HomeMy WebLinkAbout20091203UWI to Staff 97-103, 105-106.pdfMcDevitt & MillerLLP
(208) 343-7500
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December 3, 2009
Chas, F. McDevitt
Dean J. (Joe) Miler
Via Hand Delivery
Jean Jewell, Secreta
Idao Public Utities Commssion
472 W. Washigton St.
Boise, Idaho 83720
Re: Case No. UWI-W-09-01
General Rate Case Fili
Dear Ms. Jewell:
Enclosed for fig, please fid thee (3) copies of United Water Idaho's Thd Response to
Commssion Staffs Four Production Request Nos. 97, 98, 99, 100, 101, 102, 103, 105, and 106.
Kidly retu a fie staped copy to me.
Very Truy Yours,
McDevitt & Mier UP~~
Dean J. Mier
DJM/hh
EncL.
O ""," l N A Lk LJi¡ ..'
Dean J. Miler (ISB No. 1968)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, Idaho 83702
Tel: 208-343-7500
Fax: 208-336-6912
joe(imcdevitt -miler. com
it"',REC l¡1". .J
2869 DEC -3 PM 3= 56
Attorneys for United Water Idaho Inc.
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 FOR WATER SERVICE IN THE )STATE OF IDAHO )
)
CASE NO. UWI-W-09-01
UNITED WATER IDAHO INC'S
THIRD RESPONSE TO
COMMISSION STAFF'S FOURTH
PRODUCTION REQUEST
United Water Idaho Inc, eUnited Water") by and though its undersigned attorneys,
hereby submits its Third Response to the Commission Staffs Fourh Production Request Nos.
97,98,99, 100, 101, 102, 103, 105, and 106.
DATED this ~day of December, 2009.
UNITED WATER IDAHO INC.
BY~~,
Dean J. Miller
McDevitt & Miler LLP
420 West Banock
Boise, Idaho 83702
P: 208.343.7500
F: 208.336.6912
Attorney for United Water
UNITED WATER IDAHO INC'S THIR RESPONSE TO COMMISSION STAFF'S FOURTH
PRODUCTION REQUEST- 1
CERTIFICATE OF SERVICE
I hereby certify that on the ~day of December, 2009, I caused to be served, via the
method(s) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
j jewell(ipuc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
bmpurdy(ihotmail.com
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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UNITED WATER IDAHO INC'S THIR RESPONSE TO COMMISSION STAFF'S FOURTH
PRODUCTION REQUEST- 2
UNITED WATER IDAHO INC.
CASE UW-W-09-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Lyne Allaker
Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 97:
Please provide a list of all customer information transferred between affiliates and UWI from
2007, 2008 and 2009 to date. Please include within your response the pricing basis and related
documentation for all transfers, purchases, and sales.
RESPONSE NO. 97:
All entities that United Water Idaho has shared customer information with are discussed in the
responses to Staff Requests 100 and 101.
UNITED WATER IDAHO INC.
CASE UW-W-09-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Lyne Allaker
Sponsonng Witness: Gregory P. Wyatt
REQUEST NO. 98:
Please provide a detailed descnption of all activities between any company and/or business unt
identified in the organization char(s) provided and United Water Idaho's customer base whether
as a whole or in par.
RESPONSE NO. 98:
All entities that United Water Idaho has shared customer information with are discussed in the
responses to Staff Requests 100 and 101.
UNITED WATER IDAHO INC.
CASE UW-W-09-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Lynne Allaker
Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 99:
Please provide a detailed description of all activities by the Company to protect its customers'
information including addresses and ban account (or other) payment information.
RESPONSE NO. 99:
No customer information is shared with exteral entities, for any reason, without non-disclosure
and confidentiality agreements being signed. United Water corporately has strct interal controls
established, in line with Sarbanes Oxley requirements, for the interal management of customer
data. These requirements are monitored by an Internal Audit team as well as exteral auditors on
a periodic basis. United Water also implemented a Red Flag Compliance Program in 2009 in
line with new requirements issued by The Federal Trade Commission (FTC), the federal ban
regulatory agencies, and the National Credit Union Administration (NCUA). These regulations
(the Red Flags Rules) required United Water to implement a wrtten identity theft prevention
program, as part of the Fair and Accurate Credit Transactions (FACT) Act of2003.
