20190417Cary Direct.pdf

ORIGINAL
ti:CElVEi)
iir;! EfR I 7 plf 3: L6
Michael C. Creamer, ISB #4030
GIVENS PURSLEY LLP
601 W. Bannock St.
P.O. Box 2720
Boise, ldaho 83701 -2720
Telephone: [phone]
Facsimile: 208-388-1 300
mcc@g ivenspu rsley. com
r)C
Aftomeys for Petitioner SUEZ Water ldaho lnc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF SUEZ WATER
IDAHO INC.'S PETITION FOR AN
EXEMPTION FROM UTlLIry CUSTOMER
RELATTONS RULES 311(4) AND (5).
Case No. SUZ-W-19-01
DIRECT TESTIMONY OF JARMILA M. CARY
APRTL 17,2019
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Please state your name and business address?
Jarmila M. Cary, 8248 West Victory Road, Boise, ldaho 83709.
By whom are you employed and in what capacity?
I am employed by SUEZ Water ldaho lnc. ("SUEZ" or "the
Company") in the capacity of Director of Finance.
How long have you been employed by SUEZ Water ldaho?
I have been employed by SUEZ since June 1997, with a brief leave
of absence from June 2008 through August 2009.
Briefly describe your responsibilities during your tenure.
I became Director of Finance in September 2015. As Director of
Finance, I have oversight over the Company's financial activities
including planning, variance analysis, operational reporting, payroll,
accounts payable, and development and monitoring of business
metrics. I participate in rate filings, monitor capital expenditure
investment, and define and implement changes in management
initiatives. I am also the key contact person within SUEZ's ldaho
Division for centralized functions such as accounting, audit, tax,
treasury and procurement.
ln l\Iarch 2018, my role expanded to include oversight of the
Customer Service Department.
Previously, I provided testimony before the ldaho Public Utilities
Commission in the Company's 2011 and 2014 general rate cases
on operating expenses and deferred debit amortizations.
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SUEZ
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From January 2003 until April 2013,1 was in a supervisory role as
Manager of Accounting.
During April 2013, accounting functions transitioned to the SUEZ
Corporate office. I assisted in formulating rate increase requests
and operating expense adjustments in the 2006 and 2009 general
rate cases.
From 1997 until January 2003, I was in a Senior Accountant role
performing general ledger accounting, planning functions, variance
analysis and preparing annual reports to the ldaho Public Utilities
Commission and the ldaho State Tax Commission.
What is your educational background?
I was granted a Bachelor of Science in Business, with a major in
Accounting, from the University of ldaho in December, 1996.
What is the scope of your testimony?
My testimony describes the scope of, and rationale for, SUEZ's
request for exemption from the provisions of Utility Customer
Relations Rules (the "UCRRs") 311 (04) and (05), as they relate to
customer contact requirements and accepting payments during
disconnection, and SUEZ's proposals to. 1) increase the non-
mandatory customer notices before discontinuance; 2) eliminate
customer Western Union payment processing fees; and 3)
eliminate accepting customer payments at the Company's office.
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Why does the Company feel it is necessary to request these
changes?
The Company seeks to address growing safety concerns for SUEZ
personnel who are required to accept payments and make faceto-
face contacts at a customer's premises before terminating service
under the UCRRS.
The Company seeks exemption from UCRR 311 (04) and (05) to
permit it to: a) discontinue collection of payments at the customer's
premises door during the disconnection process; b) use other forms
of customer notice in lieu of the mandatory on-site faceto-face
disconnection contact; and c) where advanced remote metering
service connection/disconnection technology is installed,
discontinue posting paper notices to the customer's premises door.
ln lieu of the UCRR requirements, the Company proposes to
increase the number of non-mandatory customer notices before
disconnection to provide customers with additional notice and
opportunities to avoid a service interruption.
The Company also proposes to waive the Western Union payment
processing convenience fees that customers currently incur who
pay their bill at Western Union payment locations, by telephone, or
online. SUEZ requests recovery of this cost.
To further reduce the risks to its employees and follow similar
practices approved for other larger regulated utilities in ldaho, the
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Company proposes to discontinue accepting payments at the
Company's office while promoting other convenient electronic and
automatic payment options.
My testimony also discusses the anticipated impact of the proposed
changes to the Company and its customers, reviews the disconnect
notifications customers currently receive, the historical customer
utilization rates of the various payment methods available to them,
and the planned efforts to inform customers regarding the
anticipated changes if the exemption request is approved.
ELIMINATION OF CUSTOMER CONTACT AND ACCEPTANCE
OF PAYMENTS !N OFFICE AND FIELD
Please summarize Utility Customer Relations Rule 311.
