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Home My WebLink About20091230UWI to Staff 185, 198.pdfMcDevitt & Miller LLP Lawyers ..EC. i:í\i~:r',\~'\ .. .",1 ¡¡'.. l~t ,~"'" ~,'" (208) 343-7500 (208) 336-6912 (Fax) 420 W. Bannock Street 6 P.O. Box 2564~83701 innq OEC30 PM 2: 5 Chas. F. McDevittBoise, Idaho 83702 Dean J. (Joe) MilerIDAHO UiIUT\ESDecember 30, 2009 1ía Hand Delvery Jean Jewell, Secreta Idaho Public Utities Cotnssion 472 W. Washigton St. Boise, Idaho 83720 Re: Case No. UW-W-09-01 General Rate Case Filng Dear Ms. Jewell: Enclosed for fig, please fid thee (3) copies of United Water Idao's Second Response to Cotnssion Staffs Ninth Production Request Nos. 185 and 198. Kidly retu a fie staped copy to me. Very Truy Yours, McDevitt & Mier UP ~.~ DJM/hh End 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(fmcdevitt- miler. com RECEl r\tl. _ORIGINAL 2009 DEC 30 Pt~ 2= 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 SECOND RESPONSE TO COMMISSION STAFF'S NINTH PRODUCTION REQUESTS United Water Idaho Inc, ("United Water") by and through its undersigned attorneys, hereby submits its Second Response to the Commission Staffs Ninth Production Request Nos. 185 and 198. DATED this ~day of December, 2009. UNITED W A 'FER IDAHO INC. By:~!¡41er ' 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 SECOND RESPONSE TO COMMISSION STAFF'S NINTH PRODUCTION REQUESTS- 1 CERTIFICATE OF SERVICE I hereby certify that on the .ray of December, 2009, I caused to be served, via the methodes) indicated below, tre and correct copies of the foregoing document, upon: Jean Jewell, Secretar Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise,ID 83720-0074 jjewell(fpuc. 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(fhotmail.com Hand Delivered U.S. Mail Fax Fed. Express Email JL )4 ~i. ~i. ~i. ~i.Ki. ~i. ~i. BY:~~ McDEVI1 & MILLË UNITED WATER IDAHO INC'S SECOND RESPONSE TO COMMISSION STAFF'S NINTH PRODUCTION REQUESTS- 2 ". ~' UNTED WATER IDAHO INC. CASE UWI-W-09-01 NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer: Lynne Allaker Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 185: Please provide a description of your curent ebiling program including implementation strategy. Provide justification for the Company's deciding to initiate ebiling of customers who did not agree in advance to receive bils through the Company's ebiling program. Identify any issues or problems encountered, what was done to resolve them, whether there are ongoing issues, and any changes to the program since implementation. By month for CY2009, provide information for the program including: number of solicitations sent, number of enrollees or customers who accepted the offer, number of customers declining enrollment, and number of incorrect email addresses or undeliverable emails. RESPONSE NO. 185: The eBiling program was designed to provide customers with the option of receiving their bils electronically via emaiL. The eBil contains a PDF copy of the bil along with a payment option, instructions on opening the PDF, installing Adobe Acrobat if needed and frequently asked questions. The eBiling program was rolled out in Idao in Februar 2009. For a limited amount of time, the program allowed customers to receive both a paper and electronic bil for two biling cycles afer enrollment. The eBiling