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Home My WebLink About20111122CAPAI to UWI 1-12.pdfJean Jewell From: Sent: To: brad purdy fbmpurdy(§hotmail.comJ Tuesday, November 22, 2011 3:56 PM Weldon Stutzman; Joe Miler; heather(§mcdevitt-miler.com; kevin.dohert(§unitedwater.com; Jean Jewell Teri Ottens Case UWI-W-11-02: CAPAl's First Production Requests to United Water First Production Requests to UWl.docx Cc: Subject: Attachments: Attched are the Community Action Partnership Association of Idaho's First Production Requests to United Water in the above-referenced proceeding. As a preface, CAPAI recognizes that the parties are currently discussing settlement, but is unsure of apparent recent developments in that regard. These production requests should have no bearing on CAPAI's participation in continued settlement. Their intent is to obtain useful information regarding how certin UWI programs operate, and how costs are incurred and recovered. This has the potential for, among other things, CAPAI to propose means by which it can work collaboratively with UWI and possibly lower program costs. Certain requests pertin to low- income consumption characteristics as previously discussed. Please do not hesitate to contact me should you have questions/concerns about the timing of responses to this discovery. Thank you. bp Brad M. Purdy Attorney at Law 2019 N. 17th St. Boise, ID 83702 208-384-1299 Land 208-484-9980 Cell 208-384-8511 Fax bmpurdy(Çhotmail.com i Brad M. Purdy Attorney at Law BarNo. 3472 2019 N. 17th St. Boise, ID. 83702 (208) 384-1299 (Land) (208) 384-8511 (Fax) bmpurdy(ßhotmail.com Attorney for Petitioner Communty Action Parnership Association of Idaho RECEIVED 2011 ~mv 22 PM 4: 52 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-ll-02 COMMUNITY ACTION PARTNERSHIP ASSOCIA- TION OF IDAHO'S FIRST PRODUCTION REQUESTS TO UNITED WATER IDAHO, INC. The Communty Action Parnership Association of Idaho (CAP AI), 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 IDAP A 31.01.01.228. This Production Request is to be considered as continuing, and United Water is respectfully requested to provide, by way of supplementar 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 hearng. CAPAI'S FIRST PRODUCTION REQUESTS TO UNITED WATER 1 Please provide a response to the following discovery on or before TUESDAY, DECEMBER 12, 2011. REQUEST NO.1: Please provide a descriptive of the Company's "United Water Cares" program including how the initial request for assistace is made by a customer (and whether the Company takes and processes applications or refers out) through the determination of whether said customer is eligible for assistance (including criteria for eligibilty, e.g., customer must be more than one month delinquent on their bil) through the process by which customers actually receive assistance. By this request, CAP AI is seeking clarification regarding all of the rules, policies and protocol for assistance under United Water Cares. REQUEST NO.2: Please provide the anual number of customers who have received assistance though United Water Cares for every year since the program was implemented. REQUEST NO.3: Do customer applications for assistance through United Water Cares exceed total number of actual recipients in any given years? If so, please state the differential for every year since program implementation. REQUEST NO.4: Has the Company calculated its internal costs of implementing/administering United Water Cares, including promoting or advertising the program, as well as all other administrative costs? If so, please provide a break-out of those costs on an anual basis. REQUEST NO.5: With respect to the preceding Request, does the Company deduct its costs of implementing the program from total fuding or is that cost recovered from ratepayers or fuded by shareholders? CAPAlS FIRST PRODUCTION REQUESTS TO UNITED WATER 2 REQUEST NO.6: Without revealing customer identities or other confidential information, please provide a char showing the average monthly consumption of all customers receiving assistance through the United Water Cares program for all years since implementation of the program. REQUEST NO.7: Please provide the same information for the Company's low-income conservation kit program since implementation as requested for United Water Cares in Request NO.1. REQUEST NO.8: Please provide a calculation and break-out on an anual basis for internal costs of implementing/administering the low-income conservation kit program. REQUEST NO.9: With respect to the preceding Request, does the Company deduct its internal administration costs from the fuds otherwse available for the conservation kit program? REQUEST NO. 10: Has the Company conducted, or is in possession or aware of any studies purorting to identify what types of residential water usage is non-discretionar (e.g., flushing toilets, drinkng water, etc.) and what constitutes an average non-discretionar "baseline" average monthly consumption? If so, please provide or provide a reference to such studies. REQUEST NO. 11: How many United Water residential customers have been disconnected for non-payment for every month including Janua, 2008 through October, 2011? REQUEST NO. 12: With respect to the preceding Request, please provide the number of disconnections as a percentage of total residential customers matching the same time period. CAPAlS FIRST PRODUCTION REQUESTS TO UNITED WATER 3 DATED, this 22nd day of November, 2011. lsI Brad M. Purdy CAP AI'S FIRST PRODUCTION REQUESTS TO UNITED WATER 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY, that on this 22nd day of November, 2011, I, the undersigned, have caused to be served a true and correct copy of the foregoing CAPAlS FIRST PRODUCTION REQUESTS TO UNITED WATER to the following via electronic transmission. Weldon Stutzman Deputies Attorney General Idaho Public Utilities Commission 472 W. Washington St. Boise, ID 83702 weldon.stutzman~puc.idaho.gov Joe Miler McDevitt & Miler 420 W. Banock Street P.O. Box 2564-83701 Boise, ID 83702 j oe~mcdevitt -miler .com heather~mcdevitt -miler .com Kevin H. Doherty Director of Rates United Water Management and Services Company 200 Old Hook Road Harington Park, NJ 07640-1799 kevin.doherty~unitedwater.com lsI Brad M. Purdy CAPAI'S FIRST PRODUCTION REQUESTS TO UNITED WATER 5