Briefly, Utility Customer Relations Rule 311 subsection (04)
requires that immediately preceding termination of service, utility
personnel must attempt to make face-to-face contact with the
customer and to accept payment on an outstanding bill at the
premises. Subsection (05) requires the utility employee designated
to terminate service to notify the customer in person or with a
conspicuously placed notice at the affected service address
outlining the procedure to reconnect service.
Utility Customer Relations Rule 311 (IDAPA 31.21.01.311)
subsections (04) and (05) are as follows:
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04. Opportunity to Prevent Termination of Service.
lmmediately preceding termination of service, the employee
designated to terminate service shall identify himself or
herself to the customer or other responsible adult upon the
premises and shall announce the purpose of the employee's
presence. This employee shall have in his or her possession
the past due account record of the customer and shall
request any available verification that the outstanding bills
are satisfied or currently in dispute before this Commission.
Upon presentation of evidence that outstanding bills are
satisfied or currently in dispute before this Commission,
service shall not be terminated. The employee shall be
authorized to accept full payment or, at the discretion of the
utility, partial payment and in such case shall not terminate
service. Nothing in this rule prevents a utility from
proceeding with termination of service if the customer or
other responsible adult is not on the premises.
05. Notice of Procedure for Reconnecting Service.
The utility employee designated to terminate service shall
give to the customer or leave in a conspicuous location at
the affected service address a notice showing the time and
grounds for termination, steps to be taken to secure
reconnection, and the telephone numbers of utility personnel
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1 or other authorized representatives who are available to
authorize recon nection.
Please describe the rationale for seeking the exemption from
UCCR procedures during the disconnection process.
The Company requests exemption from Utility Customer Relations
Rules ("UCRR") 311.04 and 31 1.05 under the provision of UCRR
Rules (003) and (009), which allows utilities to seek a rule
exemption when "unusual or unreasonable hardships result from
the application of any of these rules." The Company asserts that
good cause exists for exemption due to the growing concerns for
the safety of employees and customers when handling payments,
and to avoid potentially violent conflicts, during disconnection. The
Company asserts that application of the UCRRs is an unreasonable
hardship for the Company and its customers given the reasonable
alternatives available that can reduce safety risks and promote
deployment of modern metering technologies.
How can these safety concerns be addressed by granting the
exemption?
Safety concerns can be addressed by using available customer
communication channels other than the required face-to-face
contact or door postings, accepting payments through the variety of
other convenient payment options available to customers, using
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smart metering technology and allowing the Company and
customers to realize the efficiency benefits thereof.
Do the current rules 311.04 and 311.05, which require an
attempt to make face-to-face contact and collection of
payment at the premises, present safety concerns?
Yes. According to the United States Department of Labor
Occupational Safety and Health Administration [citation:
https.//www. os ha. g ov/S LTC/workplacevio lencel, notab le risks a re
associated with employees who deal directly with the public and
those who exchange money with the public Field employees who
carry money or collect money from customers have the potential to
experience a hostile interaction leading to serious injury or death.
Field employees who are known to collect payments, who work
alone, or who carry money in their vehicle or on their person, are
inherently at a higher risk of being attacked and robbed as they
travel their route. Also, businesses that handle and carry currency
are targets for criminal activity.
Does SUEZ have any record of employee physical altercations
with customers at their premises?
SUEZ ldaho employees have reported six altercation incidents over
the last several years. These incidents range from intimidation,
verbal threats, to more aggressive physical altercations. They
include people following the employee to their vehicle, standing
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1 over the employee as the service is being disconnected, leaning
into the employee's vehicle's open window and verbally intimidating
them, threatening to release or allowing aggressive dogs to chase
the employee, attempting to engage the employee in a fist fight,
poking the employee's chest, shoving the employee and
threatening to brandish a firearm.
What steps has the Company taken to mitigate safety risk to
employees performing disconnections and accepting
payments in the field?
Safety of employees, customers and the environment is at the
forefront of everything the Company strives to do. Avoiding high-
risk situations is always the most desirable course of action. To
address the safety risk, the Company provides training to all
employees based on the job classification and risk of exposure.
This training includes assessing hazards, developing safe work
plans, familiarity with policies, rules and regulations, practical and
effective communication, prevention of workplace violence as well
making various tools and resources available to employees.
Customer Service field employees are also trained on aggressive
dogs, conflict avoidance and resolution, de-escalation
methodologies, and how to be safe and remain alert while on route,
when working alone and in the evening. The Company gives all
employees the ability to exercise full authority to stop work they
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deem is unsafe or could cause harm, and to avoid situations where
safety is a concern.
Would eliminating the practice of face-to-face contact with the
customer and/or and collecting payment at the premises
during the disconnection visit reduce the risk of harm for
employees?
