20141114PAC to Staff 1-17.pdf

ROCKY MOUNTAIN
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201 Soudr Main, Suite 2300
Salt Lake City, Utah 84lll
November 14,2014
Jean Jewell
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-5918
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RE: ID GNR-U-14-01
IPUC Data Request (1-17)
Please find enclosed Rocky Mountain Power's Responses to IPUC Data Requests 1-17.
If you have any questions, please feel free to call me at [phone].
Sincerely,
dT*rt {t/er i*g,/a, ---r-
J. Ted Weston
Manager, Regulation
GNR-U- I 4-0 I /Rocky Mountain Power
November 13,2014
IPUC Data Request 1
IPUC Data Request I
For calendar year 2013, please provide the number of field disconnection visits
made to the premises of customers. How many of these visits were made to non-
residential customers?
Response to IPUC Data Request I
There were 3,870 field disconnection visits. Of the 3,870 field disconnection
visits, 1,001 were for non-residential customers.
Recordholder: Jason Hoffman
Sponsor: Barbara Coughlin
GNR-U- I 4-01/Rocky Mountain Power
November 14,2014
IPUC Data Request 2
IPUC Data Request 2
For calendar year 2013, please provide the number of customers who had field
disconnection visits made to their premises two or more times. How many of
these customers were non-residential customers?
Response to IPUC Data Request 2
There were 688 customers with 2 or more disconnection visits. Of the 688
customers, 162 were for non-residential customers.
Recordholder: Jason Hoffman
Sponsor: Barbara Coughlin
GNR-U-I 4-01 /Rocky Mountain Power
November 14,2014
IPUC Data Request 3
IPUC Data Request 3
For calendar year 2013 , please provide the number of (a) residential customers
and (b) non-residential customers who paid at the door at the time of the
disconnection visit.
Response to IPUC Data Request 3
421
l0l
Recordholder: Jason Hoffman
Sponsor: Barbara Coughlin
(a)
(b)
GNR-U- I 4-0 I /Rocky Mountain Power
November 14,2014
IPUC Data Request 4
IPUC Data Request 4
For calendar year 2013, please provide the number of scheduled disconnections
that were cancelled by an on-site employee who had concerns about the impact of
disconnection on the customer's health and/or safety.
Response to IPUC Data Request 4
When a situation such as this occurs, the Rocky Mountain Power employee will
leave a notice with the customer and enter a "notice left" code into their work
management system. Rocky Mountain Power does not have a specific order
cancellation code for tracking such specific conditions as health and/or safety.
All employees scheduled to perform disconnections have been trained to identify
potential life threatening conditions and make a determination on-site if power
should be disconnected.
Recordholder: Cory Estlund/Larry Blaine
Sponsor: Barbara Coughlin
GNR-U- I 4-0 1 /Rocky Mountain Power
November 14,2014
IPUC Data Request 5
IPUC Data Request 5
Please provide the number of call attempts routinely made by the Company to
each affected customer prior to disconnection of service.
Response to IPUC Data Request 5
The Company attempts to reach customers by phone once before the past due
balance is due. Customers who have made the Company aware of a life
threatening medical condition receive two (2) attempts by phone prior to
disconnection of service.
Recordholder: Barbara Coughlin
Sponsor: Barbara Coughlin
GNR-U- 14-01/Rocky Mountain Power
November 14,2014
IPUC Data Request 6
IPUC Data Request 6
What steps has the Company taken to validate the telephone numbers it has on file
for customers?
Response to IPUC Data Request 6
Customer telephone numbers are validated when a customer calls the Company.
The phone number that is presented on caller [D is validated with the account for
a match; if it is not a match (the customer may use a different phone) the customer
is asked if the phone number on file is current or needs to be updated.
Recordholder: Stacey Davis
Sponsor: Barbara Coughlin
GNR-U- I 4-0 l/Rocky Mountain Power
November 14,2014
IPUC Data Request 7
IPUC Data Request 7
Does the Company electronically notifu customers of pending disconnection of
service? If so, please explain: (1) how the notification occurs (timing, whether by
e-mail or text message, etc.); and (2) whether electronic notification is in addition
to or in lieu of sending written notices via US Mail.
