20091030Staff 33-79 to UWI.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 1 8
BARNO. 3283
Q r. r: ')1\ t_ \~.1 .
iOU9 OCT 30 PM 2: 21
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN THE STATE OF IDAHO.
)
) CASE NO. UWI-W-09-1
)
)
) THIRD PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) UNITED WATER IDAHO INC.
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that United Water Idaho (Company;
United Water; UWI) provide the following documents and information on or before
FRIDAY, NOVEMBER 20, 2009.
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 1 OCTOBER 30, 2009
This Production Request is to be considered as continuing, and United Water is requested
to provide, by way of supplementa 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
31.01.01.228.
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. 33: Please provide a copy of the explanation of rate schedules sent to
customers anually and to new customers. Please provide an explanation as to when it is sent.
(UCIR - Rule 101)
REQUEST NO. 34: Please provide a sample copy of a written denial of service letter
and deposit request letter, if the Company takes deposits, for each rate schedule or class of
customer if the documents vary. (UCRR - Rule 104)
REQUEST NO. 35: Please provide a sample copy of the initial receipt for the first
deposit installment. Provide a copy of the receipt for the second installment, if such receipt is
different from the first. (UCRR - Rule 109)
REQUEST NO. 36: Please provide a sample copy of a bil sent to customers with no
past due balance, for each rate schedule or class of customers if the documents var. (UCRR-
Rule 201)
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 2 OCTOBER 30, 2009
REQUEST NO. 37: Please provide a sample copy of a bil sent to customers with a past
due balance, for each rate schedule or class of customers if the documents vary. (UCRR - Rule
202)
REQUEST NO. 38: Please provide a sample copy of a bil sent to customers when the
Company was unable to read the meter, for each rate schedule or class of customers if the
documents vary. (UCRR - Rule 204)
REQUEST NO. 39: Please provide a sample copy of a bil sent to customers when the
Company prorates the commodity charge because of the change to summer/winter rates, for each
rate schedule or class of customers if the documents var. (UCRR - Rule 204)
REQUEST NO. 40: Please provide a sample copy of the notice used when transferring
amounts between customers when the lapse in service exceeds 60 days, for each rate schedule or
class of customers if the documents vary. (UCRR - Rule 206)
REQUEST NO. 41: Does the Company offer customers a pre-printed form for the
medical emergency certificate? If so, please provide a copy of the form. (UCRR - Rule 308)
REQUEST NO. 42: Please provide the record of customer complaints and requests for
conferences for calendar years 2006 through 2009 to date. (UCRR - Rule 403)
REQUEST NO. 43: Please provide a sample copy of the Rules Summary sent to
customers. How and when are customers given the sumary? (UCRR - Rule 701)
REQUEST NO. 44: Please provide a copy of the following Company documents: Initial
Notice to Terminate, Final Notice of Intent to Terminate Service (if sent), and the Notice of
Procedure for Reconnecting Service (door tag or notice if used), for each rate schedule or class
of customers if the documents vary. Please provide explanation of how the Company conducts
its termination process. (UCRR - Rule, 304, 305, 310, 311)
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 3 OCTOBER 30,2009
REQUEST NO. 45: Please provide a sample copy of any brochure or other printed
material regarding the Company's third pary notification program if the Company has such a
program. How and when is this material provided to customers? (UCRR - Rule 307)
REQUEST NO. 46: Please provide a sample copy of any brochure or other printed
material regarding the Company's Water Conservation program. How and when is this material
provided to customers? Are any of Company's brochures, notices, forms and/or bils available in
Spanish or other languages? If so, please indicate the language(s) and information available.
How are customers made aware that there are bils, forms, and brochures available in languages
other than English?
REQUEST NO. 47: Please explain the Company's meter reading procedure and
schedule for all customer rate schedules, residential, multi-residential and commercial customers.
Are all meters read monthly?
REQUEST NO. 48: Please explain the biling process and the calculation of commodity
charges when the Company has to bil accumulated charges due to previous estimated bilings or
missed readings.
REQUEST NO. 49: Please submit the results of time studies completed or cost data
available regarding the curent cost for meter reading on a monthly basis.
REQUEST NO. 50: Please provide information regarding the meter testing charge
including the number of tests performed over the past three years, number of meters found
defective, number of customers who have requested testing multiple times and the results of
those multiple tests.
REQUEST NO. 51: Please identify the number offield collections on a monthly basis
for each year from 2005 forward to date, identify the separate classes of customers and include
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 4 OCTOBER 30, 2009
whether those disconnections were completed during normal business hours or outside of normal
business hours.
REQUEST NO. 52: Please identify the number of disconnections for non-payment on a
monthly basis for each year from 2005 forward to date, identify the separate classes of customers
and include whether those disconnections were completed during normal business hours or
outside of normal business hours.
REQUEST NO. 53: Please explain the differences in charges for a reconnection charge
and the field collection charge or the temporary disconnection at customer request charge for
both normal business hours and other than normal business hours.
