20120417UWI to CAPAI 1-12.pdf

McDevitt & Miller LLP
Lawyers
RECEIVE)
420 W. Bannock Street
[phone] P.O. Box 2564-IM'R I I PM l Chas. F. McDevitt
[phone] (Fax) Boise, Idaho 83702 Dean J. (Joe) Miller
April 17,2012 17, 2012
Via Hand Delivery
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, Idaho 83720
Re: United Water Idaho—Case No. UWI-W-11-2;
CAPAI Discovery Response
Dear Ms. Jewell:
At the time the parties reached a settlement of this matter, there was a series of outstanding
discovery requests propounded by CAPAI to United Water. As part of the settlement, United Water
agreed to respond to the requests, as the information requested was of general interest to CAPAT.
Accordingly, I am transmitting United Water's responses to CAPAI's requests Nos. 1-12.
Very Truly Yours,
McDevitt & Miller LLP
Dean J. Miller
DJM/hh
cc: Brad Purdy
United Water
UNITED WATER IDAHO INC.
CASE UWI-W-11-02 2U12 APR 17 PM 2:27
FIRST PRODUCTION REQUEST OF THE COMMUNITY
PARTNERSHIP ASSOCIATION OF IDAHO 'JTLt 1S COSSiO4
Preparer/Sponsoring Witness: Greg Wyatt
REQUEST NO. 1
Please provide a descriptive of the Company's "United Water Cares" program including how the
initial request for assistance 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 eligibility, e.g., customer must be more than one
month delinquent on their bill) through the process by which customers actually receive
assistance. By this request, CAPAI is seeking clarification regarding all of the rules, policies and
protocol for assistance under United Water Cares.
RESPONSE NO. 1
Customers eligible for assistance through the UW Cares program are residential customers who
are facing water service termination due to non-payment of their water bill, providing the
customer has not received UW Cares assistance within the previous twelve months. Such
customers are referred to the El-Ada community assistance agency which administers the UW
Cares program for United Water Idaho. Assuming the customer meets the eligibility
requirements, then El-Ada forwards the customers information to United Water's customer
service center where the appropriate billing adjustments are made to the customer's account.
Beginning October 1, 2011, the amount of assistance available to individual residential
customers in any 12-month period was raised from $50 to $65.
UNITED WATER IDAHO INC.
CASE UWI-W-11-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
REQUEST NO.2
Please provide the annual number of customers who have received assistance through United
Water Cares for every year since the program was implemented.
RESPONSE NO. 2
Information and data responsive to this request were previously provided in response to Staff's
Second Production Request No. 31.
UNITED WATER IDAHO INC.
CASE UWI-W-11-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
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.
RESPONSE NO. 3
No. All eligible applicants for assistance have received assistance.
UNITED WATER IDAHO INC.
CASE UWI-W-11-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
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 annual basis.
RESPONSE NO. 4
The Company does not track internal labor costs related to implementing the UW Cares
program. Predominantly, program promotions are via bill messaging and in conjunction with
other customer communications such as the annual Conservation Tab. In 2009, the Company
incurred $3,705.00 for printing 85,000 "UW Cares" bill inserts which were distributed to
customers within their regular bill.
UNITED WATER IDAHO INC.
CASE UWI-W-11-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
REQUEST NO. 5
With respect to the preceding Request, does the Company deduct its costs of implementing the
program from total funding or is that cost recovered from ratepayers or funded by shareholders?
RESPONSE NO. 5
The Company does not deduct UW Cares program costs from funding available for UW Cares.
All UW Cares benefits provided to customers, in excess of customer donations, are funded by
shareholders.
UNITED WATER IDAHO INC.
CASE UWI-W-11-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
REQUEST NO. 6
Without revealing customer identities or other confidential information, please provide a chart
showing the average monthly consumption of all customers receiving assistance through the
United Water Cares program for all years since implementation of the program.
RESPONSE NO. 6
The enclosed Excel file titled "#6 UW Cares Users 2011 Cons Report.xlsx" provides the ccf
billed consumption history during 2011 for all UW Cares recipients from the past three years.
Due to the recent conversion of its customer billing systems, the Company was only able to
readily produce the information for customers from the past three years. Additionally, there
were 310 UW Cares user accounts from the prior two years that are not included in the 2011
billing history because those accounts were closed at customer request in the previous customer
billing system with no money owing prior to the conversion.
Please note that the averages calculated for each month on row 841 are not "monthly"
consumption amounts but represent the average of the "two-month' ' consumption period billed in
the month for these customers, as the Company employs a bi-monthly billing practice in
accordance with its tariff.
UNITED WATER IDAHO INC.
CASE UWI-W-11-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
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.
RESPONSE NO. 7
All customers may obtain one of the Company's water saving devices which includes a hose
timer, hose nozzle, and rain sensor sprinkler shut-off device by visiting the Company's Victory
Road office location or one of the Boise City library Locations where devices are distributed.
