20190813final_order_no_34405.pdf

Office of the Secretary
Service Date
August 13,2019
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF SUEZ WATER IDAHO )CASE NO.SUZ-W-19-01
INC.'S PETITION FOR AN EXEMPTION )FROM UTILITY CUSTOMER RELATIONS )RULES 311(4)AND (5))ORDER NO.34405
On May 6,2019,SUEZ Water Idaho Inc.("SUEZ"or "Petitioner")filed a Petition'
making four requests for relief.First,SUEZ asked the Commission for an order exempting it from
the Utility Customer Relations Rules ("UCRR")311.04 and .05,IDAPA 31.21.01.311.04and 05.
Second,SUEZ requested that the exemption not become effective sooner than four months after
the Commission issues its order granting the exemption.Third,SUEZ asked the Commission to
approve SUEZ's proposal to waive all customer Western Union payment processing fees by
paying those convenience fees on behalf of its customers,and includingthis cost in future general
rate cases.Finally,SUEZ wished to modify Schedule 5 ("Miscellaneous Fees and Charges")of its
tariff to remove the $15.00 Field Collection Trip Charge.SUEZ asked that that the Commission
process its Petition by Modified Procedure.
On May 23,2019,the Commission issued a Notice of Petition and a Notice of Modified
Procedure that notified interested parties about the Petition and set deadlines for interested persons
to comment on the Application and for the Company to file a reply.See Order No.34339.
Commission Staff filed the only comments.No reply was filed.
Having reviewed the record,we now grant the Petition as discussed below.
THE PETITION
UCRR 311.04 and .05,IDAPA 31.21.01.311.04 and 05,require a utility employee to
try to make face-to-face contact immediately before terminating the customer's service for non-
payment to:(1)give the customer a final chance to avoid termination of service by paying the bill
at that time (see UCRR 311.04);or (2)if the customer does not pay at that time,notify the customer
about how the customer can have service reconnected.SUEZ explained in its Petition that it wants
the option of discontinuing payment at the door practices,and of notifying customers in ways
besides providing mandatory on-site personal or paper notice.Petition at 2.SUEZ seeks the
!SUEZ originally filed its Petition on April 17,2019.After consulting with Commission Staff,however,SUEZ filed
a modifiedPetition on May 6,2019 to clarify the scope of its requests.
ORDER NO.34405 1
exemption so it can use advances in metering,communication,and electronic payment
technologies to reduce operating costs and increase the safety of utility employees without
sacrificing customer service.Id.
SUEZ petitioned that the exemption not become effective sooner than four months after
the Commission issues its order granting the exemption.Id.at 3.This will give SUEZ time to
notify its customers of the approved changes to its customer notification,payment,and
disconnection process before the exemption becoming effective.Id.
Additionally,SUEZ petitioned the Commission to approve SUEZ's proposal to waive
all customer Western Union payment processing fees by paying the transaction fees on behalf of
its customers,and including this cost in future general rate cases.Id.SUEZ asked that it be
authorized to defer the Western Union fees costs until its next rate case and recover the deferred
amount over three years.Id.at 1.Thereafter,the processing fees would become a normal
operating expense.Id.at 4.
Finally,SUEZ asked to modify Schedule 5 ("Miscellaneous Fees and Charges")to
remove the $15.00 Field Collection Trip Charge.Id.This request is related to SUEZ's request to
be exempted from UCRR 31.21.01.311.04and .05.As SUEZ personnel would no longer accept
payments of past-due bills from a customer at the time of disconnection of service,the Field
Collection Trip Charge would be obsolete.
THE COMMENTS
Staff reviewed the Petition and supports all four of SUEZ's requests.No other
comments were filed,and no reply was filed.
Exemption from provisions of UCRR 311.04 and .05
Regarding SUEZ's request to be exempted from UCRR 311.04 and .05,Staff noted
that the Commission has granted an exemption to these rules for Idaho Power Company,Rocky
Mountain Power,and Avista.See Order No.33229.Staff supports SUEZ's plans for ensuring
customers have adequate notice and the ability to swiftly reconnect after a disconnection for
nonpayment.These plans include 1)making additional attempts to notify affected customers
regarding collection of past-due amounts and potential disconnection of service before a premise
visit by a SUEZ employee;and 2)deploying special smart meters that will allow SUEZ to
disconnect and reconnect service without actuallyhaving to make a premise visit at locations
where employee safety is at risk or there is a history of multipledisconnections due to non-
ORDER NO.34405 2
payment."Staff recognizes that there are safety risks associated with face-to-face interactions
between SUEZ's employees and customers during a premise visit to disconnect service.The
elimination of the need to do a final knock on the door,leave a notice,and/or collect payment
will help mitigate this risk."Staff Comments at 4.
