961108.docx

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
STATEHOUSE MAIL
BOISE,  IDAHO  83720-6000
[phone]
ATTORNEY FOR THE COMMISSION STAFF
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION
IN THE MATTER OF THE INVESTIGATION )
OF UNITED WATER IDAHO INC. AND ITS) CASE  NO.  UWI-W-96-6
ABILITY TO PROVIDE ADEQUATE SERVICE)     
AND WATER QUALITY.)    FIRST PRODUCTION
)REQUEST OF THE
)COMMISSION STAFF
)TO UNITED WATER
)IDAHO INC.
_____________________________________________)
The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests United Water Idaho Inc. (UWI) provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before NOVEMBER 29, 1996.
This production request is to be considered as continuing, and United Water Idaho Inc. is requested to provide by way of supplementary responses, additional documents that you or any person acting on your behalf may later obtain that will augment the documents produced.
Please provide answers to each question; supporting work papers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder.
REQUEST NO. 1:  Please provide a street map showing United Water’s certificated area, facilities and the location and date of each water quality complaint received by the Company in 1996.  Also on this map please identify all wells or pumps from which water has been discovered to have high levels of iron and/or manganese.
REQUEST NO. 2:  For each well or pump identified as having high levels of iron and/or manganese, please provide:
a)The measured iron and manganese levels for at least one summer month and one winter month for each year from 1992 through 1996.
b)A description of actions taken by the Company to reduce the high levels of iron and manganese since 1992 and the costs associated with those actions.
c)The rated capacity and average monthly volume pumped in 1992 through 1996.
REQUEST NO. 3:  Please provide on a 3.5 inch diskette in Lotus 123 spreadsheet format a list of all complaints received by the Company for the years of 1994, 1995 and 1996   (e.g. low pressure, discolored water, bad tasting water, hard water, sand in water, high bills, involuntary disconnects and any others).
Each complaint should occupy a single row on the spreadsheet and should include at least the following information in separate columns:  month, day, year, last name, first name, other name, street number, street, apartment number, city, zip code, telephone number, primary complaint, secondary complaint, etc. (any additional complaints should be in additional columns), name of the employee receiving the call or complaint letter, action taken by the Company, whether or not the Company’s official procedure was followed regarding the complaint, and whether or not the complaint was resolved to the customer’s satisfaction.
REQUEST NO. 4:  Please provide copies of any and all written procedures for handling water quality complaints.  Include names and titles of customer service representatives, field staff used for site visits and any written follow-up procedure.
REQUEST NO. 5:  Please describe employee training in listening to customer complaints and in understanding water quality problems.
REQUEST NO. 6:  For all employees who are authorized to handle customer water quality complaints, describe their levels of experience, and their levels of responsibility and authority to resolve such complaints.
REQUEST NO. 7:  In reviewing United Water’s October 18, 1996 letter sent to Commission President Ralph Nelson, it appears that the Company has invested and spent hundreds of thousands of dollars in attempts to rectify its water quality problems and plans on spending much more.  Please provide the accounting entries showing how these expenditures have been or will be recorded, the nature of each expenditure, and to whom paid.  Indicate for each expenditure whether it is for 1) normal training, maintenance and replacement or                2) activities that are in direct response to the discovery of water quality problems.
REQUEST NO. 8:  For each water supply source please describe all alternative solutions considered by the Company to reduce or eliminate iron and manganese levels and resolve associated problems.  Please provide the estimated cost of each alternative considered.
REQUEST NO. 9:  Please provide any and all information obtained by the Company regarding individual home treatment of iron and manganese.  Has the Company ever considered individual home treatment as an alternative?  If so, please explain.  If not, why not?
REQUEST NO. 10:  Please provide a list of all customer water quality complaint site visits conducted by the Company.  If a water quality test was taken at the customer location please provide the results of the test, the location of the customer’s premises, and the well most likely providing the water.
REQUEST NO. 11:  Please provide any and all customer survey information collected by the Company regarding water quality.

DATED at Boise, Idaho, this              day of November 1996.
________________________
Scott Woodbury
Deputy Attorney General
Technical Staff:
Lynn Anderson
sw:la:gdk/uwiw966.swl/umisc/pr