20210310Suez to CAPAI 1-24.pdf

Michael C. Creamer (lSB No. 4030)
Preston N. Carter (lSB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise, lD 83702
Telephone: [phone]
Facsimile: (208) 388-1 300
m cc@ g iven sp u rsley. co m
presto ncarter@g iven spursley. com
IN THE MATTER OF THE APPLICATION
OF SUEZ WATER IDAHO !NC. FOR
AUTHORIW TO INCREASE lTS RATES
AND CHARGES FOR WATER SERVICE
IN THE STATE OF IDAHO
. , : i'.i:i lrJ fl*i |il,25
Aftorneys for SUEZ Water ldaho lnc.
BEFORE THE IDAHO PUBLIC UTIL]TIES COMMISSION
Case No. SUZ-W-2O42
SUEZ WATER IDAHO INC.'S
RESPONSE TO COMMUN]TY
ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST
PRODUCTION REQUESTS
SUEZ Water Idaho lnc., ("SUEZWater" or "Companf) submits the following
responses to the Community Action Partnership Association of ldaho's First Production
Requests, dated February 23,2021.
DATED: March 10,2021.
SUEZ WATER IDAHO INC.
-O1
By:
Michael C. Creamer
Preston N. Carter
Attorneys for Applicant
SUEZ WATER'S RESPONSE TO CAPAI'S FIRST PRODUCTION REQUESTS - 1
1556981 8_1.DOCX [3G209]
CERTIFICATE OF SERVICE
I certify that on March 10,2021, a true and correct copy of the foregoing was
served upon a!! parties of record in this proceeding via electronic mail as indicated
below:
Commission Staff
Jan Noriyuki, Commission Secretary Electronic Mail
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, lD 83714
[e-mail]
Dayn Hardie Electronic Mail
Matt Hunter
Deputy Attomey General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, lD 83714
[e-mail]
matt. h unter@puc. idaho.qov
Intervening Parties
Ada County:
Lorna K. Jorgensen
John C. Cortabitarte
Ada County Prosecuting Attorney's Office
Civi! Division
200 W. Front Street, Room 3191
Boise, lD 83702
liorqen sen@adacou ntv. id.oov
ico rta b ita rte@ad acou ntv. id .qov
CAPAI:
Brad M. Purdy
2019 N. 17th Street
Boise, lD 83702
[e-mail]
lnteruenors:
Marty Durand
Piotwrowski Durand PLLC
1020 Main Street, Suite 440
P.O. Box 2864
Boise, lD 83701
[e-mail]
Electronic Mail
Boise City:
Mary Grant
Scott B. Muir
Boise City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, lD 83701-0500
boi secitvatto rnev@ citvofbo i se. o rq
mqrant@cityof boise.orq
Suez Water Customer Group:
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main Street, Suite 1300
Boise, lD 83702
NSemanko@pa rsonsbehle.com
BoisedockettO rson sbehle.com
I ntermou ntain Fair Housing
Council, lnc.
Ken Nagy
Attorney at Law
P.O. Box 164
Lewiston, lD 83501
[e-mail]
SUEZWATER'S RESPONSE TO CAPA!'S FIRST PRODUCTION REQUESTS.2
1 ss6981 8_1.DOCX [30-209]
lntermountain Fair Housing Council, lnc.
Zoe Ann Olson, Executive Director
4696 W. Overland Rd., Suite 140
Boise, lD 83705
[e-mail]
Jim Swier
Greg Harwood
Micron Technology, lnc.
8000 S. FederalWay
[e-mail]
[e-mail]
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart
555 17th St., Suite 3200
d aruesch hoff@ hol la nd ha rt. com
tnelson@ hollandhart.com
aclee@holla nd ha rt.com
g lqa rqa noa ma ri@ ho! la nd ha rt. com
L*4.-^,"
Preston N. Carter
SUEZ WATER'S RESPONSE TO CAPAI'S FIRST PRODUCTION REQUESTS.3
1 s56981 8_1.DOCX [3e209]
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 1:
Does SUEZ attempt to identify and quantify which of its customers are low-income?
RESPONSE NO. 1:
SUEZ does not attempt to identify and quantify which of its customers are low income.
When a customer contacts the company experiencing financia! difficulties, the customer
service representative will refer the customer to available resources provided by the
Company and by our community partners, including the SUEZ Cares program for low
income assistance administered by El-Ada Community Action Partnership (El-Ada).