Yes. The Company is aware that stopping collection of payments
and stopping knocking at the door during a disconnection visit will
not remove all risk, but it is a pro-active step the Company believes
would reduce the opportunities for conflicts to arise and would
further SUEZ's continuing efforts to provide a safe workplace. Risk
of injury or death to employees due to confrontations should not be
an accepted cost of doing business, nor should it be part of a utility
employee's job description and requirements.
Are the Company's concerns limited to the risk of harm to
employees while at a customer's premises during a
disconnection?
No. There is reason for concern for the physical well-being of
employees, but also for the public that may be nearby at the time of
an incident. Field collection of customer payments also presents
the concern that personal banking information on a customer's
check may be used fraudulently if the payments are stolen while
the disconnecting employee is still in the field. Safeguarding
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customer payments and information are both important, but the
safety of customers and employees is paramount.
Please reference where such an exemption during
disconnection has been requested and granted.
ln Case No. GNR-U-14-01, the Commission granted a similar
exemption request to ldaho Power Company, Avista Corporation
and PacifiCorp DBA Rocky Mountain Power. Commission Order
No. 33229 found that "the Utilities (and their customers) face
unusual and unreasonable hardships under, and should be
exempted from, UCRR 311 .04 and .05 because those sections: 1)
heighten the safety risk to utility employees; and 2) preclude the
Utilities and their customers from realizing the benefits of modern
metering technologies."
!s SUEZ's request for exemption during disconnection
materially different from the exemptions granted in Case No.
GNR-U-14-01 ?
The Company is asserting "unusual or unreasonable hardships"
exist for SUEZ similar to those recognized by the Commission in
Case No. GNR-U-14-01. There, the Commission found that "the
knock-and-accept payment rule poses an unreasonable safety risk
for [the utilities'] field personnel." SUEZ's employees are subject the
same inherent safety risks when handling customer payments and
performing manual service disconnections.
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1 O. Please discuss the remote meters the Gompany is evaluating.
A. The Company is studying and testing remote capable meters and
pending a successful evaluation, would plan to continue
deployment of this technology. lf the exemption were not granted,
SUEZ would also "unnecessarily incur labor and transportation
costs that might othenrvise be avoided through the availability of
remote disconnection and reconnection" technology by being
required to adhere to the knock-and-accept payment rule or posting
notices to the premise door where advanced remote meters are
capable of performing the service connection/disconnection without
manual intervention in the field.
a. How does the Company's request differ from the electric
companies?
A. The Company's request for exemption differs from the electric
utilities in that in addition to proposing to cease accepting customer
payments in the field, SUEZ also is proposing to eliminate
acceptance of all payments at the Company's office.
To make this change easier for customers, SUEZ proposes to
eliminate the $1.00 to $1.99 Western Union payment processing
fee incurred by customers who use this payment method. The
Company would also increase the number of customer pre-
disconnect notifications beyond what is required by the UCCR to
help customers avoid service interruptions. Where remote
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disconnection of service becomes possible as the Company
deploys advanced metering technology, SUEZ requests exemption
from having to post notices to the customer's premises door.
What is the Company's current practice when notifying and
disconnecting a customer for nonpayment of their water bill?
The Company considers disconnection of service as a last resort.
However, when it is necessary to disconnect a customer's service
due to nonpayment, numerous notifications are made in an attempt
to avoid disconnection and interruption of service.
Existing customer notices prior to disconnection of service:
Bi!! - tMailed.
lnitial Reminder Notice (AR1) - Required, mailed at least 7
calendar days prior to termination.
Final Reminder Notice (AR2) - Required, mailed at least 3 days
prior to termination, excluding weekends and holidays.
Occupants who are not customers (Tenant) Notice - Required
(where applicable), delivered to property or common area at least 2
days prior to termination.
Final Televox Auto Dialer Call - Required in-person or phone
contact, at least 24 hours prior to termination.
Termination/Reconnection Notice (AR3) - Required, hand
delivered to property at time of disconnection of service.
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On the due date per the customer's final notice, a field Customer
Service Person is dispatched to the customer's premises to collect
payment or disconnect service. The employee attempts to speak
with the customer or responsible adult at the site by knocking on
the door. lf there is no answer, or if payment or a payment
arrangement cannot be made, the employee leaves a door hanger
with the required reconnection information and proceeds to
disconnect the service. SUEZ employees have discretion to
proceed with the disconnection or not depending on whether they
feel it is safe to do so, both for the customer and the employee.
lf the customer makes a payment at the time of disconnection in an
amount sufficient to void the disconnection order, the service will
remain on and a $15 Field Collection Trip Charge is collected or
added to the customer's next billing statement.
lf the service already has been disconnected and the customer did
not make payment at the time of disconnection, then after the
customer has settled the amount due and requested the service
reconnection, an employee will be dispatched back to the
customer's site to reconnect service. The customer's billing
statement will then reflect a $20 Reconnection Charge (during
normal business hours) or a $30 Reconnection Charge (other than
normal business hours) if requested after regular business hours,
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on a weekend or holiday, as authorized in the Company's tariff
Schedule No. 5, Jvliscellaneous Fees and Charges.