Response to IPUC Data Request 7
For those customers who have chosen to receive their bills eleotronically (referred
to as paperless billing customers), Rocky Mountain Power e-mails the initial (7
day) notification of pending disconnection of service. Rocky Mountain Power
also sends a second e-mail 2 business days prior to the due date of the
disconnection notice; this is in addition to mailing the Final Notice. Below is a
table of the notices broken out by Paperless Billing Customers and Paper Billing
customers.
*Customers known to have a life threatening medical condition receive an additional
outbound telephone call and site visit by a metering manager prior to disconnection of
service.
Recordholder: Barbara Coughlin
Sponsor: Barbara Coughlin
Notice Requirements Paperless Billing
Customers
Paper Billing
Customers
304.0r Initial Notice 7
calendar days before
date of termination
E-mail past due notice Mail past due notice
304.02 Final Notice
. May mail final
written notice
3 calendar dayso At least24
hours before
the utility shall
diligently
attempt to
contact the
customer
affected either
in person or by
telephone
Outbound automated
phone call*
Mail final notice
48 hour door hanger
left at site
E-mail reminder two
days prior to due date
New - With opproval of
this waiver, RMP will add
an additional automated
outbound call after the 48
hours door hanger is left
at the site.
Outbound automated
phone call*
Mail final notice
48 hour door hanger
left at site
New - ll/ith approval of
this waiver, RMP will
add an additional
automated outbound call
after the 48 hours door
hanger is left at the site.
GNR-U- l4-0 l/Rocky Mountain Power
November 14,2014
IPUC Data Request 8
IPUC Data Request 8
Please provide the current cost of a visit to a customer premise in ldaho for the
purpose ofdisconnecting and reconnecting service? Is there a difference in cost
between a disconnection visit and a reconnection visit?
Response to IPUC Data Request 8
The approximate cost to the Company for a visit to disconnect is $12.08.
The approximate cost to the Company for a visit to reconnect is $35.77.
These costs reflect the travel and work duration time associated with a
disconnection of service for non-payment and a daytime reconnection performed
by a field metering specialist. Further analysis would be required to determine
exact 2013 costs based on other employees performing the work, i.e., a lineman
joumeyman performing a reconnection at the pole would be charged at a different
wage rate and the time spent performing the work would also be different.
Recordholder: Jason Hoffinan
Sponsor: Barbara Coughlin
GNR-U- 1 4-0 I /Rocky Mountain Power
November 14,2014
IPIJC Data Request 9
IPUC Data Request 9
If the requested rule exemption is approved, under what circumstances will the
Company's employees accept payment from a customer during the employee's
visit to the customer's premises?
Response to IPUC Data Request 9
If the rule exemption is approved, Rocky Mountain Power employee will no
longer accept any payment during a disconnection visit at the customer's
premises. Field metering specialists are allowed to use some discretion when
visiting the site to disconnect as to whether they will complete the disconnection
of service or delay the disconnection to allow the customer time to make a
payment at a pay-station, by telephone or through the web site.
Recordholder: Larry Blain
Sponsor: BarbaraCoughlin
GNR-U- I 4-0 l/Rocky Mountain Power
November 14,2074
IPUC Data Request 10
IPUC Data Request 10
The Petitioners have expressed concem about employee safety and the risk posed
by knoeking at the door before disconnecting service and accepting payment in
lieu of disconnection. Assuming that the degree of risk varies from customer to
customer, what factors (e.g., customer behavior, payment history, service
location, etc.) increase risk? Please also provide: (1) a copy of any risk analysis
or formal study that has been performed by or on behalf of the Company; and (2)
any other evidence on which the Company bases its concerns about employee
safety and risk.
Response to IPUC Data Request l0
(l) Rocky Mountain Power conducted an informal study with utilities who
are members of the National Association of Credit Managers to determine current
best practices related to knocking and collecting at the door. Based onthe
information gathered from the responses, more than half of the utilities do not
knock on the door prior to disconnecting service and nearly 75 percent did not
collect payment. See Attachment I in the Joint Utility Petition Case No. GNR-U-
14-01.