Customers who have qualified with EI-Ada for financial assistance will receive a specific
adjustment credit, SUEZ Cares (formerly United Cares) applied by SUEZ on their water
account.
suz-w-20-02
CAPAI REQUEST NO. 1
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CApAl)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO , lNc.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 2:
lf your answer to the foregoing request is in the affirmative, please state the number of
SUEZ's low-income customers for each of the past five (5) years.
RESPONSE NO.2:
SUEZ does not identify which customers are low income.
suz-w-20-02
CAPAI REQUEST NO. 2
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 3:
lf your answer to the foregoing is in the affirmative, please specify the method and criteria
utilized to determine whether a given customer qualifies as low-income.
RESPONSE NO.3:
SUEZ does not identify which customers are low income
suz-w-20-02
CAPAI REQUEST NO. 3
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO.4:
If SUEZ qualifies and quantifies the number of low-income customers it serves, please
provide the following:
A. The method/criteria utilized by the Company to determine whether a customer or
household is low-income.
B. The specific information obtained about a customer to determine if they are low-
income.
C. The number of low-income customers that SUEZ has served during each of the
past five (5) years.
RESPONSE NO.4:
SUEZ does not identiff which customers are low income.
suz-w-20-02
CAPAI REQUEST NO.4
Page 1 of 1
SUEZ WATER IDAHO INC.
CASE SUZ-W-20-02
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 5:
In what year was SUEZ Water Cares first created and made available to low-income
customers?
RESPONSE NO. 5:
The ldaho SUEZ Cares Iow income assistance program (formerly United Cares) began
in 2005 with the first credits applied to customer accounts in September 2005.
suz-w-20-02
CAPAI REQUEST NO. 5
Page 1 of 1
reparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 6:
Since the date that SUEZ acquired United Water and the Company transitioned from
"United Water Cares," to SUEZ Water Cares, did SUEZ make any atterations or program
changes to United Water Cares and the total funding amount since the acquisition?
RESPONSE NO. 6:
No changes were made to the low income customer assistance program as a result of
the Company changing its name from United Water to SUEZ and the program name
changing from United Water Cares to SUEZ Cares.
The only changes that have taken place since inception of the program in 2005 were
raising the dollar amount threshold customers could qualify for in assistance and the
removal of the matching "cap" which was initially set at $2O,OO0 annually which changed
in 2011. No voluntary funding provided by customers have contributed to the program
since 2A20.
Originally as noted in Order 29838 in case UWI-W-04-4 the assistance amount was set
to $50. ln 2011 the amount was increased to $65 per UWI-W-11-02 Setflement. lt was
raised to $75 in 2016 in UWI-W-15-01 Settlement and would continue to increase by any
subsequent general rate proceeding percentage change awarded. ln 2018 as result of
the Tax Cuts Job Act which reduced income tax rates, the tariff rates charged to
customers were reduced, however the Company did not reduce the $75 assistance
amount.
suz-w-20-02
CAPAI REQUEST NO. 6
Page 1 of 1
P
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Gommunity Action Partnership Association of ldaho (CAPA!)
FIRST SET OF PRODUCTION REQUESTS TO SU EZ WATER IDAHO, INC.
SUEZ WATER IDAHO !NC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 7:
Please provide the annual number of customers, annually, who have received assistance
through SUEZ Water Cares for the past five (5) years.
RESPONSE NO. 7:
Year
Number of
customers receiving
SUEZ Cares
financial assistance:
2016
2017
2018
2019
2020
332
267
203
178
232
suz-w-20-02
CAPAI REQUEST NO. 7
Page 1 of 1
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 8:
Please provide a descriptive of the Company's "SUEZ Water Cares" program including
how the initial request for assistance is made by a customer (and whether the Company
takes and processes applications or refers out) through the determination of whether said
customer is eligible for assistance (including criteria for eligibility, €.g., customer must be
more than one month delinquent on their bill) through the process by which customers
actually receive assistance. By this request, CAPAI is seeking clarification regarding all
of the rules, policies and protocol for assistance under SUEZ Water Cares, including the
total amount a customer is granted and whether that is in a one-time offering.
RESPONSE NO. 8:
When a customer contacts the Company experiencing financial hardship, the customer
service agent will refer the customer to available resources provided by the Company and
by our community partners. This includes information about the SUEZ Cares program
and how to apply through El-Ada Community Action Partnership (El-Ada), conservation
advice, budget billing (level-pay) option and payment plan arrangements.
