ACH)
and Pay Through ebill (ACH).
REQUEST NO.36: Please explain the difference between Western Union ACH and
Western Union ATM.
REQUEST NO.37: Please explain the communication plan the Company would
implement to direct customers to other payment method options when payments are no longer
accepted at the Company's central office. Cary Direct at p. 27. Please provide examples of all
work done to date on this plan.
FIRST PRODUCTION REQUEST
TO SUEZ WATER MAY 10,20196
REQUEST NO. 38: How does the Company propose to notify its customers that all
customer Western Union payment processing fees have been eliminated?
REQUEST NO. 39: In testimony, the Company explains that the US Bank (downtown)
is a payment location. Cary Direct at 16. Has the Company pursued the possibility of customers
making payments at additional US Bank locations? If yes, please explain. If not, why not?
REQUEST NO. 40: Has the Company pursued the reduction of the US Bank $5.00
processing fee for "cash" payment processing? If not, why not? If yes, please explain.
REQUEST NO. 41: In testimony, the Company proposes changes to its NSF policy.
Cary Direct at28.
a. Please provide exact language for the proposed policy change.
b. Regarding Sheet No. 9, Schedule No. 5 of the Company's tariff item l, the "Return
Check Charge," does the Company intend to file an updated tariff to reflect the
proposed change? [f yes, when? If not, why not?
REQUEST NO. 42: Sheet No. 9, Schedule No. 5, of the Company's tariff item 3
describes the "Field Collection Trip Charge." If the exemption to collecting fees in the field is
granted, this item will no longer apply. How and when does the Company intend to file an
updated tariff to reflect the proposed change? If yes, when? If not, why not?
REQUEST NO. 43: Has the Company had discussions with other processing vendors
offering a Utility Payment Program? If discussions have taken place, please provide a summary
of those discussions. If discussions have not taken place, please explain why.
REQUEST NO. 44: Please provide the expected deferral cost to the regulatory asset for
2019,2020, and202l.
FIRST PRODUCTION REQUEST
TO SUEZ WATER 7 MAY 10,20t9
REQUEST NO. 45: Please quantify the benefits to all customers of (a) removing the
ability to receive payments at the Victory office, and (b) removing convenience fees.
REQUEST NO. 46: Does the Company expect to defer any additional costs such as, but
not limited to, additional calls from Televox, additional mailers, and meters? Please explain.
REQUEST NO. 47: Please provide a list and copies of all cost/benefit analyses and
workpapers supporting the Company requested changes.
g,
Dated at Boise, Idaho, this i,t day of May 2019
Matt Hunter
Deputy Attorney General
i/utility/umisc/production requests/suzwl9. lmhcttnccwhksk prod req 1
FIRST PRODUCTION REQUEST
TO SUEZ WATER 8 MAY 10,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IOTH DAY OF MAY 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO SUEZ WATER IDAHO INC., IN CASE NO.
SUZ-W-19-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL C CREAMER
GIVENS PURSLEY LLP
PO BOX2720
BOrSE rD 8370t-2720
E-MAIL : rncc/,(? givenspurslcy.com
MARSHALL THOMPSON
SUEZ WATER IDAHO INC
8284 W. VICTORY RD
BOISE ID 83709
E-MAIL : marshall.thompson(/r)slrez.com
SECRET
CERTIFICATE OF SERVICE
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