service delivers both cost and environmental benefits and the Company implemented several marketing channels to encourage customers to enroll as follows: · Customer service representatives promoted the new service during phone calls; . The Company website was updated with information abobt the eBiling service and the associated benefits. Online enrollment was also made available; · Footnotes promoting eBiling were added to external emails; and · B il messages were added to paper bils and inserts were mailed out with bils informing customers of the service with directions on how to enrolL. United Water also pursued the option to purchase public email addresses. The email purchasing program allowed United Water to match the Company's current customer database to permission-based opt-in databases of emails. These databases collate email addresses of customers who have at some point given their consent to receive various emails from vendors and suppliers. If an email address was matched with a customer, a short email from the Company was sent asking the customer to verify that the email address was correct and explaining that the Company would like to do business with them via emaiL. The customer was given the option to unsubscribe from receiving further emails. Any customer who did not unsubscribe was then sent an introductory email explaining the eBiling service. This email confirmed that the customer had been enrolled in the eBiling service and again gave the customer the option to unsubscribe. Those customers who did not unsubscribe received both paper and electronic bils for the ,. next two biling periods. Every email communication sent to customers in relation to eBiling includes an option to unsubscribe from eBiling. By the third biling period paper bils were automatically stopped. The following chart shows the breakdown of the initial results from the emails that were matched and urchased: All emails sent were tracked on a daily basis including undeliverable and bounced email addresses. All customers with undeliverable or bounced email addresses were automatically unsubscribed from eBiling and continued to receive paper bils only. Below is the monthly breakdown of the number of undeliverable/bounced email addresses: The email purchase program delivered very positive results for United Water Idaho; however as with any tral there were also several learing points. The main issue identified was that a number of customers enrolled were not opening eBils sent to them. As a result, when the trial period finished and paper bils were discontinued, some customers did not open their prime bil delivered electronically and subsequently received an arrears reminder notice which was sent via both traditional mail and electronically. United Water Idaho identified this issue promptly and reports were run for all customers who had completed their two eBiling cycles and had not opened the emails sent to them. These customers were then contacted and were either unsubscribed from eBiling or asked if they wanted to provide an alternate email address where they wished to receive their eBils. As a result of this exercise, 4,163 customers were unsubscribed from eBiling. These actions were taken and any problems resolved within a matter of days of the issue being identified. Overall the results of the