Additionally,Staff recommended approval of SUEZ's request that the exemption not
become effective sooner than four months after the Commission issues its order granting the
exemption.
Elimination of $15 Field Collection Trip Charge,and reduction of Reconnection Charge where
remote metering is used
Staff supports SUEZ's request to eliminate its Field Collection Trip Charge from
Tariff Schedule 5."Staff agrees that the [charge]of $15.00 will become obsolete if the
Commission grants the requested rule exemption which will allow [SUEZ]personnel to no longer
accept payments in the field."Staff Comments at 5.As SUEZ's Petition did not include a revised
Schedule 5,Staff recommended the Commission order SUEZ to file a conforming tariff within
60 days of the Commission's order approving exemption from UCRR 311.04 and .05.
Additionally,Staff recommended that SUEZ's Reconnection Charge be reduced
where SUEZ has installed a meter with remote connect/disconnect capability.Currently,SUEZ
is authorized to collect a Reconnection Charge of $20.00 for reconnections during normal
business hours and $30.00 for reconnections outside of normal business hours.Staff
recommended that the Commission reduce the ReconnectionCharge by 50 percent,reflecting the
cost savings associated with not having to visit customer premises to disconnect and reconnect
service.This recommendation is consistent with the Commission's prior rulingin Case No.GNR-
U-14-01.See Order No.33229 at 11.If the Commission reduces the Reconnection Charge,Staff
recommended that it order SUEZ to file a conforming tariff within 60 days of the order reducing
the Reconnection Charge.
Western Union processing fees
Staff supports SUEZ's proposal to no longer require customers to pay convenience
fees to Western Union,SUEZ's third-party vender.If approved,SUEZ would assume
responsibility for the cost of handling Western Union payment transactions.Staff noted that the
Commission approved a similar request from Avista in Case Nos.AVU-E-16-01 and AVU-G-
16-01.See Order No.33494 at 3.Staff noted that eliminating the convenience fee for residential
ORDER NO.34405 3
customers will likely improve customer satisfaction and lead to cost savings for all customers.
"Convenience fees often have the greatest impact upon society's most vulnerable population,
including low-income individuals who struggle to meet the basic necessities of daily life."Staff
Comments at 7.Staff recommended that,provided SUEZ can keep its transaction costs low with
Western Union,"all transactions costs associated with receiving payment for services should be
included in base rates."Id.at 9.
Staff supports SUEZ's request to create a regulatory asset into which the costs
incurred to process payment transactions can be deferred.Staff recommended a deferral period
of up to three years,noting that "[t]his will allow [SUEZ]adequate time to file a general rate case
if cost recovery is at issue."Staff Comments at l1.However,Staff recommended that SUEZ not
be allowed a carrying charge.
Additionally,Staff recommended that SUEZ file semi-annual reports "outliningthe
number of customers using each payment method,the associated costs per transaction,and the
deferral balance of the regulatory asset as it accumulates."Staff Comments at 12.
Additional recommendations
Staff recommended that the Commission not allow SUEZ to defer legal expenses
associated with processing this case."Legal expenses are currentlyembedded in [SUEZ]'s base
rates it charges to customers,and without a comprehensive audit of [SUEZ]'s external legal
expenses for 2019,there is a risk of double recovery."Staff Comments at l 1.
Additionally,Staff recommended that the Commission not approve an amortization
period at this time,and that the more appropriate time for setting the amortization period would
be when SUEZ files a general rate case.
Finally,Staff supports SUEZ's plan to no longer accept payments at its local office.
Staff noted that SUEZ is not required to accept payments at its local office,and that "payments
can be made at over 70 Western Union locations free of charge if [SUEZ]'s request to remove
convenience fees is approved."Staff Comments at 9.