United Water has contracts with several external vendors to process customer payments
including Mellon Ban and Western Union. Each organization providing these services abides
by all regulations regarding payment processing and customer data protection, including Red
Flag compliance requirements. United Water, through Western Union, is fully compliant with
NACHA rules and regulations.
~
y
UNITED WATER IDAHO INC.
CASE UW-W-09-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Lyne Allaker
Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 100:
Please provide a detailed description of the circumstances under which the Company would
provide customer information in any form to other companies. Please include within your
response the pricing parameters associated with each scenaro.
RESPONSE NO. 100:
Detailed descriptions are included below of circumstances where United Water has provided
customer data to external companies:
Customer Satisfaction Survey
Each year United Water conducts a satisfaction and feedback survey with a percentage of
residential customers. This surey is completed by a company called Global Strategy Group. A
non-disclosure and confidentiality agreement is established with the company ensuring that the
data provided can only be used for the puroses of the surey and cannot be shared with any
other paries. The sureys are conducted by telephone and Global Strategy Group is sent a file
including the name, address and telephone number of all residential customers. 243 sureys are
conducted in United Water Idaho. There is no pricing related to the actual customer data,
however Global Strategy Group is paid for completing the surveys and collating the results.
Conservation Survey
In 2009 United Water conducted conservation sureys with residential customers. The sureys
were completed in conjunction with Pleasant Valley Analytics Inc. and Pencilbrook LLC
consulting. Non-disclosure and confidentiality agreements were established with both
companies ensurng that data provided could only be used for the purposes of the surey and
associated analysis and could not be shared with any other paries. The sureys were conducted
by mail and asked questions regarding water use in the home and also outside water use.
Participants received a personalized report comparing their household water use with national
and local norms. The report included household specific recommendations on how to reduce
water and energy spending. Data shared included a selection of residential accounts that met
specified criteria. Details in the provided fie included name, address, telephone number and
water consumption for two years. There was no pricing related to the actual customer data
however the companies were paid for the work involved. This project was fully funded by R&I
Alliance which is a research fud available to paricipating Suez Environnement companies.
,
There was no direct cost to United Water Idaho. The survey was sent to 9,000 United Water
Idaho customers between Januar and March 2009, and 1,679 customers responded.
Automated Outbound Collection Calls
In 2009 United Water Idaho conducted a tral of automated outbound collection calls. The trial
has been conducted with a company called Televox. A non-disclosure and confidentially
agreement was established ensurng that data provided could only be used for the purose
specified by United Water Idaho and could not be shared with any other paries. Data provided
included details of customers pending shut-off for non-payment. Accounts were pre-selected by
United Water Idaho and a file sent though to Televox. The file included name, address,
telephone number and amount outstanding for collection. There was no pricing related to the
actual customer data and United Water negotiated a free trial period with Televox for the
purose of assessing the service. There was therefore no direct cost to United Water Idaho.
eBilg Enrollment
In 2008 United Water conducted an email marketing campaign to invite customers to sign up for
the new eBiling service. The campaign was conducted in conjunction with United Water's
eBiling vendors, Strata and FreshAddress Inc. The latter is a company which specializes in
helping businesses to build, clean and update customer email addresses. A non-disclosure and
confidentially agreement was established ensuring that data provided could only be used for the
purose specified by United Water and could not be shared with any other paries. Data shared
included a file with names, addresses and account numbers. FreshAddress Inc. then matched
those data with public records of email addresses available in order to conduct an email
promotional campaign regarding eBiling. There was no pricing related to the actual customer
data and United Water negotiated this work as a free trial for the purose of assessing the
service. There was therefore no cost to United Water Idaho.
Home Service
United Water has an affinity marketing agreement in place with Home Service. The natue of
this agreement permits Home Service to send marketing literatue to customers of United Water,
including United Water Idaho, regarding agreed services e.g. water service line protection
program. United Water retains full control over the services offered and full editorial rights over
the literatue sent to customers. On a periodic basis, United Water sends a list of residential
customers to Home Service including names, mailing addresses and account numbers. This
ensures that mailings are correctly addressed. The contract in place with Home Service includes
strct verbiage regarding the restrctions on use of United Water's customer data. The data can
only be used for the purposes outlined in the agreement and canot be shared with any other
paries. There is no pricing related to the provision of customer data and no costs with these
services for United Water Idaho as the program is administered and facilitated by the United
Water Corporate team. United Water receives a percentage based commission for each service
signed up for by customers.
eBilg Services
United Water introduced electronic eBiling services in 2009. The vendor chosen to provide
these services is called Strata in parnership with Western Union and they were selected
following a Request for Proposal. Data is transferred to Striata as required to issue the eBil to
t
enrolled customers. There is no pricing related to the provision of customer data and non-
disclosure and confidentiality agreements are included in the contract for services.