How many customers present a payment in the field at the
time of the disconnection site visit?
The graph below indicates the number and percentage of
customers who presented payment in the field at the time of the
disconnection visit between 1999 and 2018. The number of
payments presented in the field at disconnection has been
decreasing.
Number of Customers
presenting payments at disconnection visit
What percentage of customers have multiple disconnection
events?
Of the accounts in active collection status, approximately one third
of those accounts had more than one disconnection event, incurred
more than one field service payment collection charge or service
reconnect charge, and utilized the highest cost payment option.
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1999 2000 200L 2002 2003 2004 2005 2006 2007 2008 2009 20LO 20L1 2012 2013 2074 20t5 20t6 20t7 2018
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o.lf a customer makes a payment at the time of the
disconnection site visit, how does the Customer Service
Person process that payment?
The Customer Service Person (or Meter Reader) who receives the
payment in the field provides the customer a hand written receipt
for the amount of payment provided. The employee keeps the
payments in a locked vehicle until the end of their shift when
payments are delivered to and processed at the Company's office.
Payment information is updated in the Company's customer
information system immediately following delivery or on the
morning of the next business day.
lf the requested UCRR exemption is approved then when the
customer is home at the time of disconnection but indicates
they want to pay the bill, would the Customer Service Person
accept a payment?
No. lf the exemption is approved, then the Customer Service
Person would not accept a proffered payment in the field. The
Customer Service Person dispatched to perform the service
disconnection (where remote disconnection/connection technology
is not available) would post a disconnection notice to the premises
door, but would not knock on the door in an attempt to make a face-
to-face contact and/or accept customer payments. The employee
may at his or her discretion, wait for a few minutes and offer the
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customer the opportunity to make a telephone or on-line payment
to avoid the disconnection of service. Additionally, the Customer
Service Person will have the discretion to delay or void a
disconnection if they are made aware of or observe a situation
where they believe disconnection of service will be harmful to a
resident at the site.
You previously stated a customer making a payment at the
premises at the time of the disconnection is charged a $15 fee.
How does that compare with the costs of other payment
options available to customers?
Customers choosing to make their payment at the time of the
service disconnection are using the most expensive method to pay
their water bill. lf the customer waits to make a payment until the
Customer Service Person is at their home to disconnect services,
then the customer is charged a $15 field service collection charge.
The customer's cost for making payment other than at the time of a
disconnection visit range from $0 (if paid through ACH, ebill, US
Bank downtown using check, etc.) to $5.00 (if paid at US Bank
downtown using cash), depending on the option chosen. By
eliminating accepting payments in the field, the customer would
avoid the highest cost payment option.
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^/.3
O. Can the Company remotely disconnecUreconnect service
using an Advanced Metering lnfrastructure ("AMl") Smart
Meter technology?
A. The meters currently deployed by the Company contain a mix of
mechanical, digital, and radio frequency meters. The majority of
these meters do not have remote disconnection/reconnection
capability. However, the Company is continually evaluating
opportunities to improve efficiency, reduce costs and employ
developing technologies to better serve customers The Company
has acquired a test number of meters with connecUdisconnect
technology and is installing them at select locations-predominantly
residential or small commercial customer sites. These advanced
meters also have additional capabilities such as pressure and
temperature monitoring. Results of the meter performance test will
be evaluated for continued deployment potential as part of the
Company's overall meter replacement strategy. The replaced
meters in good working condition that also comply with the 2014
Lead-Free Safe Drinking Water law are able to be reused.
O. What criterion will SUEZ use to determine where remote
connecUdisconnect meters should be installed?
A. SUEZ is intending to deploy remote connecUdisconnect metering
capability at locations that are remote, difficult to access, where
temperature or pressure monitoring is desired, or locations that
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have had multiple connect-disconnect site visits, or where safety
generally is a concern. lMultiple field visits to certain locations are
primarily attributable to collection activity, payments collected at the
door, and disconnections for non-payment, but also involve
locations where frequent customer-requested connections and
disconnections have occurred. Where new meter technology is
installed, the Company will be able to remotely connecUdisconnect
service and avoid sending an employee to the location. The
employee could then be redeployed to perform other customer
service field and troubleshooting functions.
lf an exemption is granted, is there any concern that
customers would not be provided with adequate
disconnection notice before the disconnection site visit?
No. Disconnecting service for non-payment is always a utility's last
resort. SUEZ already provides customers with multiple notifications
of account balances and potential disconnection of service. The
existing billing and collection process provides customers with
numerous notifications using various communication methods prior
to the disconnection visit and gives the customer ample time to
arrange for a payment to be made before the Company visits the
site. lncluding the initial bill, the Company makes a minimum of five
notification attempts prior to service disconnection for non-payment.