(2) Multiple governmental agencies have researched workplace violence and
provided useful information and statistics regarding workplace violence,
including identification of factors leading to higher risk of violence to
occur. Such research identified notable risks to employees dealing with public
and exchanging money with the public. These agencies include the Occupational
Safety & Health Administration (OSHA), the National Institute for Occupational
Sat'ety & Health (NIOSH), U.S. Department of Labor, the U.S. Department of
Justice and the Federal Bureau of Intelligence (FBI). Further, OSHA's general
duty clause requires employers to furnish each employee a place of employment
free from recognized hazards that can be considered harmful to an employee.
Company employees dispatched to disconnect a customer's electrical service have
the potential to experience a hostile interaction leading to injury, or even worse,
death.
Recordholder: Jason Hoffman
Sponsor: Barbara Coughlin
GNR-U- I 4-0 l/Rocky Mountain Power
November 14,2014
IPUC Data Request l1
IPUC Data Request 1l
For calendar year 2013, how many documented, customer-related safety incidents
have occurred when a Company employee has visited a customer's home for the
purpose of disconnecting the customer? Please provide a breakdown of the types
of incidents.
Response to IPUC Data Request I1
Rocky Mountain Power had zero incidents in 2013 where a customer-related
safety incident occurred with a Company employee at the customer's home.
Rocky Mountain Power's request is a pro.active approach towards minimizing
risk and providing a safer workplace. The Company recognizes the change in
policy does not remove all risk for company employees. Rocky Mountain Power
currently has nine sites where aggressive customer behavior has been documented
with three sites requiring police escort. Customers have threatened to shoot
collectors who arrive to disconnect power. Unfortunately, unlawful and violent
behavior does not always come with a warning and removing employees from
potentially confrontational situations may save their lives.
Recordholder: Jason Hoffman
Sponsor: Barbara Coughlin
GNR-U- 1 4-0 I /Rocky Mountain Porver
November 14,2014
IPUC Data Request 12
IPUC Data Request 12
If the requested rule exemption is granted, will the Company implement a
uniform "no-knock, no payment at the door" policy for all customer classes
(residential, small commercial, large commercial, industrial, and agricultural)?
Are there particular circumstances under which the policy will apply, e.g.,
premise visits for the primary purpose of disconnecting service for non-payment,
or will the policy apply regardless of the reason for the premise visit? Does the
policy apply to a particular subset of customerS, e.9., customers who have been
disconnected 2 or more times in a 12 month period? Please explain to whom the
policy will apply.
Response to IPUC Data Request 12
If the requested exemption is granted Rocky Mountain Power would not collect
payment from any customer, in any customer class, during a disconnect visit.
For commercial and industrial customers, disconnecting certain load at specific
times without advance notice could lead to dangerous equipment failure or
danage. As such, field metering specialist will attempt to talk to the owner or
individual in charge at the time of the disconnection to let them know the service
will be disconnected. This will allor.v an opportunity to turn off equipment. (The
Company would not collect payment.)
The policy would apply uniformly for all non-residential customers and will not
apply to only a subset of customers. Further, the policy only applies to
disconnection visits for non-payment and does not include service calls, meter
tests, safety disconnections or other field activities which may require
disconnection of service,
Recordholder: Larry Blain
Sponsor: Barbara Coughlin
GNR-U- I 4-0 I lRocky Mountain Power
November 74,2014
IPUC Data Request 13
IPUC Data Request 13
Does the Company contend that customer field visits, for the primary purpose of
disconnecting service for non-payment, pose the greatest safety risk to
employees? Do customer field visits for other reasons also pose a safety risk?
Has the Company determined that leaving a door hanger at the site 48 hours prior
to disconnection does not pose a safety risk to employees?
Response to IPUC Data Request 13
The Company's position regarding customer field visits made for the primary
purpose of disconnecting service for non-payment is they create a potential
adversarial situation and inherently a potential safety risk to an employee.
Interaction with customers whose power is going to be shut off poses a threat to
the employee. Customers have become upset and threatening during field visits.
The Company does not knock when delivering a 48 hour door hanger. This
approach has reduced the opportunity for confrontation with upset customers.
The 48 hour door hanger is an additional reminder to customers that absent
payment their service will be disconnected.
fhe Company also has concems that field personnel carrying money with them
throughout the day increases their risk for harm. There is also the risk for theft of
the payments collected, and that customer financial account information can be
stolen and fraudulently used.
The Company believes our customers are better served through the call center
than sending a collector to the door. Call center representatives have much more
information and resources available to assist a customer.