REQUEST NO. 54: Please describe how incoming calls from customers to the
Company are handled. Include in that explanation answers to the following questions: (a) Are
all calls handled by a centralized customer service call center, or are some types of calls (e.g.,
service outage or new construction) directed to a separate call center or deparment? (b) If some
types of calls are directed outside the customer service call center, are those calls separately
measured or tracked? (c) If some types of calls are handled through an interactive voice
response (IVR) system without the callng party speaking to a customer service representative,
are those calls separately measured or tracked?
REQUEST NO. 55: In his direct testimony, customer service witness Gregory P. Wyatt
stated that the Company had implemented an interactive voice response system in 2007 to assist
customers in paying their bils by phone. Please describe all types of calls the Company's IVR
system can handle and identify the implementation date for each type of call handled by the IVR
system. Please provide a call routing and choice selection chart or drawing for the system.
REQUEST NO. 56: Please provide the Company's performance objectives for handling
incoming calls, include objectives for both IVR and CSR handled calls. What steps does the
Company take if it fails to meet its performance objectives?
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 5 OCTOBER 30, 2009
REQUEST NO. 57: Please provide the service level for the customer service call center
by month for 2006,2007,2008 and 2009 to date. "Service level" is the percentage of calls
answered within a certain number of seconds, e.g., 80% of calls answered within 20 seconds.
Please differentiate between IVR and CSR calls.
REQUEST NO. 58: Please provide the number of incoming calls handled by the
customer service call center by month for the calendar years 2006, 2007, 2008 and 2009 to date.
Please differentiate between IVR and CSR calls.
REQUEST NO. 59: Please provide the number of abandoned calls to the customer
service call center by month for the calendar years 2006, 2007, 2008 and 2009 to date.
"Abandoned calls" are calls that reach the Company's incoming telephone system, but the callng
pary terminates the call before speaking with a customer service representative. Please
differentiate between IVR and CSR calls.
REQUEST NO. 60: Please provide the number of busy signals reached by paries
calling the customer service center by month for calendar year 2006, 2007, 2008 and 2009 to
date. Please differentiate between IVR and CSR calls.
REQUEST NO. 61: Please provide the average speed of answer for the customer
service call center by month for each of the past four years (2006, 2007, 2008 and 2009 to date).
"Average speed of answer" is the interval (typically measured in seconds) between when a call
reaches the Company's incoming telephone system and when the call is picked up by a customer
service representative. Please differentiate between IVR and CSR calls.
REQUEST NO. 62: In his direct testimony witness Gregory P. Wyatt identifies three
types of customer complaints: water quality, high bils and disconnection. Please explain how
the Company classifies an incoming call handled by the call center and provide monthly data for
each of the classifications of incoming calls for the years 2006, 2007,2008 and 2009 to date.
THIRD PRODUCTION REQUEST
TO UNITED W À TER IDAHO 6 OCTOBER 30, 2009
REQUEST NO. 63: Please describe how the Company handles e-mail inquiries,
complaints, payment arangements, service orders, and other routine customer transactions.
Please provide the average response time for e-mail transactions by month for the year 2006,
2007,2008 and 2009 to date. "Average response time" is the average number of hours from
receipt of an e-mail by the Company to sending a substantive response; auto-response
acknowledgements do not count as a substantive response.
REQUEST NO. 64: Please provide a written description of all changes to Company
governance and operations implemented in response to the Sarbanes-Oxley Act, the related SEC
rulings to implement it, and the Public Company Accounting Oversight Board (PCAOB) to date.
Please include within your response how and when those changes were implemented and any
costs associated with the changes. Also provide a schedule showing how the costs have been
allocated to UWI or any unit that includes those costs directly and/or indirectly when biling
costs to UWI. Please separate cost data by year and identify the amount by each account and
business unit in which those costs were posted.
REQUEST NO. 65: Please provide a contact name and phone number of the
individual(s) with which Idaho Public Utilties Commission Staff can discuss governance,
Sarbanes-Oxley and the previous response.
REQUEST NO. 66: Please provide a copy (or list identifying date of receipt and
providing a detailed description of topic) of any and all "Dear CFO" letters from the SEC
received by the parent company and any company!business unit during 2007, 2008 and 2009 to
date. Please consider this request as continuing and provide updates if any additional "Dear
CFO" letters are received.
REQUEST NO. 67: Please provide a copy (or list identifying date of receipt and
providing a detailed description of topic) of any and all Comment Letters from the SEC received
by the parent company and any company!business unit during 2007, 2008 and 2009 to date.
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 7 OCTOBER 30, 2009
Please consider this request as continuing and provide updates if any additional letters are
received.
REQUEST NO. 68: Please provide a copy (or list identifying date of receipt and
providing a detailed description of topic) of any and all written (both electronic and non-
electronic), substantive communications from the SEC received by the parent company and any
company/business unit during 2007, 2008 and 2009 to date.
