20150810Staff to UWI 113-124.pdf

DONALD L. HOWELL, II
DAPHNE HUANGDEPUTYATT'RNEYSGENERAL :l'liit-iil Pll 2:10
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 :BOISE, IDAHO 83720-0074
(208) 3 34-03 12t33 4-03 t8
IDAHO BAR NOS . 336618370
Street Address for Express Mail:
472 W, WASHINGTON
BOISE, IDAHO 83702-5918
Attomeys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
UNTTED WATER IDAHO INC FOR ) CASE NO. UWI-W-15-01
AUTHORITY TO INCREASE ITS RATES AND )
CHARGES FOR WATER SERVICE IN THE ) FIFTH PRODUCTION
STATE OF IDAHO.) REQUEST OF THE) coMMrssroN STAFF To
) UNITED WATER IDAHO INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Donald L. Howell and Daphne Huang, Deputy Attorneys General, request that United
Water provide the following documents and information as soon as possible, or no later than
MONDAY, AUGUST 31,2015
This Production Request is to be considered as continuing, and United Water is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIFTH PRODUCTION REQUEST
TO UNITED WATER IDAHO I AUGUST 10, 2015
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 113: Please identify the number of disconnections for non-payment on
a monthly basis for calendar years 2011,2012,2013,2014 and 2015 to date. For comparison
please include the number of customers for those same time-frames, and the number of
disconnections as a percentage of total residential customers for the same time period.
REQUEST NO. 114: For residential accounts identified as having been disconnected
for non-payment in the previous request, please provide the number of accounts that received
UW Cares benefits by month for calendar years 2011,2012,2013,2014 and 2015 to date. How
many of those customers were subsequently disconnected for nonpayment during the following
two months?
REQUEST NO. l15: Without revealing customer identities or other confidential
information, please provide a spreadsheet showing the average monthly consumption of all
customers receiving assistance through the United Water Cares program for calendar years 2011,
2012,2073,2014 and 2015 to date.
REQUEST NO. 116: Please provide an update on the United Water Cares program.
Please explain any changes to the program since 201L Please include monthly and annual data
for calendar year 201I through 2015 to date by Company contributions, customer contributions,
total dollar amount awarded to customers, total number of customers assisted, and total amount
provided to El-Ada for administration.
REQUEST NO. 117: Please provide the number of incoming calls handled by the
customer service representatives by month for calendar years 2011,2012,2013,2014 and2015
to date.
REQUEST NO. 118: Please provide a breakdown of the number of incoming calls and
emails from customers to the Company by category (e.g., payment arrangements, start/stop
FIFTH PRODUCTION REQUEST
TO LINITED WATER IDAHO AUGUST 10,2015
service, high bills, disconnections, etc.). Please include all calls, including those calls routed to
another department. Please provide the information by months for the years 201 I ,2012,2013,
2014 and 2015 to date.
REQUEST NO. ll9: Please describe the customer self-help tasks that can be handled
by the IVR or online, (e.g., bill payment, payment arangements, etc.).
REQUEST NO. 120: Please provide the Company's performance objectives for
handling incoming calls; include objectives for both IVR and customer service representative
(CSR) handled calls. What steps does the Company take if it fails to meet its performance
objectives?
REQUEST NO. 121: Please provide the average speed of answer for CSR-handled calls
by month of the calendar years 2011,2012,2013,2014 and 2015 to date.
REQUEST NO. 122: Please provide a description and cost of contents by type of kit,
(indoor, outdoor, low-income, other), provided to residential and low-income customers under
the United Water conservation programs.
REQUEST NO. 123: Please provide the number of water conservation kits distributed
by UWI in the United Water Cares program for calendar years 2011,2012,2013,2014, and 2015
to date. Please separate and identify the number and type of kits distributed through each of the
different distribution channels and those by UWI directly to customers. (El-Ada, Boise City
Library locations and other channels.)
REQUEST NO. 124: Are all costs associated with the United Water Cares program
covered by shareholders? Please explain.
FIFTH PRODUCTION REQUEST
TO UNITED WATER IDAHO AUGUST 10,2015
DATED at Boise, Idaho, this
Technical Staff: Chris Hecht (ll3-124)
i :umisc: prodreq/uwi I 5. I dhdjhrpsjbmechjbojtphtcmmac prod req 5 to UWI
FIFTH PRODUCTION REQUEST
TO UNITED WATER IDAHO
iO%*of August 2ots.
4 AUGUST 10,2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l0th DAY OF AUGUST 2015,
SERVED THE FOREGOTNG FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO UNITED WATER TDAHO, IN CASE NO. UWI-W-15-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK
BOISE TD 83702
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N ITTH STREET
BOISE TD 837092
E-MAIL: [e-mail]
E-MAIL ONLY: [e-mail]
gre e. wyatt@unitedwater. com
i erry.healv@unitedwater. com
gary'prett)'man@unitedwater' com
walton.hill@ unitedwater. com
debra.visconti (ounitedwater.com
KEVIN H DOHERTY
UNITED WATER MANAGEMENT
AND SERVICES CO
2OO OLD HOOK ROAD
HARRINGTON PARK NJ 07640
E-MAIL: [e-mail]
[e-mail]
CERTIFICATE OF SERVICE