trial were stil very positive. Out of the initial 11,186 emails purchased and used, a total of 2,853 customers remain enrolled in eBiling which represents 26% of customers contacted. There are no ongoing or outstanding issues relating to this marketing pilot program. This program was viewed as a point in time marketing strategy by the Company and there are no plans to repeat this exercise in the future. t." UNITED WATER IDAHO INC. CASE UWI-W-09-01 NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Kevin Doherty REQUEST NO. 198: Please describe the study performed by the consulting firm AON. The description ofthe journal entry for $8,320.32 is "Allocate AON Consulting fee. Analyze General Waterworks companies' original unrecognized B/S items." Please see the attached spreadsheet from Production Response No. 147 for reference purposes. RESPONSE NO. 198: Please refer to the attached invoice from AON. The charges under the heading "Regulatory Support for General Waterworks Acquisition" were allocated to the relevant United Waterworks companies. United Water Idaho's share of this cost from AON was the $8,320 referenced. On April 1, 1994, United Water Resources acquired General Waterworks Corporation and recorded a pension asset amount as a purchase accounting adjustment on their consolidated financial statements. This adjustment was done on a total plan basis and not at the individual participating company leveL. The work performed by Aon reflected in the invoices referenced above was to determine how the pre acquisition unrecognized balance sheet pension amounts, which were recognized immediately at April 1, 1994, would have been taken into expense had no acquisition occurred. This work was performed because another state regulatory jurisdiction requested it. ./ UNITEp WATER Exhibit lIE!) - Out-oC-Scone Pi'ojeets 4th Qnarter2007 Fee In'Volce OWR QUALIFIED RETIEMENT PLANs/UNITED WATERSEltVJCES RETIREMENT PLANS .) Qualified Domestic Relation Orders. and special calculations including $ 7,700 retroactive nonnal retirement benefitl. deatb benefits and prviouslý unreported teninatioiis wbU$edata is not on PACS .) ResoI\e DOL Inquiry into 2003 Master Trst Filing $ 1,80Q REGlJLATORY SUPPORT FOR GENERAL WATERWORKS ACQUISITION ~ .;. Prepared detailed exhibitssbo\Ving bow original unreognized balance sheet items would have been tiikep into expense had no acquisition occurred SUEZ REPORTING SUBMISSIONS .) Additional work related to SMA ItT submission. including migration to updptedmortliy basi$for pension plans and postretirement medical plans,responses to auditors and rèvisedtinal fonns $35,400 UNION AND NONUNIOl'40100 PLANS ~ Preliminary 20(11 NondiscdminaUonTesting $6,200 $8,250 S 1,750 $4;800 +) Investment CótiSUllng ~ Preparation of Delinquent Filer Submission for 2006 Plan Year ~ Complete 2006 Fonn 5500 Filng POSTRETIREMENT MEDICAL ~ Modifications to SMART disclosure package for reconciliation of payments $14,800 .) Milwaukee Additional PAS 5 Consideralions $7,400 TOTAL OUT-OF..COPE PROJECTS $.l ~;ØvZ;~Aon ConslJlting UJr /~~~1'l~.._~" Case No. UWI-W-09-01 Page 1 of 10 Requisition 200 Old Hook Road HarrIngton Park NJ 07640-1799 Page 1 Currency U D ShlpTo: t, f~' 'Y-ly ~çli iiém 1-1 Deser!Pn 41h Q 2001 Fee Inv rot Basc SIi- Po&l Rètemen. B8Ili alier IhanPeliiilon, .IlIlc #Of1258'MOCOt. Da 0361& Mfq!D Ôuanl! UOM Price 1.0000 EA 61,000.00 Extended Amt Due Da I 67,000.00 Buyer Còneetta L CirdOlla Vendor. OooOoot9$ AON CONSULTING INC 2.1 41h Q 20 FeeInv fo8lo$eivce.Publb Selvll;CommssnReliilèd Ses . NYL InvoicIIt1258-MQ1.Dale: 03818 I.! Tot 1.ooooEA S,20Oc.OO !i ,000. oi 5,200.00 Buyer: Concella L Cerdonll Vendor: 000~~196 AOCONSULTINGINC ttl' 3.1 4th Q 2007 Fee Inv for Basfo Séivce - LOE, AIS19 FAS 87 &106. ding ofconii..lnvJc 1I11258.MOCOt;Dale: 038 lIoeTole!; i.oooOEA 5. 