20080512Staff Supplemental Comments.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
?2.~ -
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
AVISTA CORPORATION FOR AUTHORITY )
TO IMPLEMENT A PILOT PROGRAM FOR )
REMOTE DISCONNECTS AND RECONNECTS )
)
)
CASE NO. A VU-E-07-9
SUPPLEMENTAL COMMENTS
OF THE COMMISSION STAFF
The Staff of the Idaho Public Utilties Commission, by and through it Attorney of Record,
Neil Price, Deputy Attorney General, in response to Order No. 30471 issued on December 4,
2007, submits the following comments.
BACKGROUND
On August 31, 2007, A vista Corporation fied an Application seeking approval to
implement a one-year pilot program for the remote disconnection and reconnection of customers
to its system. The Company also requested a limited waiver of Utilty Customer Relations Rule
311.03 and .04 (IDAPA 31.21.01.03 and .04) related to the final customer notification prior to
disconnection. The Company requested that its Application be processed by Modified Procedure.
IDAPA 31.01.01.201-.204.
On September 19,2007, the Commission issued a Notice of Application and Notice of
Modified Procedure, establishing a deadline for the submission of comments and/or protests.
Commission Staff fied comments supporting the Company's Application with certin conditions.
SUPPLEMENTAL COMMENTS 1 MAY 12,2008
AARP, Idaho (AARP) and the Community Action Parnership Association of Idaho (CAPAI) filed
comments opposing the Company's Application.
On December 4,2007, the Commission issued Order No. 30471 and deferred judgment on
the Company's Application. The parties were ordered to conduct workshops to fuher refine and
develop the details of the program. Following the issuance of that Order, the paries informally
communicated bye-mail and telephonically to discuss their concerns and address the following
issues identified by the Commission:
(1) The criteria for selecting customers for inclusion in the program;
(2) The distinction(s) between urban and rural customers and any links with the Company's
AMR distribution;
(3) The notice, any special notice, and any customer education for those selected for
paricipation;
(4) The plan for evaluation of the pilot, including both technological and customer impacts;
(5) Capital costs, cost recovery, reconnection fees, cost savings; and
(6) The public interest issues surounding the abandonment of the final, in-person home visit
and opportunity to "pay at the door" prior to disconnection. See Order No. 30471 at 8.
Public workshops were originally scheduled for Februar 5 and 6, 2008, in Lewiston and
Coeur d Alene, but were cancelled to allow more time for discussion among the paries. A public
workshop was held on March 27, 2008, in Boise, during which the paries reached tentative
consensus. Representatives of A vista, the Commission Staff, CAP AI, and AARP attended the
workshop. At the conclusion of the workshop, paricipants agreed to continue working informally
on the issues of customer notification and identification of the data to be collected during the
course of the pilot.
As required by Order No 30471, Avista submitted a Revised Application on April 28,
2008, that incorporates changes to the pilot agreed to during the workshop and subsequent
communication among the paries. Staff generally agrees with Avista's revised proposal for a
pilot program and continues to support the Company's request for a limited waiver of the
appropriate Utilty Customer Relations Rules (UCRR). Staff notes that effective April 2, 2008,
the UCRR was revised and the sections in Rule 311 renumbered. The specific citations in both the
Company's original and Revised Application (Rules 311.03 and 311.04) are no longer correct.
The pertinent rules are now Rule No. 311.04 - Opportunity to Prevent Termination of Service and
SUPPLEMENTAL COMMENTS 2 MAY 12,2008
311.05 - Notice of Procedure for Reconnecting Service. Staff recommends that a limited waiver
be granted for Rule Nos. 311.04 and 311.05 (IDAPA 31.21.01.311.04 and 311.05).
Although Staff generally agrees with the proposal, there are a few elements of the
Company's Revised Application that are either unclear or lacking in detaiL. Staff proposes a more
specific program duration and clarfication of when collars (the remote disconnection/reconnection
devices) wil be installed and which customers wil be excluded from the pilot. Staff also
addresses additional issues that were either previously mentioned in Staffs original comments
fied in this case or discussed during the public workshop.
Pilot Program Duration
In the original Application, A vista proposed a timeframe of one year for the pilot program.
See Application at 1. In the Revised Application, the Company proposes a pilot duration of
eighteen months from the time the last collar is installed. See Revised Application at 3. Staff
supports a longer pilot period from that originally proposed by the Company to allow a sufficient
amount of time for the Company to select customers, install the necessary equipment, and have
enough experience to allow meaningful evaluation of the pilot. As described in the Company's
Revised Application, however, the duration of the pilot is indeterminate because it is not known
when the last collar wil be installed. For that reason, Staff recommends a more definitive time
period of eighteen months from the date of the Commission Order approving the pilot program.