Sewer Authorities
United Water Idaho is required by its' Franchise Agreement to provide the City of Boise with
customer consumption data annually. The sewer authorities use this data to bil for sewer service.
United Water Idaho provides this data at no charge to the City as required by the Franchise
Agreement.
UNITED WATER IDAHO INC.
CASE UW-W-09-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Lyne Allaker
Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 101:
Please provide a detailed description of all such circumstances under which any customer
information was provided to another company beginning with Home Serice to date. Please
include within your response the name of the company, its relationship to UWI, the type of
customer information provided, the date such information was provided (if the information is
provided or updated anually, please include that within your response), the price charged for
such data, if any, and the method used to calculate the price charged (if there is no charge, please
so state and indicate in detail the underlying reason).
RESPONSE NO. 101:
Detailed descriptions are included below of circumstances where we have provided customer
data to external companies. We have never sold customer data to any external company.
Home Service
United Water has an affnity marketing agreement in place with Home Serice. The natue of
this agreement permits Home Service to send marketing literature to customers of United Water
regarding agreed services e.g. water service line protection program. United Water retains full
control over the services offered and full editorial rights over the literatue sent to customers.
United Water sends a list of residential customers to Home Serice including names, mailing
addresses and account numbers every 3 to 6 months. This ensures that mailngs are correctly
addressed. The contract in place with Home Service includes strict verbiage regarding the
restrctions on use of United Water's customer data. The data can only be used for the puroses
outlined in the agreement and canot be shared with any other parties. There is no charge for the
data provision and no costs associated with these services for UWI as the program is
administered and facilitated by the United Water Corporate team. The reason there is no charge
for the data provision is that the sole purose is to ensure that mailings are addressed to the
correct customer of record. The services provided by Home Service could continue without the
provision of customer data.
Customer Satisfaction Survey
Each year United Water conducts a satisfaction and feedback surey with a percentage of
residential customers. This survey is completed by a company called Global Strategy Group. A
v
non-disclosure and confidentiality agreement is established with the cpmpany ensuring that the
data provided can only be used for the purposes of the surey and Caiot be shared with any
other parties. The surveys are conducted by telephone and Global Strategy Group is sent a fie
including the name, address and telephone number of all residential customers. 243 sureys are
conducted in UWI. There is no charge for the provision of data as Global Strategy Group is
using the customer data to provide a specific service for United Water. Data is sent to Global
Strategy Group in October each year and the surey is conducted in November.
Conservation Survey
In 2008 and 2009, United Water worked with a company to conduct conservation sureys with
residential customers. This survey was completed in conjunction with Pleasant Valley Analytics
Inc. and Pencilbrook LLC consulting. Non-disclosure and confidentiality agreements were
established with both companies ensurng that data provided could only be used for the puroses
of the surey and associated analysis and could not be shared with any other paries. The
sureys were conducted by mail and asked questions regarding water use in the home and also
outside water use. Paricipants received a personalized report comparng the household water
use with national and local norms. The report included household specific recommendations on
how to reduce water and energy spending. Data shared included a selection of residential
accounts that met specified criteria. Details in the provided fie included name, address,
telephone number and water consumption for two years. There is no charge for the provision of
data as it is used to provide a specific service for United Water. This project was fully fuded by
R&I Allance which is a research fud available to paricipating Suez Environnement companes.
There was no cost to UWI. The survey was sent to 9,000 UWI customers between Januar and
March 2009 and 1,679 customers paricipated. Data was sent at the beginning of 2009 and
refreshed data wil be sent again at the beginning of2010 in preparation for follow-up surveys to
the original paricipants.