290. og 30,000.00 30,000.00 ~~.~ Buyer: Conc;la L CardonlJ Vendor: 00~~0198 AON CONSULTING INC 4-t 4th Q 2007 Fee lov for Basc Seiv - Unied Wate Setvii" lnvoloø ft11256.MOC01. Dele: 031618 L1nøTola¡ 1.0000 EA 27,500.00 30.000.02 27,SOO.00 RECEIVED Buyr: Conçe(la L Cardne AUG 082008 Attachment to Production Request 198 Response Case No. UWI-W-09-01 Page 2 of 10 Requisition Ship To:200 Old Hook Road HarrIngton Park NJ 0764Q.1799 (In,..cM Item Oesçllon MU ip Vendor: 0000000198 AON CONSULTING INC QuanU UOM Pri Exnded AmtPue pate I 5-1 LIe Tot 1.0000 EA 2:1,200.00 27,5!!1J.!l 4th Q 2007 Fee Inv for Paslc Sel'ces - P80P -Invol tl011258,MoC01.Dal.: 03/261 22,200.00 Buyer: Concelta L Caidona Vendor: 0000000198.. AON CONSULTING INC Lk1eTOlt.. 1,ooooEA 15,800.00 22.3°0," 4th Q 2007 Fe8 lflvforaa1o Sal'c... PublloSaleolsonRoflltlK SIMco - CT -IIWOlce ti011ôa.MOQQ1. Dale: O3OLL Buy Concelta L Cardone Vendor: 00~0196 AON CONSULTING INC 7.1 lIMTolt 1.0000 EA 99,700.00 lS.§!!O,go 4I1Q2007Fn fnv fotBå$l Se""ceii~SP8cål Pen 1I1udO$ andollar cosulting-Invo 1I01t268.MOC01, Dale: 032518 99,700.00 Buye: Concelta L Cardone Vendo 000000196 . AON CONSULTING INC 8-1 LlnaIQ1I¡ 1.0000 EA 2,000.00 9! ,70q, 90 41l Q 2007 Fe. Inv (or ßasla Saivces- SERPIDIRECTOR/ON -QUALIFIED Benoftle. Invoce 1I011258-MOC01, Dale: 031251 2,000,00 RECEIVED AUG 082008 Accounts Payabl Dept. Attachment to Production Request 198 Response Case No. UWI-W-09-01 Page 3 of 10 Requisition Ship To:200 Old Hook Road Harrington Park NJ 07640.1799 2008 Lios-sëha IIp DesCl!on Mfq lOBUY81: Coneøiia L Catdoll Vendor: 000000196 AONCONSULTING INC Quanllt YOM Price Exed AmIDus Diìle I LfntTolal¡2,000.00 Tolal Requl§l!lgn Amunl;2li.f00.OO lov fl01126&.MQC1 Oate: 03126108 RECEl\i.EO AUG OS 2008 ~CCoun\S Pava\) nap\. Attachment to Production Request 198 Response Case No. UWI"W-09-01 Page 4 of10 AOICONSULTING UNITED WATER Exhibit "Ef'_ Out-or-Scope Profects 1$1 Qual'ter 2008 FèeInvolce UWR QUALIFED RETIRMENT PLANS/UNITED WATER SERVICES RETIREMENT PLANS + Qualified Domestic Relation Ol'dersand special calculations including $ 9l300 retroactive normal retii-ement benefits. death benefits and preioiisly uni'eported termiations whose data is not on PACS .) Milwåukee Cåsho\tt Calculations $ (5-:00).~~~~, $ QllOO~)~/~ Milwakee CurlaUtíent CalQulations REGULATORY SUPPORT FOR GEN WATERWORKS ACQUISITION .) Preparation for and attendance at meetin to discuss detailed exhibits showing how original unrecognized balance sheet items would have been taken into expense had no acquisition occUlTed (. Valuation of mortality impact by each entity (completed) UNION AND NONUNION 401(K) PLANS .:. Complete 2007 Nondiscrinnnation Testing $ $ 12.600 8.250.:. Investnient Consulting POSTRETIREMENT MEDICAL (+ Milwaukee Consuting Related to Contl'8ct Teimintion c§$ .) Audit Support and Additional Consulting Related to Update of2007 Actual Payments and Completion ofYeal'-End US GAAP Results $ $ 14,500 .:. Handling Transfers of Company Recoi'ds - Local US GAAP 8,750 TOTAL OUT. OF-SCOPE PROJECTS $ ~ _.