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I INCREASI NG NON.MAN DATORY CUSTOMER NOT! FICATION
What changes to the customer notifications at disconnection
does the Company propose if the exemption is granted?
Suez proposes to increase the number of auto-dialer customer
notifications to help customers avoid a service disconnection and to
evaluate customer responses. The Company will add one
telephone notification before the required mailed notification - lnitial
Reminder Notice (AR1). The Company will evaluate whether this
additional courtesy notice is effective in reducing customer service
disconnections and investigate the effectiveness of varying dates
and times of the notices.
The current cost to the Company to place an automated call though
Televox averages between $0.12 and $0.15 per call. The Company
is investigating alternate technologies and service providers that
could potentially reduce this cost and offer the Company and
customers more options such as text messaging. lf the number of
calls placed increases, the Company's costs would increase, but
efficiencies gained by eliminating field payment collection visits
during manual disconnections and by no longer accepting
payments in the Company office are expected to help offset that
cost. The Company expects that increasing the number of
telephone notices should reduce the cost associated with the
printed and mailed disconnection notices. Depending on actual
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number of disconnects and customer responses to such, operating
costs should remain essentially unchanged.
What are SUEZ's customer payment method utilization rates?
The chart below illustrates the percentage of total customers who
have utilized the various available payment options over the five-
year period from 2014-2018. These include various Western Union
electronic payment options. The "Local Field Payments" category
represents payments made to employees outside of the office and
"Local Office - Cashiering" represents payments made at the SUEZ
Victory office by walk-in customers or the after-hours drop box.
Customer Payment M ethods
20L4-20L8
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tcll Offic. . Cathia.rnS (Wallnn & Nr8htdrop)..,
w6t?rn Unon ATM 2.lar6
wcrt.m Unon ACH 2.44X
wcrtcm Unpn ACH t.om e8rll 3.3616
wcrtc.n Uoon Cr.drl C.d 5,21t'6
Coll6ts A8ocv 0.07X
Lc.l t|ld P.yn6t3 0.05t6
Wcat?rn Union QuKk Collccr (C$h) 0.0396
Waitcrn UnroD ConE6[n<! Plyrrcot Ccntar 0.23%
: Mellon or Citibank Lockbox (Check Mailedl
r E-Pay (AcH Dircct Debit)
* LocalOffice (Mailed or US Bank)
. Western Union Credit Card
r Western Union ACH from eBill
, Wcstcro Union ACH
r Western Union ATM
r Local Office - Ca3hierint (Walk-in & Night-drop)
r Western Union Convenience Payment Centet
r Colhction Atency
. Loc.l Fi€ld Paymanti
r Western Union Quick Collea (Cashl
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12 How many customers present payments at the Company's
office?13
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LmlOtfc.
(M.ihd s US
B.n$ 9.05r(
Manoo frCrtibark
l*kbor (Clxk MriLd!
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E.Pry {ACH Drc<t Oct t}
12.5296
I A A small percentage of customers choose this payment option.
Based on the Company's analysis from 2014-2018, just 1 .67% of
all customer payments were presented at the SUEZ Victory office.
Of those, the majority were payments made by check. During
2013-2016, there were a total of 14,369 cash payments presented
at the SUEZ Victory office for that four-year period, with an average
cash payment amount of $75.99. The ovenvhelming majority of
customers who came to SUEZ's office to make payment during that
time, were from the immediately surrounding geographic area (i.e.,
within zip code 83709). For customer convenience and for after-
hours deposits, a drive up deposit box is currently available for
check payments. The drive-up deposit box payments are retrieved
each business day morning and applied to customer accounts
immediately, prior to any disconnection process.
What are the fees associated with the currently available
payment options?
Customer payment options and the associated third party fees:
. Field collection trip charge (at disconnection) $15.00
. US Bank (downtown Boise - cash) $ 5.00
. Call Western Union $ 1.99
. Pay on SUEZ website (credit card) $ 1.99
. Pay through ebill (credit card) $ 1.99
. Western Union Pay station (cash) $ 1.50
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a Western Union Pay station (check)
By US mail (first class stamp)
US Bank (downtown Boise - check)
Victory Road office (checks only)
Victory road night drop (check only)
E-pay direct debit (ACH)
Pay through ebill (ACH)
$ 1.oo
$ 0.50
no cost
no cost
no cost
no cost
no cost
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A.
ELIMINATION OF WESTERN UNION PAYMENT FEES
What payment convenience fees have the Company's
customers incurred using Western Union and what is the
company's proposa!?
The table below represents the number of Western Union
payments presented and the associated convenience payment
processing fees customers incurred for years 2013 through 2018.
