20200707_tc1rq.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:TERRI CARLOCK
UTILITIES DIVISION ADMINISTRATOR
DATE:JULY 2,2020
RE:JOINT PLAN TO RESUME NORMAL COLLECTION AND
DISCONNECTION ACTIVITY BY LARGE IDAHO UTILITIES.
BACKGROUND
On June 30,2020,the large Idaho utilities,Idaho Power Company,Avista,Rocky
Mountain Power and Intermountain Gas (collectively,"Idaho Utilities")filed a joint plan "Joint
Plan"proposing to resume collection and disconnect activities.On or before March 17,2020,
these Idaho Utilities,voluntarily stopped performing disconnections due to the impact of
COVID-19 on customers and the economy.The attached Joint Plan contains an overview of
enhanced communication with customers and flexible payment arrangements each utility will
make available to customers.The Idaho Utilities propose resuming collection reminder notices
no earlier than July 13,2020,with an earliest disconnection date of August 3,2020 for customers
that have not entered into a payment arrangement.
STAFF RECOMMENDATION
Staff had a joint call and shared emails with representatives from the Idaho Utilities to
better understand the rationale for their proposal to resume collection and disconnection
activities at this time.The Idaho Utilities are proposing additional payment arrangements
beyond those available before COVID-19 and as a result of coordination efforts delayed the Joint
Plan proposed start date by two weeks.The accumulation of large past-due amounts,many
include bills from the winter of 2019-2020,is concerning to the utilities and some customers.
These Idaho Utilities are trying to establish reasonable payment arrangements before winter bills
DECISION MEMORANDUM -1 -JULY 2,2020
of 2020-2021 add to the accumulation.Communications with customers have resulted in limited
payment arrangements being established so far this year.The Idaho Utilities make this proposal
to have greater means to establish flexible payment arrangements.Tariff changes were made to
provide more flexible options when disconnections were stopped but the Joint Plan does not
require additional Tariff changes.
Suez Water has expressed interest in joining the Joint Plan.
COMMISSION DECISION
Does the Commission wish to:
1.Approve the Joint Plan for Idaho Power Company,Avista,Rocky Mountain
Power,IntermountainGas,and Suez?
2.Approve a modified plan?
3.Establish something else?
Terri Carlock
Udmcmos/Plan to Rcsume Normal Collection und Disconnection July 2020 Decision memo
DECISION MEMORANDUM -2 -JULY 2,2020
Connie Aschenbrenner Shawn Bonfield
Rate Design Senior Manager Sr.Manager RegulatoryPolicy &Strategy
Idaho Power Company Avista Utilities
Lori Blattner Ted Weston
Director,RegulatoryAffairs Idaho RegulatoryAffairs Manager
Intermountain Gas Rocky Mountain Power
June 30,2020
Diane Hanian,Secretary
Idaho Public Utilities Commission
11331 W.Chinden Boulevard
Building 8,Suite 201-A
Boise,ID 83714
Re:Idaho Utilities'Joint Plan to Resume Normal Collection and Disconnection
Activity
Dear Ms.Hanian:
The Idaho utilities understand and sympathizewith customers who have been andcontinuetobeimpactedbyCOVID-19 and the state of the economy.On or before March
17,2020,Avista Corporation,Rocky Mountain Power,Intermountain Gas,and Idaho
Power Company (collectively,"Idaho Utilities")voluntarily stopped performing
disconnections.Avista Corporation,IntermountainGas,and idaho Power Company have
also voluntarily stopped charging late fees.
At the request of Commission Staff,the Idaho Utilities prepared a Joint Plan to
outline proposed next steps under which the Idaho Utilities may resume collection anddisconnectionactivities.The Joint Plan proposes resuming collection reminder notices
no earlier than July 13,2020,with an earliest disconnection date of August 3,2020 for
customers that have not entered into a payment arrangement.The Joint Plan details how
the Idaho Utilities will communicate changes to customers before resumingdisconnectionsandtheprovisionofalternativepaymentarrangements.
Recognizing that the continued accumulation of large past-due amounts creates
future hardship for their customers,the Idaho Utilities stand ready to implement this Joint
Plan or one like it as approved by the Commission.If we can assist with additional
information,please contact me or one of my utility colleagues.
Da this 30*da of Ju
Connie Aschenbrenner,on behalf of the Idaho Utilities
Enclosure:Idaho Utilities'Joint Plan
Idaho Utilities'Plan to Resume Normal Collection and Disconnection Activity
Background
On March 13,2020,Idaho GovemorLittle issued a Proclamation declaring a state of emergency and
providing directives to combat the spread of COVID-19,provideessential services and limit public
exposure.
On April 23,2020,Govemor Little announced Rebound Idaho,which provides a staged reopening for
businesses in Idaho.Rebound Idaho stages include:
Stage 1 (May 1 -May 15):Places of worship,daycares,and organized youth activitics can open
if they can meet business protocols.
Stage 2 (May 16 -May 29):Restaurant dining rooms,indoor gyms,and cosmetic businesses can
open if they can meet business protocols.
