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HomeMy WebLinkAbout20091203UWI to Staff 97-103, 105-106.pdfMcDevitt & MillerLLP (208) 343-7500 (208) 336-6912~Fax) Lawyers REeF"' fr"f',i' . .../.-.1 'tJ r:ti 420 W. Bannock Street P.O. Box i~&ß PM 3: 56 Boise, Idaho. 8~~n~ " " , . i I D f~h \.) r:-~il;;x \ I;;: c:' ; C' :'dTli.ITlí::": C',j,',¡;i'l ¡ ,_,,;t, ,,/,1 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 K.~'- U ~'- ~'- tu ~'- ~'- ~ 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. EXAMPLE 1 (PAGE 1) - WATER SERVICE LINE PROTECTION MAILING I I I II I I I, I I III I I I )Rep By 811410 ~f.samDleA. 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He Mo i a.m." p.. sa 10 a.m.- 4 p.. ES*********************************************"A. oi X¥, pr fl Ne i!!lle I"'L~"- ~ US I! Ml Qi r_ Sl1 is tl i:b ~!h!l iiym i ii mum a de UI Ir AYQi llo; yir a:_ --..11--,i _iU__. EXAMPLE 2 (pAGE 2) - WATER SERVICE LINE PROTECTION MAILING GUARANTEED ACCEPTANCE fORMI., 1: ai)' iî õl,.awQn OI- D~ ~rn-ITCI-1 I I 1 ii I II II I IIRIlCl Cl __ ___o ii-~adw h..fil¥an~hi llli...i bldøloll aiClar.. CJ o Ae.!' up b ~~L i-u: mrdw or lIor fcmr ~ rA m.PU MA CHICK MYAIlO LlGUAR~._ t: dl)''' I.".IIC Io $&99pim: $l1J1pi~ D$1.ipi)lIIU~lOi: lDfl~iictøØClIlflfI~.CI"'~_1I~iiorøØCl 1l.1!"~~~ddl.~SJPl 1:il1i----~~...~~~~.~~~~'!~------ 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 ì' m II lipa ro i: ~ II lo eia,._".-. .. ..._.,. -IIGI_ Re MI se IllZ1... .....-IIGI_ . 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"'O_"~_'~~_'__'",_' I ai L. to i: m¡ 1l:n ll :n m¡ 1l DI toai 1l lIlSÆl fd Of1: I am lI a aI ti m¡ fto .....SU, .....$17.91.....S1.. (- ---_._._~~-~=~~ PI 1l1'c:PA TO -11... EXAPLE 3 (PAGE 2) - WATER SERVICE LINE PROTECTION MAILING _Ii 1- Il sI ii ~ ll Ii 0 l) lI Wl )Q ii SI m - ai IVII l.i: CI'llbhM ~lllt.!illJnDíipi.ai Ifllll' Sl In ne I'p ~ to w:-. Hai..ie Rl"" ~i:!l Of Wl lJn w. Cls NS--~oasiOl_lIh 1. lnND_ QI~No_llD'CD~. CØlICQIl iilr~ii~'._.._lI.lIti..i.!l Cl II soi 36,~ a yi ._...II rJ -.... ...."C Qr ....lf7.97U.....In.CJ~ '-1= CllU IT I IJ CL-:Tl YB J*SlII ~ti ~1i-lIpqiiimPlII..ca.. .._-.10lØ...Nm~S1. EXAMPLE 1 (PAGE 1) - CROSS-SELL MAILING (JOINTLY BRADED) ~ UNITED WATER Ho5e IS to: ""Mf~ samp A. samp;,;,,,~ess tine 1 (Milin¡" ,,~ess LJne 2 (Miling¡;,;, ".:Cít,51 12345-1234;,,II by: .:.:12¡);, fo Your Ho Yl al ma th wise de ti pr yor hoiæ Wí Cl fr Hm se. Enjo iipe of ir by ex~ \' prCl ti inud Yl II ¡ú an drna. Di JO kn th yo ho's in pI an dra ~ ca incup to lI fe of pipe c: fn wa an wa an yo ho? . AS a ti yo ar relË fo th imna an rer of al th ¡i1I~ an diawi yo ho . 