When Collars Installed
The Company states that customers selected for the pilot must meet at least one of three
criteria listed in the Revised Application. See Revised Application at 3. The second criterion is
customers who have previously had two field collection visits or disconnections in the preceding
12 months. ¡d. Staff wishes to fuher define this criterion with additional language that specifies
a collar wil be installed at a selected customer's location at the time of the third field collection
visit or disconnection within the 12 month period.
Customers Excluded From Pilot
The Company states that it will exclude from the pilot "CARES customers, customers
subject to the moratorium, who are on a winter payment plan; who have provided medical
certificates, or who have made satisfactory payment arangements". See Revised Application at 3.
SUPPLEMENTAL COMMENTS 3 MAY 12,2008
Staffs understanding of the Company's intent differs from the literal wording in its Revised
Application. Staff agrees that customers who are in Avista's CARES1 program should be
excluded from the pilot. However, customers who declare eligibilty for the moratorium or obtain
a medical certificate during the pilot program would continue to be eligible for selection for the
pilot, but if selected, they would not be disconnected during the time period covered by the
moratorium or medical certificate as required by Commission rules. Likewise, customers who are
on a winter payment plan or other type of special payment arangement could be selected for the
pilot but would not be disconnected as long as those payment arangements were kept.
Reset Button
Originally, it was Avista's intent to require customers who had been disconnected remotely
to self-connect using a manual reset button on the meter before service was reactivated. See
Attachment 1, page 2 of Application. In response to concerns expressed by the paries, A vista no
longer intends to require customers to perform this final action before service is restored. When
the conditions for reconnection are met and the customer requests reconnection, the Company wil
restore service remotely without requiring further action from the customer.
Door Hangar Envelope
During the discussions at the March 24, 2008 workshop, paricipants discussed the
necessity to provide an early waring to customers whose payment history or other actions could
eventually meet the selection criteria for the pilot program. To accomplish this, the Company
agreed to modify the "door hangar" envelope to include a brief explanation of the pilot program.
A Notice of Disconnection is enclosed in the "door hanger" envelope and either given to the
customer or, if the customer is not available, left on the premises durng a field collection visit or
disconnection. A customer who has already been selected for the pilot will receive a special
notice designed for program paricipants. See Attachment A of the Revised Application. Staff
recommends the Company work with the Staff to modify the envelope.
i Avista's Customer Assistance Referral and Evaluation Service (CARES) program provides assistance to customers
who are having trouble paying their utilty bils and can benefit from a more comprehensive and personal focus on
their particular needs.
SUPPLEMENTAL COMMENTS 4 MAY 12,2008
RECOMMENDATIONS
Staff recommends that the Commission approve the proposed pilot and grant a limited
waiver of Rules 311.04 and 311.05, UCRR, with respect to customers selected for the pilot under
the following conditions:
(1) The pilot program's duration be fixed at eighteen (18) months from the time the effective
date of a Commission order approving the pilot;
(2) The collar allowing remote disconnection and reconnection of service be installed at an
eligible customer's premises in the event of a third field collection visit or disconnection
durng the previous twelve (12) months;
(3) Automatic exclusion from the pilot program be limited to CARES customers;
(4) Commission rules governing when and under what conditions customers' service can be
disconnected continue to apply to all customers selected for the pilot;
(5) The Company be directed to work with Staff to revise the "door hanger" envelope used
when leaving a Notice of Disconnection at a customers' service location to include a
description of the pilot program.
Respectfully submitted this I~ 17, day of May 2008.
lC7 Neil Price
Deputy Attorney General
Technical Staff: Nancy Hylton
Grace Seaman
Beverly Barker
i:umisc:commentsiavue07.9npnhgsbab comments 2
SUPPLEMENTAL COMMENTS 5 MAY 12,2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF MAY 2008, SERVED
THE FOREGOING SUPPLEMENTAL COMMENTS OF THE COMMISSION STAFF,
IN CASE NO. AVU-E-07-09, BY MAILING A COpy THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220
E-MAIL: david.meyeraYavistacorp.com
BRAD M. PURDY
ATTORNEY AT LAW
2019N.17THSTREET
BOISE, ID 83702
E-MAIL: bmpurdva.hotraiI.com
JIM WORDELMAN, STATE DIRECTOR
AARPIDAHO
3080 E. GENTRY WAY STEI00
MERIDIAN,ID 83642
E-MAIL: mwilsonaYaa.org
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwoodaYavistacorp.com
MARY CHANT, EXECUTIVE DIRECTOR
COMMUITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
5400 W. FRANKLIN ROAD STE G
BOISE, IDAHO 83705
E-MAIL: mchantaYcapaLorg
~bØ&0SECRET Y -
CERTIFICATE OF SERVICE