Stage 3 (May 30 -June 12):Additional businesses,including bars and movic theaters can open
if they can meet business protocols.
Stage 4 (June 13 -current):Nightclubs may operate with diminished standing-room occupancy,
where applicable and appropriate.Large venues can operate under limited physical distancing
protocols.
On June 13,2020,GovemorLittle moved Idaho into Stage 4 of the re-opening plan,which means all
businesses are eligible to operate.
On June 22,2020,the Central Distdet Health moved Ada County back into Stage 3,ordering the closure
of bars operating in the county.
Avista Corporation,Rocky Mountain Power,Intermountain Gas,and Idaho Power (collectively,"Idaho
Utilities")anticipate modifying their collection and disconnections practices in accordance with changes
in Rebound Idaho or Governmental mandates.This Joint Plan is submitted by the Idaho Utilities on June
30,2020 and contains an overviewof the current state of collection activity for cach utility,a proposed
timeline to resume co]Icetion activity,and an overviewof enhanced communication and Dexible payment
arrangements that will be made available to customers.
Current State
On or before March 17,2020,the idaho Utilities voluntarily stopped performingdisconnections.Avista
Corporation,Intermountain Gas and Idaho Power Company have also voluntarily stopped charging late
fees.While the Idaho Utilities are not performingdisconnections or charging late fees,they are
continuing to notify customers of their payment obligations in a variety of ways including:
•Avista Corporation:phone calls and reminder letter with account balance and energy assistance
information;
•Rocky Mountain Power:phone calls;postcards;emails;on-bill messages
•Intermountain Gas;phone calls;
•Idaho Power Company:phone calls,field visits,and door hangers.
Anticipated Changes
Resume Collection Activity and Disconnections.
The Idaho Utilities understand and sympathize with customers who have been and continue to be
impacted by COVID-l9 and the state of the economy.The Idaho Utilities will continue to communicate
with customers regarding past due balances and the availability of payment arrangements and energy
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Idaho Utilities Joint Plan to Resume Normal Collection and Disconnection Activity
assistance options.Between mid-June and the beginning of July,the Idaho Utilities will initiate an
enhanced communication effort to all customers in arrears.These messages will share the need to enter
into payment arrangements to avoid an interruption in service.
Collection activity (remindernotices)will resume no earlier than July 136 for customers that have not
entered into a payment arrangement.The Idaho Utilities have providedadditional payment arrangement
options for impacted customers and plan to use disconnections as a last resort.The earliest date a
customer may be disconnected will be August 36 Customers can avoid an interruption in service by
setting up a payment arrangement in advance of their scheduled disconnect.
Each Idaho Utility will follow a communication plan lo ensure customers are aware of the potential for
disconnection and the actions needed on their part to avoid disruption in service.The communication will
be shared several weeks prior to potential disconnection dates.
Communicating changes to customers is vital prior to resuming disconnections.
Idaho Utilities plan to proactivelycommunicate with customers prior to resuming disconnections and/or
charging late fees.The Idaho Utilities will broadly communicate with customers through various
methods of their intent to resumc "normal"collection and disconnection activity.Idaho Utilities will start
implementing field visits for disconnection only after the rcquired communications have been providedto
non-paying customers.
Idaho Utilities intend to communicate with customers in several ways.Potential avenues of
communication are through website messaging,phone calls,emails,social media,text messaging,
postcards,Ictters,door knockers,reminder notices and final disconnection notices.'The Idaho Utilities
will proactivelycommunicate regarding the availably of expanded payment arrangement options,energy
assistance information,and ways to make payments.Updates in specific utility conditions will continue
to be made available through the individual utility website,
Idaho Utilitics expect to performdisconnections using phased-in approaches (e.g.,utilitics may start
collection activity for customers with higher past due balance or balances further in arrears).It is
estimated that once collection activity resumes,collection calls will increase significantly.A phased-in
approach ensures the Idaho Utilitics have bandwidth to take customer phone calls and providethe
necessary field visits within a timely manner.
Providing alternative payment arrangements.Idaho Utilitics havc considered offering additional
payment arrangements beyond what has been typical business practice.Each individual utility will work
with Consumer Affairs StafTto keep them upprised of additional payment arrangement offerings.Idaho
Utilitics are using criteria as providedfor in UCRR 313 to provide flexibility for tbc customer's payment
needs (e.g.,ability to pay,the size of the unpaid balance,and the customer's payment history).
Avista Corporation,latermountain Gas and Idaho Power Company do not assess late fees when a
customer has entered into a payment arrangement.Rocky Mountain Power previously charged late fees
on payment arrangements but will continue to consider waiving late fees prospectively,on a case-by-case
basis,
i Customer communications regarding pending disconnection will be provided in accordance with UCRRs
300-399 (Denial and Termination of Service and Payment Arrangement Rules for Residential and Small
Commercial Customers)and UCRRs 600-699 (Rules for Deposit,Denial,and Termination ofT Service for
Industrial,Large Commercial and lyrigation Customers).
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Idaho Utilities Joint Plan to Resume Normal Collection and Disconnection Activity