Recordholder: Larry Blain
Sponsor: Barbara Coughlin
GNR-U- I 4-0 I /Rocky Mountain Power
November 74,2014
IPUC Data Request 14
IPUC Data Request 14
If the requested rule exemption is granted, Idaho Power plans to make field visits
during the winter moratorium to knock on the customer's door before
disconnecting the customer for nonpayment, regardless of meter type. Has Rocky
Mountain considered taking that step as well in its service territory? Does the
Company prefer to establish a consistent no-knock policy throughout the year?
Response to IPUC Data Request 14
The Company has requested exemption to UCRR 31 I to establish a consistent no-
knock policy for residential customers throughout the year. Implementing a
policy where the Company is knocking part of the year would reduce the overall
effectiveness of this initiative. This will allow Company employees to be
consistent with their approach and will give customers confidence in how the
Company conducts business. A change in process during the year could result in
confusion, and an increase in customer frustration after the Company stops
knocking after the moratorium.
Recordholder: Larry Blain
Sponsor: Barbara Coughlin
GNR-U- I 4-0 I /Rocky Mountain Power
November 14,2014
IPUC Data Request l5
IPUC Data Request 15
In her testimony, Company witness Coughlin states that "In 2013, 1050 payments
were collected by field metering specialists in Idaho." See page 7 , line 21 , how
much money was collected? How much of that total amount collected was for
payment of the $20 field service collection charge?
Response to IPUC Data Request 15
Rocky Mountain Power field metering specialists in ldaho recorded payments
made by customers of $7 I I ,089 in 201 3 . A quick review of the largest 20
payments collected indicates they were payments towards non-residential
accounts and accounted for over $345,000.
There were no dollars collected for the Field Service Collection Charge during
visits by a collector. The Field Service Collection Charge is billed to the
customer's account following the visit and is shown on the customer's next billing
statement.
Recordholder: Eric Holje
Sponsor: Barbara Coughlin
GNR-U-I 4-OllRocky Mountain Pou,er
November 14,2014
IPUC Data Request 16
IPUC Data Request 16
In states where a policy change was approved and the Company subsequently
implemented a no knock, no payment at the door" policy, did the number of
customers disconnected for non-payment increase, decrease, or stay about the
same?
Response to IPUC Data Request 16
The Company has implemented this policy in four other states and the trend in the
number of disconnection orders is varied.
California- Implemented May 2013, slight decrease in disconnections
Oregon- Implemented May 2014,trending about the same
Utah- Implemented October 2012, down slightly this year after being up last year
Wyoming- Implemented April 2013, slight increase this year
The Company does not believe we can draw a conclusion on the number of
disconnections based on the roll-out of this new policy. There are numerous
factors that impact the number of disconnections that occur each year. In addition
to the policy change, local economies, continued refinement of work order routing
in the mobile work management application, and manpower availability continue
to play apart in the number of disconnection orders that are completed.
Recordholder: Cory Estlund
Sponsor: Barbara Coughlin
GNR-U- l4-Ol/Rocky Mountain Power
November 14,2014
IPUC Data Request 17
IPUC Data Request l7
In preparing to change its field collection practices in other states, the Company
only informed customers with past due balances of the change. Please explain
why notification was limited to these customers. Does the Company propose to
use the same process in Idaho? If not, please explain.
Response to IPUC Data Request 17
Prior to implementing this change in Utah, the Company did consider informing
all customers of this change in practice. However, a decision was made that
notification would be specifically provided to customers who paid at the door or
who had potential for the need to pay atthe door because they were customers
who would be impacted by the change in policy. Customers that are current on
their bill are by far the majority of our customers, and we believed they would
have no expectation or awareness that payment at the door was an option. Also,
our experience has been that customers who are not past due dislike receiving
notification about collection related activities and notification to these customers
could potentially cause confusion for those already paying their bill, thereby
causing incoming phone calls and complaints.
This decision was reevaluated before implementing this change in
Wyoming. Based on the fact that the roll out and policy implementation worked
very well in Utah, it was decided once again to only notify customers with past
due balances. This same decision point has been raised as rve rolled out in
California and Oregon, and again because the process worked well in every state
to date, and there have not been any issues raised by customers, we continued
with this same process.
Recordholder: Barbara Coughlin/Larry Blarn
Sponsor: Barbara Coughlin