El-Ada CommunityAction Partnership administers the SUEZ Cares program, accepts and
processes applications for assistance, determines eligibility, and informs the Company
when a customer qualifies for financial assistance based on their programs' and federal
government poverty guidelines. The guidelines for eligibility are defined by El-Ada
regarding income leveland the applicant has to be considered late on a utility billor have
a past due balance on their account to qualify. An application and eligibility determination
must be completed with El-Ada for each one-time financial assistance award.
Customers are eligible to receive one SUEZ Cares financial assistance award per year
funded entirely by SUEZ shareholders. After receiving notification of customer eligibility
suz-w-20-02
CAPAI REQUEST NO. 8
Page 1 ol2
SUEZ WATER IDAHO INC.
CASE SUZ-W-20-02
Gommunity Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
from El-Ada, SUEZ verifies that the customer has not received SUEZ Cares financial
assistance during the last twelve months. The amount of financial assistance provided is
up to $75 based on the amount that is due on the customer's account.
Currently there is no established funding cap nor a limit on number of customers that may
receive financial assistance through the SUEZ Cares program for a given year.
suz-w-20-02
CAPAI REQUEST NO. 8
Page 2 o12
SUEZ WATER IDAHO !NC.
GASE SUZ-W-2042
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 9:
Please state what a customer who receives assistance through SUEZ Water Cares is
given; e.9., is it a onetime credit or a monthly reduction of the customer's bills and what
is the total amount of the credit?
RESPONSE NO.9:
A customer who is qualified and approved by E!-Ada Community Action Partnership for
SUEZ Cares program low income financialassistance, would receive up to a $75 one-
time credit on their account. Customers may reapply and receive assistance once every
12 months.
suz-w-20-02
CAPAI REQUEST NO. 9
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 10:
What is the average bill per month of all SUEZ's low-income customers and those who
receive assistance through SUEZ Cares?
RESPONSE NO. 10:
SUEZ does not designate customers a Iow-income. SUEZ Cares program recipient
average bil! data is not readily available. An average monthly bill for Residential
customers is $30.66. This includes pass-through costs such as Idaho Department of
Water Quality Safe Drinking Water fees and City franchise taxes.
suz-w-20-02
CAPAI REQUEST NO. 10
Page 1 of 1
SUEZ WATER IDAHO INC.
GASE SUZ-W-20-02
Gommunity Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 1 1:
Do customer applications for assistance through SUEZ Water Cares exceed total number
of actual recipients in any given years? !f so, please state the differential for each of the
past five (5) years.
RESPONSE NO.11:
El-Ada Community Action Partnership does not maintain records of customers who apply
for SUEZ financialassistance but do not meet El-Ada's eligibility guidelines.
Customers who qualified through El-Ada Community Action Partnership for financial
assistance and have not received SUEZ Cares assistance within the last 12 months are
eligible to receive SUEZ Cares financialassistance.
suz-w-20-02
CAPAI REQUEST NO. 1 1
Page 1 of 1
SUEZ WATER IDAHO INC.
CASE SUZ.W.2O.O2
Community Action Partnership Association of ldaho (CAPA!)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, !NC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 12:
PIease state the total amount of available funding of the SUEZ Water Cares program,
annually, and the number of customers who received assistance through the program for
each of the past five (5) years.
RESPONSE NO. 12:
The $20,000 cap that was established in 2005 as part of the original design of the
program has not been enforced and the Company has not Iimited the financial
assistance it provides to date.
SUEZ Cares program provided customer financial assistance
Funds
Year Customers Provided:
2016
2017
2018
2019
2020
332
267
203
178
232
$22,444
$17,443
$13,951
$12,618
$16,268
suz-w-20-02
CAPAI REQUEST NO. 12
Page 1 of 1
SUEZ WATER IDAHO !NC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CApAl)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHo, lNc.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 13:
Please provide a calculation and break-out on an annual basis for internat costs of
implementing/administering the SUEZ Water Cares program?
RESPONSE NO. 13:
PIease see the attachment to this response
When a customer calls, some time may be spent discussing the customers' needs as
related to the payment of their bill which may include SUEZ Water Cares. The Company
does not separately track this time as it is a part of the overall customer service. When
customers receive assistance from SUEZ Cares through El Ada, some time is spent in
reviewing the information and applying such funding to the customers' accounts.