~~io3(~~:-A~=r~_.'00_~.~ Page50f10 . ~ Requisiton ShIp To:200 Old Hook Road Harrington Park NJ 07640-1799 l:uslOess unil:UU3UtI ReqlD:Dale Paga 0 0 1 RequlÌ\Ør Currecy I'iâ.ttl.. Ml.."b..i uiiD Requeste Slgialue Unø; Item 1-1 MfglD 67,000.00 OesalUon 1st Q 2008 Fee In'l for 1Jll1c SeMc$. Post Retirement BenéßfS olhet thllPelllOns . InvlCè 1I11574-MOC01. Date: 04/11108 Buyer: cocetta.L CetdO/& Vendor 000~~198 AON CONSULTING INC 2.1 1$tQ200Fee Inv for Be'ltt SlINlce8. PllbßcSel\ Comml$løn Reiiled Seivlce. NY.lnv 1l011614-MOCOt, oate: 04111108 Buer: ConceUa L Caron VendOl: 000000198 AON CONSLTING INC 3-1 1stQ2008Fee InV for Bilskl sørvoes- LOE, AIS19 FAS s¡ & 10e, change Ci oonlrol-Inofç 1I11614-MOC01. pate: 041/08 Buyr: Conc:t\ØL Cate VendOl: 0000000198 AON CONSULTING INO 4"1 1st Q 200 Fee Inv for Balo seNlce. - United Wat.t SeNlce - Involç 1I11674.MOC01, Dal.. 041110 Buyer: Cocelta L Cardono Quant!!y UOM 1.0000 EA EiindedAiDUl Date IPiJ 6',000.00 L1AATgts i.ooooEA 67.9:°0,00 5,200.00 5,200.00 UoeTolal¡ 1.0000 EA 30,000.00 :¡.ago.oo 30,000.00 L!nøTotal¡ 1.0000 EA 27,500.00 30,9°0,00 27,500.00 RECEIVED SEP 262008 i\ccounts Payable Dept. gna ure Attachment to Production Request 198 Response Case No. UWI-W-Q9-01 Page 6 of 10 ShIp To:200 Old Hook Road Harrington Pèrk NJ 07640.1199 Requisition Pag.. 2Cur Attachment to Production Request 198 Response Case No. UW-W-Q901 Page 7 of 10 Requlslton ShIp To:200 Old Hook Road HanIngton Park NJ 07640-1799 lloe1§ kêì Qê8tõû Mfq 10 Buyer Concetla L Cardone Vendo 00~~0198 AON CONSULTING INC lnv tlllô14-M01 Dale.: 04111/08 Page 3 Currenc o QuantIty UOM Pd ExtendAìtDueDate I UnBTolat 2.oQl,QO Total ß8Uln Ant 26§,lg0.00 Attachment to Production Request 198 Response Case No. UWL-W-0g.01 Page 8 of10 Ui.EDlYAlllU.UOEIIINr &lElES r,wiPAY"lIatOC ADiiçOl$Ulm:a (o14...Ii..tw&.illiiiçll.'"viii ATTI LYIII~.t.tlWJllSlYOI".i:~I"". I~WH_I~AtmsAYOUOflNOlI , ipiJIPI'_l\lsu.""'lN4ll._' err 9J .1 V I!PI 6C!1=_' ACAlótAIOIl'GlllDis~P.O'l iimoM 8U305 REQUISITION. VElfDOR19l 90ñN J.OPCH Irr iN lIivoltillll7_ l, ~...( ....\.... ..;ri ¡.'"viaiAlAlmsAII/Of~nail.I.11OICO ~Pl 'dM!~'N:AlmsAYOIO,-,ÐQll UlD WAlI8£f.l 11.... .. I.~I ~lT"IOn5N'iOUliIOFlWl ,DElR! IIN/llm CilI.I liI COÐLË Ell 0ctA RECEIVED Acñ\ !11 !pElf t I I V ~ YiØit I Mì I i JQijßKl SEP 26 2U08 '\CGounts Payabite Dept. ~ij nA ~ ~ ItJ(#fOF~.1 Svb ..1'0\\°1ii;tI __lll'le/I!I lloiAU A. t. ,.p.i "r c; Attachment to Procuetion Request 198 Response Case No. UWI-W-D9-01 Page 9 of 10 Ulario",1l~._"~.AT~".''' AOIC~_1VIo(o _ ol.,. aiIISCH....W/mL~,lÆJÐ~~... aU30l REQUISITIONfVEIlDORUl ~i-\\ \ qitl 0 j)t\-\ 'i oq f~'ô~ c., Mira.bA.\1__*'-...-A'louOFOlICI .. DlICli..l'0 I'""oi_ot__.__....llll.-it""- rr îl. I eWI!l'ni Aëir I ëØrri ijYõOFâW - IVM_i- '.!iBa'Ac À\.iOII'I~'ii 2l 'Eû",_.ACAI.lU_or_IItlCRP1lUai,CO8£_. -~ .ffii~lil~!P~I 7!t:::~l '=!1Wl.!_Alms~OI~ .--.."...._""--.: Torll i_meo'_AI_1U00Ofii_ .DUIOJlml l£lircoli_ii__ ~iOClC I)¡ I 91Rt I "§if I Mõì5 Aû ~ ~ ~ç;mE~rfiCf~1 :=t'Th~+~ 2,, ;0 tota. · ? 2u,(n, ioo-p _""CC-e:i.,lf ZP'i'¿'O~ Attachment to Production Request 198 Response í Case No. UW-W-09-01 Page 10 of 10