20071025Comments.pdf

DONOV AN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
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Street Address for Express Mail:
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Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
A VISTA CORPORATION FOR AUTHORITY
TO IMPLEMENT A PILOT PROGRAM FOR
REMOTE DISCONNECTS AND RECONNECTS
CASE NO. A VU-O7-
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through it Attorney of Record
Donovan E. Walker, Deputy Attorney General, in response to the Notice of Application and
Notice of Modified Procedure, issued on September 19 2007, Order No. 30437, submits the
following comments.
BACKGROUND
On August 31 , 2007, A vista Corporation filed an Application seeking approval to
implement a one-year pilot program for remote disconnects and reconnects. The Company also
requested a limited waiver of Utility Customer Relations Rules 311.03 and 311.04 (IDAP A
31.21.01.311.03 and 311.04).
A vista proposes to implement a one-year pilot program for the evaluation of remote
disconnects and reconnects. The Company proposes to install approximately 250 remote
disconnect collars that would utilize Power Line Carrier (PLC) as the communication protocol in
rural areas and approximately 350 wireless meter devices for use in urban areas. The devices
STAFF COMMENTS OCTOBER 25 , 2007
would allow for the remote enabling and disabling of electric service from A vista s office.
According to the Application customers selected for the pilot would include customers with 200
amp services that either have had multiple disconnects, are located in rural areas, or otherwise
occupy premises where the A vista employee may be "at risk" for manually performing
disconnects and/or reconnects.
The Company states in its Application that the anticipated benefits of remote disconnect
and reconnect capability include: (1) reducing operating and maintenance expenses related to
multiple disconnections and reconnections for urban and rural accounts; (2) productivity gains of
employees by eliminating multiple trips to customer homes for collections; (3) enhancing
employee safety; (4) quicker response time to reconnect service leading to increased customer
satisfaction; and (5) recognizing a reduction in bill defaults and write-offs by encouraging prompt
consumer payment over time. A vista proposes to report on the following at the conclusion of the
one-year pilot program: (1) number of disconnect devices installed; (2) reason for installation; (3)
utilization of the disconnect devices after installation; and (4) costs together with realized savings.
STAFF ANALYSIS AND COMMENTS
Staff supports A vista s proposed pilot program with certain conditions as more fully
discussed below. The Commission has encouraged utilities to implement "smart meter
technology. As with any new technology, evaluation and adjustments are necessary. This pilot
provides the opportunity to determine the costs and benefits of remote connection and
disconnection, test the equipment, and perhaps more importantly, allow all interested parties to
evaluate the impact of such a program on customers.
Customer Selection Criteria for Inclusion in Pilot Program
It is Staff s understanding that participants have not been pre-selected for the pilot.
Participants will be selected over time on a case-by-case basis. If the Commission approves the
pilot, customers scheduled for disconnection will be screened to determine ifthey meet the pilot's
selection criteria: multiple disconnects, location in a rural area, or the customer occupies a premise
where an A vista employee may be at risk. The Company anticipates that participants will be
primarily residential, but the pilot could include any customer with 200-amp service. Customers
who frequently are disconnected for non-payment will be the most likely to be selected for the
pilot.
STAFF COMMENTS OCTOBER 25, 2007
The Company s definition of "multiple disconnects" is that service has been disconnected
two or more times in the past three years. Staff believes it would be more appropriate to focus on
disconnections within the most recent 12-month period. A customer that meets that particular
requirement could live in either a rural or an urban area. The Company is more likely to realize
significant cost savings and other benefits if there is a history of multiple visits to a customer
premise over a relatively short period oftime (1 year). Staff recommends that only those
customers who are actually disconnected at the time of a visit to the customer s premises be
eligible for selection under the pilot program. Staff believes that excluding past premise visits that
did not result in actual disconnection of service from the selection criteria will narrow the focus of
the pilot to those customers with an established history of disconnections and simplify evaluation
of the pilot program.
The Company defined "rural area" as typically those areas outside the city limits of
Lewiston, Moscow and Coeur d' Alene, Idaho, the three cities with the largest populations in
Avista s Idaho service territory. Staff believes this definition is overly broad, and that greater
efficiencies and cost-savings would be realized ifthe Company focused on customers in remote
locations, as opposed to simply outside the city limits of major population areas. Staffs
understanding is that customer location will be a secondary factor used in the selection process.
