20221007Veolia to Staff 1-5.pdf

PrestonN. Carter,ISB No. 8462
Morgan D. Goodin, ISB No. I1184
Givens Pursley LLP
601 W. Bannock St.
Boise, D 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarter@ sivenspursley. com
moreansoodin@ eivenspursley. com
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Attornqts for Yeolia Water ldaho, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
TO AMEND BRIAN WATER SURCHARGE
AND REFUND CUSTOMERS.
CaseNo. VEO-W-22-03
Vrom WnrER Iolno, INc.'s
Respousps ro Fm.sr pRoDUCTIoN
RnquEsr or ruE CouurssroN Srarr
Veolia Water ldaho, Inc. ('Veolia" or "Company''), in response to the First Production
Request of the Commission Staff to Veolia Water Idaho, Inc. dated Septe,mber 16,2022, submits
the information below. The requested documents will be provided under the tenns of the
Protective Agreernent.
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yEoLIA WATER IDAIIO, INC.
cAsE vEo-w-22-03
FrRST PRODUCTION REQUEST OF THE COMMTSSION STAIF
Preparer/Sponsoring Witness: J.Cary
REOUEST NO. 1:
Please provide a list of all customers that are eligible for the credit and or refund, the principal
balance still owed, and whether they pay monthly or bi-monthly.
RESPONSE NO. 1:
Please see the attached list, which is filed as confidential per Commission rules. Based on
inforrnation as of Septemb er 23 , 2022, customers are eligible for a refund if they made a Brian
Subdivision Surcharge installment payment between October 2018 and such time as the
surcharge rate is modified by the Commission. The Company's billing system does not reflect a
principal balance still owed by the customer, or premise. However, based on the surcharge
payment table and the number of installment payments made, including any pay-offamounts
made to date, file Brian Subdivision Surcharge CONFIDENTIAL Response to Request No
l.xlsx will show customers eligible for refund, the calculated principal balance still owed, if any,
and the customer's payment frequency. The file will also show the amount of surcharge
payments (principal plus interest) made to date as of September 23,2022 and the amount of
surcharge interest overpaid (calculated as $2.87 per each $141.35 installment palmrent made),
plus any extra installment overpayments made to date through September 23,2022, the amount
of additional interest the Company intends to refund to customers to make them whole, and the
total amount of credit to be refunded to customers. Please note that customers making additional
surcharge paynents which will be billed during the month of November and going forward until
the surcharge is changed, the amount of refund due will change due to the interim billing
activities.
VEoLLA WATER IDAHo, INC.'S REspoNSEs ro FR.sr PRoDUcTIoN
REeUEST oF THE CoMMrssroN SrRrr
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vEoLIA WATER IDAHO, INC.
cAsE yEo-w-22-03
FrRST PRODUCTTON REQUEST OF TIrE COMnIISSTON STAIT'
Preparer/Sponsoring Witress:J.Cary
REOTJEST NO.2:
The Company's Application states that it "will provide credits on customer bills in the arnount of
the customer's surcharge overpaynent, including interest at a rate of 2%o, which is the amount of
interest on customer deposits." Does the Company propose to apply the credit to the customers'
monthly water bill, or to the principal balance still owed by the customer for Schedule No. lC -
Brian Water Surcharge?
RESPONSE NO.2:
The Company intends to include the2o/o calculated additional interest and apply it to the amount
of overpalment. The total amount to be refunded is reflected in the file accompanytng Response
to Request No. 1.
VrolnWarrR IDAHo, INC.'S REsPoNsEs ro FIRSTPRoDUcTIoN
Rnqursror nrn Comutsslox Surr
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YEOLIA WATER IDArrO, rNC.
cAsE vEo-w-22-03
FrRST PRODUCTION REQT EST OF TIrE COMMTSSTON STAIT'
Preparer/Sponsoring Witress: J.Cary
REOUEST NO.3:
If the credit will be applied to the customers' monthly water bill, did the Company consider
applying the credit to any unpaid principal balance for Schedule No. 1C - Brian Water Surcharge?
RESPONSE NO.3:
No. The Company believes the amount of the overpaynent should be refunded to customers,
including interest, as described in Response to Request No. 2 for the benefit of the customer.
Additionally, the Company's billing system does not reflect a principal balance still owed by the
customer, which is a manual process, and therefore it is administratively more efficient to credit
the customer bills to refund the surcharge and interest, and correct the surcharge amount billed
going forward.
VEoLr.A WATER IDeHo, INc.'s RsspoNsEs ro FRsrPRoDUcrIoN
RseuEsr or rHr CouurssloN Srerr
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vEoLIA WATER IDAHO, INC.
cAsE vEo-w-22-03
FIRST PRODUCTION REQ[TEST OF TrrE COMMTSSTON STAFF
Preparer/Sponsoring Witress: J.Cary
REOI]EST NO.4:
Does the Company have a contingency plan for returning the overpaynent to former customers if
those customers cannot be located?
RESPONSE NO.4:
The Company has a last known address for all former Brian Subdivision customers. None of the
customer notification letters that were mailed by the Company to the last known address advising
customers of this proceeding have been retumed as undeliverable. Accordingly, the Company
expects that all fonner customers will receive their checks. If a refund check is returned by the
US Postal Service, the Company staffwill make every effort to contact the customer via phone
numbe(s) listed on their account and email address(es). Uncashed refund checks after a period
of time, will escheat to the State of Idaho as unclaimed property.
VEoLTA WATER IDAHo, INC.'S RESPoNSES To FRsr PRoDUCTIoN
Rrquesr or rnr CouurssloN Srerr
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vEoLIA WATER IDArrO, INC.
cAsE vEo-w-22-03
FrRST PRODUCTTON REQUEST OF TIrE COMMTSSION STAIT'
Preparer/Sponsoring Witness: J.Cary
REOT]EST NO.5:
Did the Company consider any other options on how to retum the overpaynent to customers? If
so, please explain those options and why the Company chose a bill credit as the appropriate means
to refund the overpayurent.
RESPONSE NO.5:
The Company considered issuing a refund check to all impacted customers. However, the
Company decided to offer a bill credit because it ensures that customers will receive the amount
due in the most expedient way possible. By providing a bill credit, the customer receives the
money expeditiously and does not have to contend with a physical check which, for some, may
require a visit to their bank when ordinarily they do not make such trips. By issuing a bill credit,
administrative issues,like lost checks, significant delays in checks being cashed etc. are avoided.
Additionally, the Company's billing system includes the most up to date information provided by
customers. Refund checks remain the most efficient way to provide refunds to former customers.
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Pece 6 or 8
DATED: October 7,2022
By:
Vrorl{ WerER IDAHo, INc.'s REspoNsEs ro Fnsr PnoDUCTToN
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Preston N. Carter
Givens Pursley LLP
Attornqtsfor Yeolia Water ldaho, Inc.
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CERTIXICATE OF SERVICE
I IIEREBY CERTIFY TIIAT on October 7,2022,I caused a ttre and correct copy of the
foregoing to be servod upon the following parties as indicated below:
JanNoriyrki
Commission Secretary
Idaho Public Utilities Commission
F.O. Box 83720
Boise, Idaho 8372A-007 4
i an.noriyuki@nuc. idaho. gov
[e-mail]. eov
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U.S. h[ail
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PrestonN. Carter
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