Approximately 13% of customers over this timeframe used a
Western Union payment method. The NationalAssociation of State
Utility Consumer Advocates (NASUCA) issued Resolution 2012-07,
"Urging Utilities to Eliminate 'Convenience Fees'for Paying Utility
Bills with Debit and Credit Cards and Urging Appropriate State
Cary, Di
SUEZ
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Western Union 2073 2074 2015 2076 2017 2018
Total # Speedpay payments 61,594 70,288 76,782 91,675 94,226 98,578
Total fee # payments 41,031 49,846 54,171 63,4s9 66,714 70,177
Total fee amount (S)s 81,663 s 99,1e4 S 109,006 5 726,283 $ 132,761.s 138,451
Avg payment amount ($)577 576 574 s78 Szs 577
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I Regulatory Oversight" in 2012, outlining the rationale for eliminating
convenience fees.
Customers have expressed frustration with incurring convenience
fees as they have become accustomed to paying for goods and
services electronically by credit card and expect not to incur fees.
The Company recently surveyed SUEZ customers nationwide and
received 456 responses; 103 from ldaho. The number one
complaint received from customers is that they are unhappy
incurring payment processing fees.
The feedback for payment preferences includes:
o Preferred payment channel for customers is predominantly
online through the Company's website with only 1%
preferring to make a payment in person.
ln the future, through which channelwould you
prefer to make your payment?
7Oo/o
600/o
5Oo/o
40o/o
30o/o
20o/o
1Oo/o
Oo/o
Customers' preferred method of payment is by their bank
and in generalthey prefer one-time payments, followed by
crediUdebit card one-time and then automatic payments.
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rgt l%b 6o/o ryoI
ln the future, what would be your preferred
method of payment?
40o/o
35o/o
30o/o
25o/o
2Oo/o
15o/o
1Oo/o
5o/o
Oo/o
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Are there examples where other utilities have eliminated
"convenience fees" associated with customer payments?
ln Case AVU-E-16-01 Avista Corporation was authorized to defer
the costs incurred in offering a fee-free payment program and
recover them in a subsequent rate case. ln Commission Order
33494, the Commission found that eliminating the convenience fee
"will likely improve customer satisfaction and lead to cost savings
for all customers."
The Company anticipates that if convenience fees are eliminated,
customer use of electronic or convenience payments will likely
increase. However, the more convenient the Company can make it
for customers to pay bills, the more it benefits all customers.
Obviously, customers who pay on time and are able to take
advantage of the various payment options are the least expensive
to serve. Customers who do not pay on time and who are subject to
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SUEZ
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1 collections efforts use more call center and field service time and
increase Company costs, which are borne by all customers. The
Company recognizes that a number of its customers face a
constant struggle to stay current with their bills, but it also
anticipates that its proposed changes in collection and
disconnection practices will better serve all of its customers, help to
reduce direct costs to its less advantaged ones, and may reduce
overall Company costs associated with these activities. SUEZ
believes it is reasonable to offer customers additional payment
options without incurring convenience fees and that this cost should
be included in the overall cost of service for all customers.
How does the Company propose to account for the customer
Western Union payment processing fees it proposes to
absorb?
The Company proposes to waive the customer Western Union
payment processing fees by paying those convenience fees, on
behalf of its customers and capturing these costs in an operating
expense account and including this cost in future general rate
cases. The Company is also requesting that if this is granted, the
Company be authorized to defer the Western Union fees costs until
the next rate case and recover that deferred amount over three
years. Thereafter, it would become a normal operating expense.
Several SUEZ affiliate companies have already implemented such
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changes or are in the process of obtaining their Commissions'
approval to eliminate customer payment convenience fees and
recover that cost.
a.
DISCONT!NUANCE OF COMPANY OFFICE PAYMENTS
How does SUEZ justify discontinuing accepting payments at
its Company office?
There is no requirement that utilities accept walk-in or night drop-
box payments at their company office. Based on communications
with other utility company representatives, SUEZ understands that
ldaho Power does not accept customer payments at its company
office. lntermountain Gas Company has a drop box for customer
payments by check. SUEZ is not aware that these companies have
experienced any collection or customer service issues by not
accepting payment in their offices. SUEZ also believes that like field
collection of payments, there are safety risks when handling
payments, particularly cash. Eliminating acceptance of payments in
the field and in the Company's office would lower the risk of robbery
for customers and employees. Fufthermore, handling cash
payments is a more time intensive management process compared
to other payment options. Handling cash poses additional
challenges and employee time could be better used to address
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customer inquiries and concerns. Some of the established controls
necessary to handle and safeguard cash include:
. Time counting, making change, filling out cash receipts
. Securing cash drawers
. Balancing payments with checks and cash
. Cashing out at the end of the business day
. Supervisor time to recount cash and verify cash-out amount
. Obtaining proper denominations of cash/coin at bank
. Preparing cash deposits for armored car pick-up
ln light of the various payment options available and the low
percentage of customers who actually present payments at the
Victory office or at time of disconnection, the Company asserts that
there would be no undue hardship to customers if the ability to
present payments at the Company office or in the field was
discontinued.
lf approved, the Company would put a communication plan in place
to direct customers to the various other convenient payment
method options. The Company also proposes to cease accepting
payments in the field and at the Company's office over a four-
month period, providing fair notice of the coming changes to
customers.