The Company will first determine whether there has been multiple disconnects and then consider
location.
A vista provided several examples of situations that may put an employee at risk:
customers have threatened harm to either an Avista employee or Avista property, locations where
there is danger from animals, e., a dog tied to a meter, or access to the customer s location is
difficult. If a customer is scheduled for disconnection and A vista determines that the employee
who will be dispatched to visit the premises will be "at risk " the Company may select this
customer for the pilot even if he or she may not have been disconnected multiple times in the past.
Staff agrees that this would be an appropriate criterion for selection.
Customer Notification
Currently, the first disconnection notice is sent to the customer at least seven calendar days
before the proposed date of disconnection (Rule 304., Utility Customer Relations Rules
(UCRR)). A final (second) notice is sent at least three days before the proposed date of
disconnection. A call must be made to the customer at least 24 hours before actual disconnection
STAFF COMMENTS OCTOBER 25, 2007
(Rule 304., UCRR). All the notices must provide information on steps the customer may take
to avoid disconnection. Under the pilot, the Company intends to continue providing these written
and oral notices.
The day service is disconnected, the utility is required to knock on the door to give the
customer a final opportunity to pay the amount required to prevent disconnection (Rule 311.
UCRR). If no one is at the premises at that time, the employee must leave a notice advising the
customer that service has been disconnected and what steps must be taken to get service
reconnected (Rule 311., UCRR).
Under the pilot, the Company will not be visiting the premise to disconnect service after
the initial visit to install the necessary equipment. Since no employee will be dispatched to
disconnect service, the Company will not be able to provide the customer one final opportunity to
avoid disconnection by paying the bill or leave the usual post-disconnection notice. Some
customers routinely avoid disconnection of service by paying the Company employee when he or
she visits the customers' premises. The Company has advised Staffthat most premises visits
(85%) actually result in disconnection of service. Customers who are selected for the pilot will
not be afforded that final opportunity to pay, literally at the last minute. As discussed previously
in these comments, Staff recommends that customers selected for the pilot have a history of actual
disconnection. Therefore, it is less likely that selected customers will have come to rely on the
option of avoiding disconnection by paying during a premise visit.
The Company must be granted a waiver of Rule 311.03 and .04 (final visit and opportunity
to pay) if the pilot is approved. Staff supports granting of the waiver for those customers selected
for the pilot program.
Currently, the notice left at the customer s premises following disconnection contains
information on what actions are necessary to get service restored and how to contact A vista. The
Company has drafted a special notice that will be given to customers or left at the premises when
the remote connect/disconnect equipment is initially installed. The notice will advise the customer
that the device has been installed and explain how that will change the disconnection and
reconnection procedure from that point forward. The notice also requests updated customer
contact information so that the Company can call the customer immediately prior to
disconnection. It is Company policy to update customer contact information anytime a Company
representative speaks to a customer. The notice provided to the customer includes information on
action the customer needs to take after the Company restores service, i., push the reset button on
STAFF COMMENTS OCTOBER 25 , 2007
the meter. The customer will be given the same information when the customer contacts the
Company to request reconnection. Staff supports this special notice, but believes the text of the
draft/special notice could be rewritten to provide greater assistance to program participants. Staff
recommends that the Company work with Staff in preparing this special notice for customers
selected for the pilot program. In particular, Staff believes the notice should encourage customers
to contact the Company if there are any questions or concerns or if there are reasons why the
customer would not be able to reset the meter.
Remote Disconnection Devices
The equipment the Company selected for the pilot program has a manual reset button
primarily for safety reasons. For example, if something was left cooking on a stove or a space
heater was on at the time service was disconnected, cooking or heating would resume as soon as
service was restored. If service was restored remotely without the customer having to reset the
meter device, there would be a potential risk of damage to appliances or even fire. The Company
indicated that it could override the reset function and restore service remotely without the
customer s participation if necessary, as might be the case if the customer is physically unable to
access the meter or push the reset button.
The two devices to be used by the Company are a relatively new technology. The
Company will be tracking the failure rate during the pilot. Should a remote device fail at any
point during a disconnect or reconnect, the Company will follow its normal process for an
employee visit to the location to either disconnect or reconnect service.