REQUEST NO. 69: Please provide a written description of the process related to the
determination of compensation (executive and non-executive/union and non-union) levels for
United Water Idaho employees. Please include within your response the timeline (calendar
dates) associated with compensation studies, budgetar reviews, contract negotiations, and
eventual rates of pay authorized/negotiated for the years 2007, 2008 and 2009 to date.
REQUEST NO. 70: Please provide a written description of any planed changes to the
compensation process described in response to the preceding request.
REQUEST NO. 71: Please provide a copy of all compensation studies (internal or
external/formal or informal) used to determine compensation levels for 2007, 2008, and 2009 to
date. Please include within your response the date any compensation studies that are currently
underway or planed wil be completed and update the Company's response to this request with
a copy.
REQUEST NO. 72: Please provide a detailed written description of the Company's
capital expenditure process. Include a full description with at least the following: a) method to
establish total capital expenditure budget; b) prioritization and allocation of that budget to
specific and blanet projects; c) reassignment of budget allocations based upon project variances
(if one project is under budget is another project added to expend those unused dollars or the
opposite); d) methodology to determine which projects are high priority and which can be
deferred until the economic climate (or other factors) are improved; e) asset management
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 8 OCTOBER 30,2009
transactional process (how projects are entered into that system and ultimately closed to the
general ledger and by whom), and f) other items relevant to the process including a listing and
copy of all documents and reports required and maintained throughout the process.
REQUEST NO. 73: In reference to the more than $12 milion of investments the
Company has made since the last case to replace aging infrastructure identified in Greg Wyatt's
testimony (page 4, lines 9 and 10), please provide the following:
a. project number;
b. project description;
c. project's original budget;
d. project's final budget if different than response to item c;
e. project costs;
f. date project was closed to Plant in Service; and
g. date project considered in service if different than response to item f.
REQUEST NO. 74: Please provide detail regarding location, length, pipe size, whether
bid or not, and cost breakdown for the 16 miles of water mainline replacement referred to in
Greg Wyatt's testimony (page 4, lines 10 and 11) separated by calendar year to date.
REQUEST NO. 75: In reference to the $2 milion in treatment facilties improvements
at various locations in the system since the last general rate case identified in Greg Wyatt's
testimony (page 4, lines 3 and 4), please provide the following:
a. project number;
b. project description;
c. project's original budget;
d. project's final budget if different than response t9 item c;
e. project costs;
f. date project was closed to Plant in Service; and
g. date project considered in service if different than response to item f.
REQUEST NO. 76: In reference to the $ 1.4 milion in booster station improvements
since the last general rate case identified in Greg Wyatt's testimony (page 4, lines 12 and 13),
please provide the following:
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 9 OCTOBER 30, 2009
a. project number;
b. project description;
c. project's original budget;
d. project's final budget if different than response to item c;
e. project costs;
f. date project was closed to Plant in Service; and
g. date project considered in service if different than response to item f.
REQUEST NO. 77: In reference to the $0.7 milion in auxilar power generators at
various sites throughout the Company's water system identified in Greg Wyatt's testimony (page
4, lines 13 through 15), please provide the following:
a. project number;
b. project description;
c. project's original budget;
d. project's final budget if different than response to item c;
e. project costs;
f. date project was closed to Plant in Service; and
g. date project considered in service if different than response to item f.
REQUEST NO. 78: Please provide the Company's water quality testing schedule, how
it relates to DEQ's compliance requirements and a detailed report of water quality expenses for
the test year and the previous year that includes:
a. transaction amount;
b. date paid;
c. vendor paid;
d. testing performed; and
e. invoice/transaction number of payment.
REQUEST NO. 79: For the test year and the previous year, please provide all vehicle
allowance and expense records, monthly usage reports, anual mileage certification, logs, and
any or all records pertining to use of company cars as outlined in UWI's automobile usage
policy.
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 10 OCTOBER 30, 2009
Dated at Boise, Idaho, this~rJH day of October.
~)().~W)
Krist ne A. Sasser
Deputy Attorney General
Technical Staff: Chris Hecht/33-63
Patricia Hars/64-79
i:umisc:prodreqluwiw09. i wsks prod req 3.doc
THIRD PRODUCTION REQUEST
TO UNITED WATER IDAHO 11 OCTOBER 30, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30TH DAY OF OCTOBER 2009,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO UNITED WATER IDAHO INC., IN CASE NO.
UWI-W-09-1 BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
KEVIN H. DOHERTY
UNITED WATER IDAHO INC
200 OLD HOOK ROAD
HARRINGTON PARK, NJ 07640
E-MAIL: Kevin.doherty(ßunitedwater.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(ßmcdevitt-miler.com
BRAD M. PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(ßhotmail.com
Jodc2 d
SECRETARY (
CERTIFICATE OF SERVICE