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Home My WebLink About20100112UWI to CAPAI 1-15.pdf(208) 343-7500 (208) 336-6912 (Fax) McDevitt & Miller LLP Lawyers RECEI n 420 W. Bannock Street P.O. Box 2sæiiiM 12 PM~: 25 Boise, Idaho 8~6~Jio UTILITIES Janua 12, 2010 Chas. F. McDevitt Dean J. (Joe) Miler Via Hand Delivery Jean Jewell, Secreta Idaho Public Utities Commssion 472 W. Washigton St. Boise, Idaho 83720 Re: Case No. UWI-W-09-01 General Rate Case Filng Dear Ms. Jewell: Enclosed for fig, please fid thee (3) copies of United Water Idaho's First Response to the Communty Action Partnership Association's First Production Request Nos. 1,2,3,4,5,6, 7, 8,9, 10, 11, 12, 13, 14, and 15. Kidly retu a fie stamped copy to me. Very Truy Yours, McDevitt & Mier ll DJM/hh End ~~Dean J. Mier ORtGtNAL 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 l'ECCP!i ,,_ .! i"~. ., '. iOto JMl 12 PH~: 25 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 FIRST RESPONSE TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION FIRST PRODUCTION REQUEST United Water Idaho Inc, ("United Water") by and through its undersigned attorneys, hereby submits its First Response to the Community Action Partnership Association's First Production Request Nos. 1,2,3,4,5,6, 7, 8, 9, 10, 11, 12, 13, 14, and 15. DATED ths ~day of Januar, 2010. UNITED WATER IDAHO INC. BY:WJ UJ Dean J. Miler 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 FIRST RESPONSE TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION FIRST PRODUCTION REQUEST- 1 CERTIFICATE OF SERVICE I hereby certify that on the Lday of January, 2010, I caused to be served, via the methodes) indicated below, true 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 j ewell(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(fhotmail.com Hand Delivered U.S. Mail Fax Fed. Express Email ~'- '"'- '"'- '"'- '"'-~ '"'-ù '"'- UNITED WATER IDAHO INC'S FIRST RESPONSE TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION FIRT PRODUCTION REQUEST- 2 UNITED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNTY ACTION PARTNERSmp ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO.1: Does United Water conduct any type of tracking or monitoring to determne 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? RESPONSE NO.1: No, United Water Idaho does not conduct any type of tracking or monitoring mentioned above. UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNRSHIP ASSOCIATION Preparer/Sponsorig Witness: Gregory P. Wyatt REQUEST NO.2: If your answer to the preceding production request is in the affirative, please provide the number of such low-income customers for every month from Januar, 2007 to November, 2009.1 RESPONSE NO.2: Please see response to Request NO.1. i Though the requested, "monthy" data sought herein is preferred if any of the Requests for Production can only be answered by replacing requested "monthly" data with actual "biling cycle" data. please so state and provide the requested information in whichever method is available. UNITED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO.3: Does the Company conduct any type 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. RESPONSE NO.3: No, United Water Idaho does not conduct any particular analysis of customers whose water service is disconnected due to failure to pay their water bilL. The Company assumes that customers who have the abilty to pay their water bil do so. " ~ UNITED WATER IDAHO INC. CASE UWI- W-09-01 FIRST. PRODUCTION REQUEST OF COMMTY ACTION PARTNERSmP ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt REOUEST NO.4: How many United Water customers have been disconnected for non-payment for every month including January, 2007 though November, 2009? RESPONSE NO.4: Please see the attched worksheet for the number of disconnections for non-payment for 2007 - 2009. " I I 1~ - - - - - - - - - - - - l = = - - = ~ + = ~ ~ - = - ~ - - , ~ i -- ¡ - - - - - - - - - - ~ - - - - i - - - - - ~ - - r - - c ' - - - - - - - = = l - = - - ~ = l - = l . . . Ju l _ _ A u g S e p - - O c t _ L N o v _ ! _ _ J ~ ~ E j _ J o t a l _ __ _ _ _ _ _ _ _ . = - _ _ . ~ _ . - = t _ ~ i - = = = - - t = - ~ - - - ~ t = = ~ . ~ = ~: : ~ ~ : ~ j = ¡ : T ~ s = ~ ~ : Un i t e d W a t e r I d a h o .' - - - - _ . . . , _ . _ ~ - - - - - _ . _ - - . - - - - - , . . , _ . _ . . _ - - - Re s p o n s e t o C A P A I P r o d u ç t i o n R e q u e s t N o . 4 -- - , . - u - - - ' - - ~ _ _ ~ i -~ - - Di s c o n n e c t i o n s fo r n o n - p a y m e n t ~~ - ~ ~ t - - . Ma y l J ü n - - -- , - Ja n Fe b Ma r Ap r I- ._ l _ 2 0 0 7 _ L _ _ _ 1 7 4 1 = ~ = = 1 4 3 ~ - 1 4 8 16 7 ~ 1 0 8 l _ _ _ _ _ 1 3 ~ 1- 18 5 - 22 8 20 0 8 13 8 24 1 14 8 -- i 3 - 9 - + - 20 0 9 15 7 16 1 20 6 21 1 1 i o s r - 2 4 1 - - - . . - - - - UNTED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSmp ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO.5: Has the Company calculated the average net costs incured in disconnecting a customer in any given month from Januar, 2007 though November, 2009? If so, please state what said monthly averages (or actual costs if you prefer) of net disconnection costs were for the period Januar, 2007 though December, 2009. RESPONSE NO.5: No, United Water Idaho has not made a calculation of the average net cost incured in disconnecting a customer for the period requested. UNITED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSmp ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt 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? RESPONSE NO.6: Please see Company's the response to Request NO.5. UNTED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNRSmp ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO.7: Please briefly explain the maner in which the Company calculates its net disconnection costs for any given month or biling period? RESPONSE NO.7: Please see the Company's response to Request NO.5. UNTED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO.8: Please describe all programs, policies or methods that the Company has implemented to reduce the number of disconnections it incurs? RESPONSE NO.8: United Water Idaho prepares and mails a bil to its customers every two months. If the customer does not pay the bil, thiry-five days after the bil date, a reminder notice is mailed. If that doesn't prompt payment, a shutoff notice is mailed with a specific date that disconnection wil occur. Two days before the proposed disconnect date, the customer receives a telephone call from either an automated service or a customer service representative. If the customer does not respond to the telephone call, a service person is dispatched on the disconnect date. Prior to disconnecting the service, the service person goes to the door to give the customer the opportunity to pay the bil or call the office in order to make payment arangements. Only afer all these attempts to collect are unsuccessful does the Company then terminate service for non- payment. Beginning in 2005, United Water Idaho initiated a program called UW Cares which enables customers, who are having diffculty paying their water bil, to receive up to $50 a year against their water bilL. This was the first and remains the only low-income help program available for water customers in the state of Idaho. Customers who take advantage of UW Cares are also provided with water conservation kits to help them reduce their water consumption. The Company, historically and curently, actively promotes wise water use and water conservation though a variety of public education campaigns, school programs and water saving device give-a-ways. UNITED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSmp ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO.9: Please briefly explain how the United Water Cares program functions, including whether the Company's shareholders contribute to the program and, if so, to what extent. RESPONSE NO.9: United Water Idaho makes customers aware of its UW Cares program via bil messages, bil inserts, and communications in varous conservation notices to customers. Customers who request assistance under the program are to contact EI-Ada Community Action Agency to access the program. Customers may receive up to $50 in assistance towards paying their water bil in a 12-month period. Although the Company encourages customers to contribute towards funding UW Cares via bil messages, the vast majority of customer assistance provided through UW Cares has come from the Company's shareholders. Company response to Staff Production Request No. 136 provides the detail breakout of Company funded and customer funded contributions to UW Cares from Januar 2006 though October 2007. During that period $35,550 was provided by Company shareholders and $3,210 was provided by customer contributions. UNITED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSmp ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt 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. RESPONSE NO. 10: The UW Cares program was initiated in 2005. Company response to Staff Production Request No. 136 provides the detail breakout of how much money/credits customers have benefited from the program from Januar 2006 through October 2007. . UNTED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNRSHIP ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt 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. RESPONSE NO. 11: Please see the Company's response to CAP AI Request No. 10 and Staff Request No. 136. UNITED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMITY ACTION PARTNERSmp ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 12: Has United Water increased or decreased any shareholder contributions 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. RESPONSE NO. 12: At the inception of the UW Cares program the Company committed to matching customer contributions anually up to $20,000 towards the program. Regardless that customer contributions have been quite small, the Company has funded qualified customer paricipants each year, and have not yet reached the $20,000 anual threshold. The Company contributions toward the program rise and fall in accordance with anual requests so long as they remain under the $20,000 anual commitment. UNTED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 13: Please provide the identical information requested in the preceding Request, but replace "shareholder" contributions with "ratepayer" contributions. RESPONSE NO. 13: Please see the Company's response to CAP AI Request No. 10 and Staff Request No. 136. . UNITED WATER IDAHO INC. CASE UWI-W-09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt REQUEST NO. 14: Aside from unrecovered disconnection costs due to non-payment, has United Water conducted any type of analysis of the financial impact of losing an average residential customer due to non- payment? If so, please explain said analysis and the results thereof. RESPONSE NO. 14: No, United Water Idaho has not conducted such an analysis. UNITED WATER IDAHO INC. CASE UWI- W -09-01 FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION Preparer/Sponsoring Witness: Gregory P. Wyatt 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 otherwise be disconnected due to non-payment and, if so, the extent of said reduction? RESPONSE NO. 15: No, United Water Idaho has not conducted such an analysis.