The remote devices do not have an indicator light to allow a customer to know that's the
reason for power being off. There are other situations that could result in a power outage such as a
general power outage, a blown fuse or a tripped circuit breaker. A customer selected for the pilot
will receive the normal disconnection notices and a call prior to a remote disconnection. As
previously mentioned, the Company will provide a special additional notice when the equipment
is installed. If a customer is unsure as to whether a service interruption is due to remote
disconnection or a power outage, the customer will need to contact the Company.
Currently, there is information on all the notices provided to customers giving them
information on steps that can be taken to prevent disconnection as well as contact information for
both the Company and the Commission. For those customers selected for the pilot, the Company
STAFF COMMENTS OCTOBER 25, 2007
will provide contact information in a more permanent fashion, e., by placing a sticker on either
the customer s circuit panel or the meter base.
Program Evaluation
The evaluation effort identified by the Company in its Application focuses on the hardware
used in the pilot program and a financial cost/benefit analysis. The Company does not mention
any effort to evaluate the impact upon customers and customer payment behavior. A vista has
expressed a willingness to work with Staff and other interested parties to develop an evaluation
plan designed to make meaningful analysis of customer impacts possible.
Other Issues
An advantage of the pilot program is the ability of the Company to restore service within
minutes, 7 days a week, 24 hours a day, once the customer has satisfied all the conditions required
to restore service. Normally, it can take up to several hours to restore service, taking into account
scheduling and drive time to the customer s premise. Customers who request reconnection
outside of Avista s normal business hours (8 a.m. to 7 p.m. weekdays and 8 a.m. to 4 p.m. on
weekends and holidays) must wait until the following day to be reconnected. For these customers
remote reconnection will be a major benefit, since service will be restored much more quickly.
The Company did not propose to reduce or waive reconnection fees for those customers
selected to participate in the pilot. Although Staff believes it would be appropriate to consider
changing the fees or fee structure in the event a permanent program is proposed in the future, Staff
does not recommend any changes at this time.
Remotely disconnected customers have the same payment options as all other customers:
payment by mail, the Internet using a third party vendor, by phone with either a debit or credit
card, or a direct debit to their checking account. Customers may also make payment at one of 30
pay stations in the Company s Idaho service territory.
The Company estimates the cost of the pilot to be $104 000. Staff notes that Avista is
already in the process of installing metering equipment under its Advanced Meter Reading (AMR)
program to enable the Company to read meters remotely. The same technology used to read
meters remotely can be used to connect and disconnect service remotely. Therefore, the Company
anticipates that it will not necessarily incur additional equipment cost for every customer selected
for the pilot. To the extent that is true, it will reduce the overall cost ofthe pilot program.
STAFF COMMENTS OCTOBER 25 , 2007
RECOMMENDATIONS
Staff recommends that the Commission approve the proposed pilot and grant a limited
waiver of Rules 311.03 and 311.04 with respect to customers selected for the pilot under the
following conditions:
(1) The Company modify its selection criteria to define "multiple disconnections" as two or
more disconnections within the past twelve months and change its location focus to
customers whose premises are in remote areas;
(2) Direct the Company to work with Staff on preparing its special notice for customers
selected for participation in the pilot program; and
(3) Direct the Company to work with Staff and other interested parties to prepare a plan for
evaluation that includes the pilot's impact on customers and customer behavior as well as
the technological and financial aspects ofthe program.
Respectfully submitted this d5' 'II) day of October 2007.0 ~tL-~ Walker
Deputy Attorney General
Technical Staff: Wayne Hart
Nancy Hylton
i: umisc: comments/avueO7 - 9dwwhnh
STAFF COMMENTS OCTOBER 25 , 2007
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF OCTOBER 2007
SERVED THE 'FOREGOING COMMENTS OF THE COMMISSION STAFF IN CASE
NO. AVU-07-, BY MAILING A COpy THEREOF POSTAGE PREPAID, TO THE
FOLLOWING:
DA VID 1. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220
MAIL: david.mever~avistacorp.com
KELL Y NORWOOD
VICE PRESIDENT - STATE & FED. REG.
AVISTA UTILITIES
PO BOX 3727
SPOKANE W A 99220
MAIL: kelly.norwood~avistacorp.com
'-
~T0-
SECRET A
CERTIFICATE OF SERVICE