How would this change impact cash only customers?
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SUEZ
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1 A.Customers who choose to pay with cash would still be able to do so
at the numerous available Western Union Quick Collect locations,
free of charge if Commission approved, or at the designated US
Bank downtown Boise branch for a small fee.
From 2013 to 2016, SUEZ received 2,452 checks from customers
that subsequently were rejected by their bank due to non-sufficient
funds ("NSF'). These NSF payments represent only 0.1% of all
payments the Company received over the same period. Customers
who attempt to pay with an NSF check are required to satisfy both
the amount due and a $20 Return Check Charge with cash,
certified check or money order.
The Company proposes to change its current NSF payment policy
and provide customers added options to pay by credit card and
other electronic payment options to settle an NSF payment.
What other payment options will continue to be available to
SUEZ's customers?
Customers will continue to have numerous options to pay such as:
mailing payments, e-pay direct debit ACH, eBill, Western Union
Credit Card, Western Union ACH, Western Union ATM, Western
Union Quick Collect kiosk locations and their own bank.
To make the proposed transition as convenient as possible for
customers, the Company proposes eliminating the Western Union
customer payment processing fees that are imposed when
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1 customers present payment online, via the telephone and also
when paying in person at a Western Union Quick Collect location.
The Company is also working with its vendor to continue offering
additional locations for payments and upgrade features while
lowering costs.
There are currently Tl Western Union payment locations within ten
miles of the Company's office zip code 83709, with 36 Western
Union Quick Collect cash payment locations. These payment
locations and the form of payments accepted can be obtained by
visiti ng tt/ySU EZWater. com.
lf the exemption is approved and payment processing fees are
eliminated, what payment fees would remain?
lf approved, customer payment optlons and the associated third-
party fees would be:
. US Bank (downtown Boise - cash) $ 5.00
. By US mail (First class stamp) $ 0.50
. CallWestern Union no cost
. Pay on SUEZ website (credit card) no cost
. Western Union Pay Station (cash) no cost
. Western Union Pay Station (check) no cost
. US Bank (downtown Boise - check) no cost
. E-Pay Direct Debit (ACH) no cost
. Pay through ebill no cost
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BENEFITS AND CONCLUSION
What benefits are expected if SUEZ's request for exemption is
granted during the disconnection process and payment
options at the Company's office and in the field are
eliminated?
The benefit will be a reduction to the safety risk employees face
when performing service disconnections and when accepting
payments in the field or at the office.
Eliminating the ability to pay at the door removes only the most
expensive payment option from the list. Eliminating the ability to
pay at the Company's office impacts only a small number of
customers from the immediate surrounding geographic area. lf
approved, however, customers will benefit by no longer incurring a
field trip collection fee or incurring Western Union payment
processing fees. They will have additional convenient payment
options at no additional charge. Customers will receive additional
notices before a service disconnection, which will give them more
opportunity to avoid service disruption.
How do customers who will have remote connecUdisconnect
capable meters benefit?
The primary change for customers at locations where remote
connecUdisconnect capable meters will be installed is that SUEZ
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I will no longer visit their location to connect or disconnect service,
and they will no longer have the opportunity to pay at their door to
avoid a disconnection for non-payment. The vast majority of SUEZ
customers rarely require a site collection or disconnection visit.
However, some customers have repeated on-site collection and/or
disconnection activity. Those are ideal locations where remote
meters would make the process more convenient for customers
and the Company.
For those customers who are facing a disconnection for non-
payment, the new process will be more predictable and timely. The
customer will know what day their service is subject to
disconnection and not have to guess when the SUEZ field
personnel will arrive. Unlike manual service disconnections,
disconnecting meters with remote capability will be on a specific
schedule. SUEZ plans to schedule remote disconnections for non-
payment early in the day so that customers have an opportunity to
make payment arrangements and reconnect service the same day
in most cases.
Predictability of disconnects and reconnects will result in a more
consistent process that can help customers easily manage these
situations. Additionally, the remote connecUdisconnect meter has
the ability to reconnect service much faster once payment is
received. SUEZ anticipates that customers with remote reconnect
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technology will experience reconnection within minutes rather than
the hours sometimes required for an employee to be dispatched
and travel to the customer's premises and manually reconnect
them.
