20091223CAPAI 1-15 to UWI.pdf

Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 1 ih St.
Boise, ID. 83702
[phone] (Land)
[phone] (Fax)
bmpurdyØ)hotmail.com
Attorney for Petitioner
Community Action Partership
Association of Idaho
RECEIVED
2009 December 21 PM 3:38
IDAHO PUBLIC
UTILITIES COMMISSION
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. UW-W-09-1
COMMNITY ACTION
PARTNERSIDP ASSOCIA-
TION OF IDAHO'S FIRST
PRODUCTION REQUESTS TO
UNITED WATER IDAHO, INC.
The Community Action Partership Association of Idaho (CAPAI), by and through its
attorney of record, Brad M. Purdy, requests that United Water Idaho, Inc.("United Water" or
"Company") provide the following documents and information pursuant to the Commission's
scheduling order previously issued in this case.
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. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as contiuing, and United Water is
respectfully requested to provide, by way of supplementary responses, additional documents that
it or any person acting on its behalf may later obtain that wil augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
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Request No.1:Does United Water conduct any tye of tracking or monitoring to
determine how many of its customers qualify as "low-income" according to either the United
States federal poverty guidelines, or by any other measure or index?
Request No.2:If your answer to the preceding production request is in the
affrmative, please provide the number of such low-income customers for every month from
Janua, 2007 to November, 2009.1
Request No.3:Does the Company conduct any tye of analysis to determine the
primar cause(s) of customer disconnections? If so, please explain the analysis and, specifically,
if the cause is due to the income level of the customers, provide how many customers'
disconnections are related to their income level and/or inabilty to pay.
Request No.4:How many United Water customers have been disconnected for
non-payment for every month including Janua, 2007 through November, 2009?
Request No.5:Has the Company calculated the average net costs incured in
disconnecting a customer in any given month from Janua, 2007 through November, 2oo9? If
so, please state what said monthly averages (or actual costs if you prefer) of net disconnection
costs were for the period Janua, 2007 thugh December, 2009.
Request No.6:What is the average percentage of disconnection costs that the
Company completely recovers from the customer who was disconnected for non-payment for the
same period as the preceding request?
Request No.7:Please briefly explain the maner in which the Company calculates
its net disconnection costs for any given month or biling period?
i Though the requested, "monthy" data sougt herein is preferred if any of the Requests for Production can only be
answered by replacing requested "monthly" data with actu .'biling cycle" data pleae so state and provide the
requested information in whichever method is available.
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Request No.8:Please describe all programs, policies or method that the
Company has implemented to reduce the number of disconnections it incurs?
Request No.9: Please briefly explain how the United Water Cares program
fuctions, including whether the Company's shaeholders contrbute to the program and, if so, to
what extent.
Request No. 10: Please state when United Water Cares was first implemented, and
how much total money, or biling credits generated, on an anual basis since the program's
inception to the estimated total for the year 2009.
Request No. 11: In responding to the preceding Request, please separate the money
or biling credits provided by United Water customers as opposed to Company shareholders.
Request No. 12: Has United Water increased or decreased any shareholder
contrbutions to United Water Cares since the program's inception and, if so, please identify
when the shareholder contributions were increased or decreased, and to what extent.
Request No. 13: Please provide the identical information requested in the preeding
Request, but replace "shareholder" contrbutions with "ratepayer" contributions.
Request No. 14: Aside from unecovered disconnection costs due to non-payment,
has United Water conducted any tye of analysis of the financial impact of losing an average
residential customer due to non-payment? If so, please explain sad analysis and the results
thereof.
Request No. 15: Has United Water analyzed whether the United Water Cares
program has resulted in a reduction in the number of customers that would otherse be
disconnected due to non-payment and, if so, the extent of said reduction?
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DATED, this 21st day of December, 2009.
~~~B~M.~
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"
CERTIFICATE OF SERVICE
I HEREBY CERTIFY, that on ths 21 st day of December, 2009, I, the undersigned, have caused
to be served a tre and correct copy of the foregoing CAPAI's FIRST PRODUCTION
REQUESTS to the following by the method indicated.
Weldon Stutzman
Chrstine Sasser
Deputies Attorney General
Idaho Public Utilties Commission
472 W. Washingon St.
Boise,ID 83702
(Sent via email attachment to be followed with hard copy hand-delivered).
Joe Miler
McDevitt & Miler
420 W. Banock Street
P.O. Box 2564-83701
Boise, ID 83702
(Sent via email attachment to be followed with hard copy hand-delivered).
~~ ..........\-Bra .Purd /,~~
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