20190517 Decision Memo.pdf

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DECISION MEMORANDUM
TO COMMISSIONER KIELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:MATT HUNTER
DEPUTY ATTORNEY GENERAL
DATE: M.ay 9,2019
SUBJECT:PETITION OF SUEZ WATER IDAHO INC. FOR EXEMPTION TO
UTILITY CUSTOMER RELATIONS RULES 311.04 AND .05, APPROVAL
oF WAMR OF PAYMENT PROCESSING FEES, AND REMOVAL OF
FIELD COLLECTION TRIP CHARGE FROM TARIFF, CASE NO. SUZ.
w-19-01
On April I'1,2019, SUEZ Water Idaho Inc. ("SUEZ") filed a Petition with the
Commission. After consulting with Staff, SUEZ filed an Amended Petition on May 6,2019 to
clarify the scope of SUEZ's requests. The Amended Petition makes four requests for relief.
First, SUEZ petitions the Commission for an Order exempting them from Utility
Customer Relations Rules 311.04 and.05l,31.21.01.311.04 and.05. In summary, these rules
require a utility employee to try to make face-to-face contact immediately before terminating the
customer's service for non-payment to: (l) give the customer a final chance to avoid termination
of service by paying the bill at that time (see UCRR 31 1.04); or (2) if the customer does not pay
at that time, notify the customer about how the customer can have service reconnected. SUEZ
explains 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. SUEZ seeks the
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.
1DECISION MEMORANDUM
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Second, SUEZ petitions that the exemption not become effective sooner than four
months after the Commission issues its Order granting the exemption. This will give SUEZ time
to notify its customers of the approved changes to its customer notification, payment, and
disconnection process prior to the exemption becoming effective.
Third, SUEZ petitions 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 including this cost in future general rate cases. SUEZ summarizes its third-
party payment processing fees as follows:
SUEZ asks that it be authorized to defer the Western Union fees costs until its next rate case
and recover the deferred amount over three years. Thereafter, the processing fees would become
a normal operating expense.
Finally, SUEZ petitions to modify Schedule 5 ("Miscellaneous Fees and Charges")
to remove the $15.00 Field Collection Trip Charge. This petition is related to SUEZ's petition
to be exempted from UCRR 31.21.01.311.04 and.05. As SUEZ personnel would no longer
accept payments of past-due bills from a customer at the time of disconnection of service, the
Field Collection Trip Charge would be obsolete.
SUEZ requests that the Commission process the case under Modified Procedure.
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Payment Option Current Charge Proposed Charge (if Petition
approved)
US Bank (downtown Boise - cash)$s.00 $5.00
Call Western Union $ 1.99 No cost
SUEZ website (credit card)$ 1.e9 No cost
eBill (credit card)$1.99 No cost
Western Union Pay Station (cash)$ 1.s0 No cost
Western Union Pay Station (check)$ 1.00 No cost
US Mail (first class stamp)$0.50 $0.50
US Bank (downtown Boise - check)No cost No cost
Victory Road office (checks only)No cost No cost
Victory Road night drop (check only)No cost No cost
E-pay direct debit (ACH)No cost No cost
eBill (ACH)No cost No cost
DECISION MEMORANDUM
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STAFF RECOMMENDATION
Staff recommends that the Commission issue a Notice of Application and Notice of
Modified Procedure setting a July 18, 2019 comment deadline, and a July 25, 2019 reply
deadline.
COMMISSION DECISION
Should the Commission issue a Notice of Application and Notice of Modified
Procedure setting a July 18, 2019 comment deadline, and a July 25,2019 reply deadline?
fo,Matt unter
Deputy Attorney General
I:\Legal\WATER\SUZ-W- I 9-0 I \SUVW I 90 I -mh.doc
JDECISION MEMORANDUM