Automated Outbound Collection Calls
In 2009 we have conducted a tral of automated outbound collection calls in UWI. The trial has
been conducted with a company called Televox. A non-disclosure and confidentially agreement
was established ensuring that data provided could only be used for the purose specified by UWI
and could not be shared with any other paries. Data shared included details of customers
pending shut-off for non-payment. Accounts were pre-selected by UWI and a file sent through
to Televox. The file included name, address, telephone number and amount outstanding for
collection. There is no charge for the provision of data as Televox are using the customer data to
provide a specific service for United Water. Daily is sent on a daily basis, Monday though
Thursday.
eBiling Enrollment
In 2008 we conducted an email marketing campaign to invite customers to sign up for our new
eBiling service. The campaign was conducted in conjunction with our eBiling vendor, Strata
and FreshAddress Inc. The latter is a company which specializes in helping businesses to build,
clean and update customer email addresses. A non-disclosure and confidentially agreement was
established ensuring that data provided could only be used for the purpose specified by United
Water and could not be shared with any other paries. Data shared included a file with names,
addresses and account numbers. FreshAddress then matched our data with public records of
email addresses available in order for us to conduct an email promotional campaign regarding
eBiling. There is no charge for the provision of data as FreshAddress Inc. are using the
customer data to provide a specific service for United Water. This was a one-off exercise in
which data was sent to FreshAddress in 2008.
eBilg Services
United Water introduced electronic eBiling services in 2009. The vendor chosen to provide
these services is called Strata in parnership with Western Union and they were selected
following a Request for Proposal. Data is transferred to Strata as required to issue the eBil to
enrolled customers. There is no charge for the provision of data as Striata are using the customer
data to provide a specific service for United Water.
Sewer authorities
United Water Idaho provides customer consumption data anually to the City of Boise and
several sewer distrcts. This information is provided to the sewer billng entities as outlined in
the franchise agreement. The consumption data is provided at no charge in April each year.
UNITED WATER IDAHO INC.
CASE UW-W-09-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Lyne Allaker
Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 102:
Please identify how Suez, Home Service and United Water clearly and expressly communicate in
each and every mailing to United Water Idaho customers that the service being offered and
company providing it is not the customer's regulated utility. Please include in your response an
example of each mailing from Home Service to any United Water Idaho customer and circle the
statements clearly and explicitly communicating that information.
RESPONSE NO. 102:
There are two basic types of mailings sent to United Water customers as a result of our
parnership with Home Service. The first mailing introduces the customer to the water service
line protection product which is called LeakGuard. Three examples of this type of mailing are
included below and specific elements of the mailings are highlighted which we believe support
the fact that the service is not offered by the regulated utility.
If a customer signs up for LeakGuard, then they may receive mailings relating to additional
product offerings from Home Service. Two examples of these additional mailings are included
below also. These are referred to as cross-sell mailings. Cross-sell mailings are all dual branded
as the customer is an existing customer of both United Water and Home Service. United Water
retains full control over which services are offered and also retain full editorial rights over all
information sent to customers.
Ultimately, the regulated utility business is not referenced in any mailings at any time.
Following feedback and/or questions from customers, United Water regularly reviews the style
and content of mailings sent to customers. An example of this is also highlighted on one of the
mailings included below showing some new wording which wil be included in all mailings from
Januar 2010.
The examples include below do not include actual customer data but are the proofs that we sign-
off on. Any statements included inside double arows e.g. -:-: :;:; are personalized to each
regulated utility at time of printing by Home Service (if applicable to that business unit).
United Water is registered as a pseudo customer in each of our regulated terrtories. This means
that we receive copies of all mailings through the post also so we can complete a quality
assurance check on the finished marketing literature we approved. These are all sent to our
Corporate Customer Service team that administers the Home Service parership. Some
mailings reference www.unitedwater.com for more information about Home Service and for
money-saving offers. For customers following this direction the following information is
included in our website:
Who is Home Servce?
Home Service is the premiere provider of managed home emergency repair programs. United Water have partnered with
Home Service to offer residential customers a range of products designed to provide peace of mind and fast, effective help
when an emergency occurs around the home.
The services offered are not part of United Water's regulated business and are not funded in any way by the water rates that
our customers pay.
Over 100,000 United Water customers have already benefited from our partnership with Home Service, covering their home
against emergencies that can happen every day.
To learn about Home Service, visit their website at Home Service.
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What would you do in a water servce line emergency?1I ~ Il _ltwa !l hl u..)( rtUØ as a!Ø,J! Il an 19 tm lI cm pøon_hØIlnuatøS8 ~YQ~Ø'Qlwi!l1l ~~ "~CØ1I.. $I Jl. rI I* Of mm tI" II _.. Of;n ~ !I1S'- 24 \' ii (I.. a yuø )Q
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CAll TOll-fREE 1-888-666-7712 to protect your home!