The primary benefit of advanced metering technology for both the
Company and customers is increased safety in alerting customers
and the Company to potential backflow detection issues and
improved efficiency through an automated process rather than a
manually performed connection/disconnection function. As a result,
there will be fewer vehicles on the road, which will reduce
congestion and vehicle emissions, and customers will have more
privacy. The Company staff that normally would have been
dispatched to perform disconnection of service can be redeployed
to other customer service functions. Customers who have paid at
the door have been subject to a Field Trip Charge and, if this option
will no longer be available, customers will not incur this fee. ln
addition, through the implementation of At\Il smart meters,
customers with internet access will have detailed personal
consumption history available through their online account at
ttIySUEZWater.com and the ability to receive automated alerts
informing them through email or text message of potential leaks.
At\Il meter technology also alerts the Company of potential
backflow detection issues.
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What are the Company's customer communication and
education plans should the exemption be granted?
The Company does not wish to confuse or alarm the majority of our
customers that pay their bills on time and already use alternative
payment methods. SUEZ will target customers whose payment
records indicate that they previously have elected to pay at the door
before termination, paid late, or chose to pay at the Company's
office. Customers who pay on time do not respond favorably to
notifications regarding late payments. As they have expressed to
the Company, they take great pride in paying their bills early or on
time. To provide customers with sufficient communication regarding
the proposed changes, the Company proposes to continue
accepting payments in the field and Company office for a period of
four months following approval by the Commission, then stop the
practice.
lf approved, the Company would:
1) Modify the three collection notices SUEZ uses to collect on past
due bills.
2) Modify the prerecorded automated collection call (Televox) to
include these changes.
3) lncrease the Televox calls to customers and vary the call times
during the collection process. lf the customer answers the
automated call, voice mail records the call and if someone
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hangs up, the Company will not continue to make additional
calls. lf there is no answer and no answering machine, the
Company will make three attempts the same day, at around
noon, in the afternoon, and in the evening.
4) Post a lobby sign at its office advertising the approved changes
no-knock, no collections at the premises, and no cash accepted
at the office. This sign will remain in the lobby for a period of
one year and the exterior door will be posted with a notice that
customer payments are not accepted at this location.
5) Leave an informational card such as the example below
outlining approved changes, with the shut-off notice at the
customer's premises at the time of disconnection.
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1 Sample lnformation Card
2 @suea
Dear Valued Customer,
as of pr/rcy'mr, field service personnel will
no longer accept payments in the field or at the
Company's office 8248 West Victory Road.
Payments made through Western Union are now
free, at no additional charge.
SUEZ offers many convenient payment options
to pay your account.
. CallWestern Union at 1-888-608-6690 l24l7lo Go to www.mysuezwater.com to findo How to make payment via the web
o A nearby Western Union Pay Station
o A Western Union Quick Collect Stationo How to get set up for Direct Debit
o How to get set up for ebilling
. By mail (cost of stampl. Pay through your Ebill
lf you need to make a pay plan or need other
assistance, please call our customer service
department at (208) 362-73O4, Monday through
Friday, 8:00 a.m. to 4:30 p.m.
We have made this change for employee safety,
as well as for the security of your payments.
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We appreciate your patience and understanding.
Thank you for being a SUEZ customer.
6) Attach the above-mentioned information card (step 5) to
payment receipts given out in the office on Victory Road during
the four month moratorium period.
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I 7) lnform customers of approved changes when Company
Customer Service Representatives are discussing payment
plans or late payments.
8) Provide Customer Service field employees with training on how
to speak to customers about the approved changes.
9) I\Iodify the call on-hold messages customers hear when waiting
to speak to a Customer Service Representative.
10) lnclude a message on all prime bills for two complete billing
cycles (a four month period).
1 1) lnclude information on the approved changes on the Company
website at [VlySuezWater.com
Sample Bllfvlessage
As of xx/xx/xxxx, SUEZ will no longer be accepting payments in the
field for the safety of our employees and payments will no longer be
accepted at the 8248 West Victory office. lf you wish to make a
payment you may now do so free of charge at any Western Union
location, online or by contacting (PHONE NUMBER).
ttIySUEZWater.com will provide a listing of Western Union payment
locations.
The employee education plan will consist of the following:
1) Hold department meetings and discuss approved changes
before they are rolled out.
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2) Provide training and summary of changes for field and office
employees, on how to discuss changes with customers.
Has SUEZ consulted with any of its stakeholders regarding
this proposal?
Yes. On April 1 1,2019 SUEZ met with Commission Staff to discuss
this proposal. The Company also has visited with the executive
director of the Community Action Partnership Association of ldaho
("CAPA|") to discuss its proposal.
Does this conclude your testimony?
Yes it does.
Cary, Di
SUEZ
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