Additionally, there is some supervisor review. Based upon rough estimates, the time cost
we estimate to be about $10k per year. ln addition to these costs, there are program
administration fees of $2k per year and SUEZ funded financiat assistance (which is not
included for rate recovery) of approximately 920k.
suz-w-20-02
CAPAI REQUEST NO. 13
Page 1 of 1
Annual estimated cost of implementing and administering SUEZ Cares program
Hourc Averageper hourly
week Employees rate
Annual
Estimated
Cost Total
Customer Service Representatives discuss SUEZ Cares low income
assitance program with customers
Review information from El-Ada, apply credit to account
Supervisor review and approval
1
1
0.5
10 $ 16.80 $1 $ 17.80 $
1 $ 41.00 $
8,736
926
1,066
lnternal costs $ 10,728
El-Ada Community Action Partnership program administration fee $2,000
External costs $ 2'000
$ 20,000
$ 20'000
$ 32,728
SUEZ funded financial assistance provided to customers (not included for recovery in rates)
Tota! annual cost of SUEZ Cares program, including financial assiaatance provided by SUEZ
suz-w-20-02
CAPAI REQUEST NO. 13
Attachment
1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-2042
Community Action Partnership Association of ldaho (CApAl)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO,lNc.
Preparer/Sponsoring Witness: Jarmila Cary
CAPA! REQUEST NO. 14:
How many customers have received assistance through SUEZ Water Cares for every
year since program implementation?
RESPONSE NO.14:
Customers receiving SUEZ Cares
financial assistanceYear
2005 (Sept-Dec)
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021 (through Feb)
42
117
152
284
412
460
311
434
316
273
171
332
267
203
178
232
34
suz-w-20-02
CAPAI REQUEST NO. 14
Page 1 of 1
Community
SUEZ WATER IDAHO INC.
CASE SUZ-W.20.02
Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUEST S TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 15:
Without revealing customer identities or other confidential information, please provide a
chart showing the average monthly consumption of all customers receiving assistance
through the SUEZ Water Cares program for all years since implementation of the
program.
RESPONSE NO.15:
Average monthly consumption specifically for SUEZ Cares program recipients is not
readily available. Please find average residential customer usage below'
Year
Average monthly
consumption reflected in ccf
(100 cubic feet)
2005 14.74
2006 15.10
2007 15.51
2008 14.51
2009 13.72
2010 13.00
2011 12.80
2012 13.68
2013 13.66
2014 13.28
2015 13.01
2016 12.84
2017 12.04
2018 12.39
2019 11.53
2020 12.02
suz-w-20-02
CAPAI REQUEST NO. 15
Page 1 of 1
SUEZ WATER IDAHO INC.
CASE SUZ-W-20-02
Community Action Partnership Association of ldaho (CApAl)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO , lNc.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 16:
Does the Company deduct its costs of implementing the program from the total SUEZ
Water Cares annual funding amount; i.e., what is the net amount of funding available to
low-income customers annually for the Program?
RESPONSE NO. 16:
No, the Company does not deduct costs of implementing or administering the SUEZ
Cares program from the funds made available by SUEZ for assisting low-income
customers. Also, since 2010, the Company does not include costs for specific customer
outreach to provide customers information on how to voluntarily donate to the program.
Funding available for the SUEZ Cares program is not reduced by any cost. The $20,000
cap that was established in 2005 as part of the original design of the program has not
been enforced and the Company has not limited the financial assistance it provides to
date.
suz-w-20-02
CAPAI REQUEST NO. 16
Page 1 of 1
SUEZ WATER IDAHO INC.
GASE SUZ-W-20-02
Gommunity Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 17:
Aside from the SUEZ Water Cares program, does the Company offer any other form of
assistance to its lOw-income customers, 9.9., payment assistance programs, etc.?
RESPONSE NO. 17:
Whenever any customer contacts the Company regarding experiencing financial
hardship, a customer service agent will refer them to resources provided by the Company
and in the community. This includes information about the SUEZ Cares program, El-Ada
Community Action Partnership, conservation advice, the budget billing option (level-pay
plan), and payment plan arrangements, including extended 12 month payment plans.