1ri pi and dr probms ca be meSS lXea. an eiq ti fix . co' se ca le and re hils ar no ClOO by mo ti nsur po 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," II ND"'f Pi F4Cc Ri-Al ciar ~fo ~irrelh ín ~ am~~ a1)'hi uplD$2li pe seca 1i Up 10 r-li c. PlYe - 'i em mi uplD 2 se cils pe _,ii)O $!ct ~ fo IiIT pe inla ZUEl li Hi -Ai 241i a daJt di a ye relD ~ ti a ca Pn~-A ki Ho Secmwi mitt 0C ~ a1)' to QiWa -Al Ho Se co ar Uy Ii im iÆ GUARAED ACXANC FO 1_1: D-)l me 01 pie:CllI 0 \\ 0 _ .... Ic.lV I 1 1 I I I I I I 1 1 1 1 1 1 I I 1 1 I E- Flc-1l 0 1- oi a_ b my fn pø in_ll al(S-""_ fu¡E iol:i:mlh ii_iill_ 0 ::~::=~=~I- PU!ASE MAIC CHEK I'YABLI TO HOM Sl!lla,1- 2: D- ya Pl fr 1 o $'!i9pirn 0 i:97pi(l D$1191!pi\i Ii _dU adæn '" £~l"" i dlll _'" ~ "'1í;u.. Ui __ "'''-.ai oradæn an "'- __ii ____ti "'-.ai oradciit_íoii_ínoAllll_..-.d-'''i: _ maæi a: to'Piiir__ ~~-I ",o:~ "" I EXAPLE 1 (PAGE 2) - CROSS-SELL MAILING (JOINTLY BRADED) What would you do in an interior plumbing and drainage emergency? ll lIm be sl Whe thi' ar Iitæ to go wr wi your ho's ina plui~ an dranaWi Int Pf an Drri COag it's no so~ yol ne to wo ab )Cl re anerm re an no bil to pa fo CCre l1! U! bI Ir_SlFi U! St ~IDm__ Il1l~ il,..", '\,/J Bwln, 1aP! ørBa SI ør1J 8I1l O'~., i cq : : io SI '. ....._l I . Il ¡ù me II 0l' ib me To set up this essential coverage, simply call TOLL-FREE 1-888-666-7711,, -' j. , .._I..fa..&....01.._IeiA ~ iisriip¡wilE.. til' )I aM ll i''.. ..f1.. Jl anlEl!iw fa mian~u 12miI_...- 'i Pr ÌI by.- lU-H HII18-&.m1. Yw ""IB by E-l 1(.. a:di,lBaøhi ¡I 1t æn iiai", E-lPsby 1!" di l" b fO SB in hi ~ . an ib ....~RlE-lPsíia¡: lÍ ir.. an !Øwøm ..'l~ li)IlI usb Ildi)I Iøtlld'liili,1 p! Iø i1il llat aiYa aMwi biid.. &D 1t'.Il'" '" ii)I Iø 1tdu yo pi ia ca d li Il Yi, ii ei tn )I1l lb a: I4 '"'~ ÔE pi sr ~ 1)1 fi 'J1i !l fI )I!l.. iBwilE.1i iiil......fIji?My IB I' wi II pr '" ti !i' "' fl ci jc.liil diwilh.liba~Mä lD annd ii li m eI ii jc, Cl pq_eIu~_..I,....caloSiltdi~Faíi~ ..cm)&Toi-..'..ai~¡ilHm lib'~, "'ii1i3l røilltiioiiii ""ma&..ii-~'J11 rndaMil)Ilì!d~ 1..llIlDii........,.'bma"'bIW..æI.IHiililrd"'li~. d~""\I 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 2. PI Respo A lo, tiit,lic co wiD be se to yo ho to evluae th pr am to ma anco re 3. JO comp1 JO do; all yo ne to do is si to st yo aresasf, am th bil foco reir wil beseed fo yo Wì thcoge limit 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) Re ~ se d se li 52,74....-lI Cl 1Isz"" B-..~..-ll. 11.._1~llAlliiujl_lIti,. ...Ì1V1im1I ~.. ÌlI3li-....d,._lipian_""_l'Vlim ..~__.. lIl..ai..pi11l1eI-.ùil'...._.iw__Of~dfi ___ bi IJllf JI lli-iì-=\I_......1i1i ..-. ~_ _1_...,'Milli ìH.lÍ-.' " "lai.lIlluCl.___'*l*....,..1Idl\lIl1.i .1''llI be ei I4ID $\ l* __ ci bi hi lX rf ~ daMC!VS ..lIo: __\I lI__ hill\Ipr ....01.._1..~=:i:=~cidllb ___"lipii- ::=,.~'=:-~::":~=:-'::::C....ii..lijo? ..,........,2.. M 3:a=5'f::~~:5 ===:a~=-~=.n::,::~ fb.. b_'__.__'_~1fpiMiíil _'~~LL ..iiRMY' ,t=_.. ...==:.~~~~ ~~i:,: ~.,..""..- _.jl~ , ~... =:FL~~~:iI~;i:C~~-:ai~__ :.~~.;~~:rlE~==i. 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.