Mon-Fri 8 a.m.- 8 p.m. Sat 10 a.m.- 4 p.m. EST
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EXAMPLE 3 (PAGE 1) - WATER SERVICE LINE PROTECTION MAILING-I
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EXAPLE 3 (PAGE 2) - WATER SERVICE LINE PROTECTION MAILING
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EXAMPLE 1 (PAGE 1) - CROSS-SELL MAILING (JOINTLY BRADED)
~ UNITED WATER
Ho5e
IS to:
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New wording added to
all mailngs from
January 2010 - "Home
Service is an
independent entity not
affliated with you
water company United
Water Idaho and
participation in Home
Service's protection
program is optional".
Five Spe(iai Bpiidits of Interior Pluiibm~ dnd Dldillilq,"
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EXAPLE 1 (PAGE 2) - CROSS-SELL MAILING (JOINTLY BRADED)
What would you do in an interior plumbing and drainage emergency?
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A Crisis Avoided In 3 simple steps!
You su noce wa dnppng ovd frm a bu water pipe ìn th celìng
1. !Aour Hep
No ne to sech fo
soeo to rer it - juscaR th 241 Er5e l-m
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EXAMPLE 2 (PAGE 1) - CROSS-SELL MAILING (JOINTLY BRADED)
o Cii ii fO lOprl '! pI ilfl r""'' to _1S LiPI ... fo íJst " ,00 IE
moli ~ Il $1200 IEyeJ.lleM~""""1:1""-,,~50,.
EXAMPLE 2 (PAGE 2) - CROSS-SELL MAILING (JOINTLY BRADED)
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UNITED WATER IDAHO INC.
CASE UW-W-09-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Lyne Allaker
Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 103:
Please descrbe in detail how United Water Idaho customers were identified to receive mailings
from Home Serice. Please include within your response whether a customer had to expressly
opt in or opt out of mailings from related companies, an example of each of the mailngs
including those options and the dates when United Water Idaho customers were identified for
Home Service mailings.
RESPONSE NO. 103:
All residential customers in United Water Idaho's service terrtory are eligible to sign up for
services provided by Home Service. A customer can request that mailings are stopped at any
time by contacting either Home Service or United Water Idaho. The customers' details are then
immediately suppressed from all futue mailngs by Home Service. The curent mailings do not
include any details relating to "opt in" or "opt out" options and therefore no examples are
included.
United Water has been in parnership with Home Service since 2005 and this is when mailings to
United Water Idaho customers began.
UNITED WATER IDAHO INC.
CASE UW-W-09-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Lyne Allaker
Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 105:
Please identify the timeline of the current contractual relationship with UBS - when the contract
was negotiated, the costs for other arangements at the time, and any evaluation/preparation for
contract adjustments given the past and current economic environment.
RESPONSE NO. 105:
The last amendment to the terms and conditions of the Serice Agreement with UBS was
completed on Januar 1, 2006 for revised terms to take effect on January I, 2007. At that time
the services were not competitively bid. However, United Water conducted an extensive market
study of costs for comparative, alterative biling systems. The study identified the market rate
per bil for comparative systems would be between $1.25 and $1.95. United Water negotiated a
per bil price of$O.93 from Januar 1,2007. This price is fixed through the end ofthe current
contract which is December 31, 2011 and therefore no fuer amendment in price is possible in
relation to the economic environment.
UNITED WATER IDAHO INC.
CASE UW-W-09-01
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer: Lynne Allaker
Sponsoring Witness: Gregory P. Wyatt
REQUEST NO. 106:
Please identify any changes, if any are contemplated, with the Company's relationship with
UBS.
RESPONSE NO. 106:
The existing contract with UBS wil remain in effect until December 31, 2011. Over the past 14
months, representatives from United Water have been assessing business requirements in relation
to customer serice, biling and collections for the future. This team has completed a detailed
technical assessment of the UBS Wins CiS system in comparson to curent alternative market
technologies and systems. As a result of these business and techncal assessments, United Water
has determined to replace the current UBS Wins CiS system. Following an extensive RFP
process, Oracle CC&B has been selected as the new CiS solution. United Water plans to be
fully migrated onto Oracle CC&B by December 3 I, 2011.