The Company's low-income conservation kit program, which includes the hose timer and hose
nozzle devices, is administered by El-Ada, which was unable to provide any information for this
response.
UNITED WATER IDAHO INC.
CASE UWI-W-11-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
REQUEST NO. 8
Please provide a calculation and break-out on an annual basis for internal costs of
implementing/administering the low-income conservation kit program.
RESPONSE NO. 8
As in the Company's response to Request No. 1, the Company does not separately track labor
costs associated with implementing/administering the low-income conservation kit program.
The 2011 average cost per kit for the devices is as follows:
$ 7.50 - Hose timer
$ 1.90—Hose nozzle
$ .71 - tax and shipping
$10.11 —Total
UNITED WATER IDAHO INC.
CASE UWI-W-11-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
REQUEST NO.9
With respect to the preceding Request, does the Company deduct its internal administration costs
from the funds otherwise available for the conservation kit program?
RESPONSE NO. 9
No, the Company does not deduct its internal administration costs from the funds otherwise
available for the conservation kit program.
UNITED WATER IDAHO INC.
CASE UWI-W-11-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
REQUEST NO. 10
Has the Company conducted, or is in possession or aware of any studies purporting to identify
what types of residential water usage is non-discretionary (e.g., flushing toilets, drinking water,
etc.) and what constitutes an average non-discretionary "baseline" average monthly
consumption? If so, please provide or provide a reference to such studies.
RESPONSE NO. 10
The Company is aware of studies examining residential water usage on a national level. See, for
example, Residential End Uses of Water Study, A WWA Research Foundation,
http://www.allianceforwaterefficiency.org/residential-end-uses-of-water-study-1999.aspx.
There are no studies specific to the United Water Idaho system. The Company has, as part of the
present case, filed revenue and consumption analysis which differentiates between customer's
winter and summer water use (see witness Herbert testimony and exhibits). The extent to which
the winter "base load" water use is discretionary or non-discretionary was not evaluated.
UNITED WATER IDAHO INC.
CASE UWI.-W-11-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
REQUEST NO. 11
How many United Water residential customers have been disconnected for non-payment for
every month including January, 2008 through October, 2011?
RESPONSE NO. 11
The number of accounts disconnected for non-payment is indicated on the attached sheet. United
Water Idaho does not track disconnections by customer class. Also, the Company does not
separately track UW Cares recipients that are disconnected for nonpayment.
United Water Idaho
Case UWI-W-11-02
CAPAI's First Production Request
Request No. 11 & 12
Nonpay Disconnections (all customer classes):
Jan Feb Mar
2008 138 185 228
2009 157 161 206
2010 134 221 213
2011 130 263 216
Apr May Jun Nov Dec Total
241 148 239 139 226 211 259 147 98 2259
211 108 241 102 203 232 245 209 164 2239
214 174 197 161 160 257 262 219 133 2345
228 168 217 165 163 177 25 1752
/
UNITED WATER IDAHO INC.
CASE UWI-W41-02
FIRST PRODUCTION REQUEST OF THE COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO
Preparer/Sponsoring Witness: Greg Wyatt
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.
RESPONSE NO. 12
The percentage of accounts disconnected for non-payment is indicated on the attached sheet.
United Water Idaho does not track disconnections by customer class. Also, the Company does
not separately track UW Cares recipients that are disconnected for nonpayment.
United Water Idaho
Case UWI-W-11-02
CAPAI's First Production Request
Request No. 11 & 12
Nonpay Disconnections (all customer classes):
Jan Feb Mar Apr May Jun Jul Aug Sea Oct Nov Dec Total
2008 138 185 228 241 148 239 139 226 211 259 147 98 2259
2009 157 161 206 211 108 241 102 203 232 245 209 164 2239
2010 134 221 213 214 174 197 161 160 257 262 219 133 2345
2011 130 263 216 228 168 217 165 163 177 25 1752
Residential Customers:
2008 72,902 72,972 72,992 73,077 73,157 73,249 73,329 73,377 73,420 73,306 73,267 73,264
2009 73,248 73,236 73,243 73,267 73,304 73,348 73,364 73,419 73,407 73,384 73,397 73,422
2010 73,461 73,453 73,495 73,579 73,717 73,729 73,850 73,934 73,939 73,970 73,972 73,960
2011 73,995 74,014 74,095 74,168 74,268 74,304 74,428 74,542 74,616 74,477
Disconnection Percentage:
2008 0.19% 0.25% 0.31% 0.33% 0.20% 0.33% 0.19% 0.31% 0.29% 0.35% 0.20% 0.13%
2009 0.21% 0.22% 0.28% 0.29% 0.15% 0.33% 0.14916 0.28% 0.32% 0.33% 0.28% 0.22%
2010 0.18% 0.30% 0.29% 0.29% 0.24% 0.27% 0.22% 0.22% 0.35% 0.35% 0.30% 0.18%
2011 0.18% 0.36% 0.29% 0.31% 0.23% 0.29% 0.22% 0.22% 0.24% 0.03%