Any customers who experiences a Ieak in their home or lawn irrigation plumbing may also
be eligible to qualify for a leak adjustment credit, if their consumption is markedly higher
than their average usage for the respective billing period as compared to history. The
customers must provide required documentation to the Company including receipts for
leak repairs.
suz-w-20-02
CAPAI REQUEST NO. 17
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 18:
PIease provide a calculation and break-out on an annual basis for internal costs of
implementing/administering the SUEZ Water Cares program?
RESPONSE NO. 18:
PIease see response to Request No. 13 for a calculation of SUEZ Cares intemal
program implementation and administration costs.
suz-w-20-02
CAPAI REQUEST NO. 18
Page 1 of 1
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO.19:
Has the Company conducted, or is in possession or aware of any studies purporting to
identify what types of residential water usage is non-discretionary (e.9., flushing toilets,
drinking water, etc.) and what constitutes an average non-discretionary "baseline"
average monthly consumption? !f so, please provide or provide a reference to such
studies.
RESPONSE NO. 19:
The Company does not have studies identifying types of non-discretionary water usage
or an average monthly baseline consumption number. Base Iine level of water
consumption can vary depending on a variety of factors including: the needs of and
number of the occupants in the home, whether they are home during the day or not,
appliance Energy Star ratings, capacity and age of appliances, type and age of fixtures
(shower vs. bath), etc.
ln Case No. UWI-W-044 Order No. 29838 and the Company and CAPAI's Stipulation
outlines what was established as "the amount of "minimum non-discretionary . . . use of
water at the Iowerwinter rate" referring to the 3ccf of water used during the summer period
that would be priced at the winter block rate, pages 31 through 32. The testimony of Teri
Ottens in that proceeding stated that (the Company) "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 purpose of this is to
provide the bare minimum, non-discretionary (i.e., "subsistence level) use of water at the
lower winter rate".
suz-w-20-02
CAPAI REQUEST NO. 19
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Gommunity Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 20:
How many SUEZ residential customers have been disconnected for non-payment
annually for each of the past five years? In responding to this, please break out !ow-
income customers from al! other residentia! customers.
RESPONSE NO. 20:
The Company does not identiff low-income customers.
Year Disconnections for Non-Payment
2016 1,666
2017 1,315
2018 921
2019 1,286
2020 174
suz,w-20-02
CAPAI REQUEST NO. 20
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20{2
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 21:
What has been the amount of uncollectible debt from residential customers that SUEZ
incurred during each of the past five years?
RESPONSE NO. 21:
The Company's bad debt expense (writeoffs) from customers classified as residential
are
2016
2017
2018
2019
2020
$156,480
$162,879
$197,798
$195,485
$176,395
suz-w-20-02
CAPAI REQUEST NO. 21
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CApAl)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, lNc.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 22:
What has been the amount of uncollectible debt, on an annual basis, aftributable to tow-
income customers for each of the past five years?
RESPONSE NO.22:
The Company does not identify Low lncome customers.
suz-w-20-02
CAPAI REQUEST NO. 22
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Gommunity Action Partnership Association of ldaho (GAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 23:
What has been the amount of uncollectible debt, on an annual basis, attributable to
residential customers who receive funding through SUEZ Water Cares for each of the
past five years?
RESPONSE NO. 23:
2016 $10,988
2017 $15,437
2018 $13,861
2019 $17,469
2020 $7,894
suz-w-20-02
CAPAI REQUEST NO. 23
Page 1 of 1
SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPA! REQUEST NO. 24:
Regardless of SUEZ Water Cares, how many low-income customers have been
disconnected for each of the past five years?
RESPONSE NO. 24:
The Company does not identify low income customers
suz-w-20-02
CAPA! REQUEST NO. 24
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SUEZ WATER IDAHO INC.
CASE SUZ.W.2O.O2
Community Action Partnership Association of ldaho (CAPAI)
FIRST SET OF PRODUCTION REQUESTS TO SUEZ WATER IDAHO, INC.
Preparer/Sponsoring Witness: Jarmila Cary
CAPAI REQUEST NO. 25:
With respect to the preceding Request, please provide the number of disconnections as
a percentage of total residential customers matching the same time period.
RESPONSE NO. 25:
The Company does not identiff Iow lncome customers.
2016
2017
2018
2019
2020
Total Disconnections*
1,666
1,315
921
1,286
174
Total Residential Customers
80,761
81,864
84,015
85,414
86,774
*Not net of reconnections. Please see the response to CAPAI Request No. 20.
suz-w-20-02
CAPAI REQUEST NO. 25
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