COMMISSION FINDINGS AND DISCUSSION
The Commission has jurisdiction over this matter under the Idaho Public Utilities
Law,including Idaho Code §§61-125,61-129,61-501,61-502,61-507,and 61-524.The
Commission has reviewed the record,includingthe Petition and Staff Comments.Based on this
review,we find it is fair,just,reasonable,and in the public interest to grant SUEZ's Petition by
ORDER NO.34405 4
exempting it from the requirements of UCRR 311.04 and .05,and approve SUEZ's proposed
practices under the exemption.Additionally,we approve SUEZ's requests that the exemption not
become effective for four months from the issue date of this Order,and that the $15 Field
Collection Trip Charge be eliminated from Schedule 5 of its tariff.
We find it reasonable to direct SUEZ to reduce its ReconnectionCharge where SUEZ
has installed a meter with remote connect/disconnect capacity.As SUEZ will not have to send an
employee to the premises to reconnect service in this situation,the cost incurred by SUEZ to
reconnect the meter will be less.Consistent with our prior ruling in Order No.33229,the
Reconnection Charge where SUEZ has installed a remote disconnect/reconnect meter shall be 50
percent of SUEZ's current Reconnection Charge.
Additionally,we approve SUEZ's request to assume responsibility for the cost of
handling Western Union transaction costs.The Commission approves this request with some
trepidation,however,as it continues to adhere to the principles of cost causation.We also expect
cost reductions in other areas to offset at least a portion if not all of these transaction costs.While
we have approved similar requests in the past,we are increasingly concerned that making all
ratepayers bear the cost of transaction fees they might have otherwise avoided by using a different
payment method is inconsistent with the principles of cost causation to which we adhere.In this
particular case,we are willing to approve SUEZ's request because the projected cost to SUEZ
for bearing the transaction costs is fairly small (and thus will not significantlyaffect rates),and
because we have granted similar requests in the past.We continue to evaluate,however,whether
socializing transaction costs is consistent with cost causation principles.
SUEZ may defer for up to three years the costs incurred to process payment
transactions.This will give SUEZ adequate time to file a general rate case.No amortization
period shall be set until SUEZ asks to recover the regulatory asset as part of a general rate case.
We expect Suez to reflect reduced costs not only in the test year for the general rate case,but to
show associated cost reductions that can be quantified in the regulatory accounts during the
deferral period.We find it reasonable to direct SUEZ to file semi-annual reports outlining the
number of customers using each payment method,the associated cost per transaction,and the
deferred balance of the regulatory asset as it accumulates.
ORDER NO.34405 5
Finally,we do not allow SUEZ to defer legal expenses associated with processing this
case.As noted by Staff,legal expenses are already embedded in SUEZ's base rates it charges to
customers.
ORDER
IT IS HEREBY ORDERED that Suez's Petition is granted;effective December 8,
2019,SUEZ shall be exempted from the requirements of UCRR 311.04 and .05,and their proposed
practices under that exemption are approved.
IT IS FURTHER ORDERED that the $15.00 Field Collection Trip Charge will be
removed from Schedule 5 of SUEZ's tariff on December 8,2019.SUEZ shall file a conforming
tariff with this Commission within sixty (60)days of this Order.
IT IS FURTHER ORDERED that SUEZ's Reconnection Fee in locations where SUEZ
has installed a meter capable of disconnecting and reconnectingremotely shall be reduced by fifty
(50)percent.SUEZ shall file a conforming tariff within sixty (60)days of this Order.
IT IS FURTHER ORDERED that SUEZ may discontinue collecting convenience fees
from customers by its third-partyvendor,Western Union,and may pay the transaction fees.The
cost incurred by SUEZ may be deferred for a period up to three years.No carrying charge is granted
to SUEZ on the amount deferred.
IT IS FURTHER ORDERED that SUEZ shall file a report with the Commission every
six months outliningthe number of customers using each payment method,the associated cost per
transaction,and the deferred balance of the regulatory asset as it accumulates.
THIS IS A FINAL ORDER.Any person interested in this Order may petition for
reconsiderationwithin 21-days of the service date of this Order with regard to any matter decided
in this Order.Within seven days after any person has petitioned for reconsideration,any other
person may cross-petition for reconsideration.See Idaho Code §61-626.
ORDER NO.34405 6
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this
day of August 2019.
PALÍL KJELLLA E RESIDENT
KRIS E RAPER,COM SSIONER
ERIC ANDERSON,COMMISSIONER
AT
ane M.Hanian
Commission Secretary
I:\Legal\WATER\SUZ-W-19-01\Orders\SUZW1901_Final_mh.docx
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