20160222Respondent Answer.pdf

Avista Corp.l4ll East Mission P.O.Box3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
February 19,2016
State of Idaho
Idaho Public Utilities Commission
472W. Washington St.
Boise,ID 83702-5983
Attention: Ms. Jean Jewell, Secretary
RE: AVU-E-I6-02, Avista Response to Summons Issued February 1,2016
Dear Ms. Jewell:
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Enclosed is an original and seven (7) copies of Avista's response to the Summons issued on
February 1,2016 in Docket AW-E-16-02 regarding the formal complaint filed by Mel E. Wactr"
owner of Yes Mortgage.
Please contact myself at the number below or Shawn Bonfield at [phone] with any
questions related to this filing.
/Sincerely, //l-lAhlryb"
Manager of Regulatory Policy
Avista utilities
linda. gervais@ avistacom. com
509-495-4975
Enclosures
David Meyer
Vice President, Chief Counsel,
Regulatory and Govemmental Affairs
Avista Corporation
l4l I East Mission Ave.
Spokane, WA99202
Phone: [phone]
Fa:r: [phone]
david.meyer@avistacorp. com
Mel E. Wach, Owner, Yes Mortgage
Complainant,
vs.
AVISTA UTILITIES,
Respondent.
R[CEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMN/flSSION
CASE NO. AVU-E-I6-02
RESPONSE OF AVISTA
CORPORATION
Avista Corporation ("Avista" or "Company") hereby submits its response to the Idaho
Public Utilities Commission's ("Commission") Summons dated February l, 2016 regarding the
"Formal Complaint of Mel E. Wach, Owner of Yes Mortgage ("the Customer or Yes Mortgage")
Against Avista Utilities."
The Company appreciates the opportunity to respond to the complaint filed by the
Customer.
I. Introduction
The Customer, in his letter to the Commission dated December 29,2015, stated his desire
to file a formal complaint against the Company seeking a refund for incorrect billings from the
period of April 2008 to August 2015. Yes Mortgage began receiving service from Avista in
April 2008. In October 2015 it was identified that the electric meter installed at Yes Mortgage's
AVISTA CORPORATION RESPONSE IN AW.E.I6.O2
Page I
premise had been switched with the premise adjacent to his. As a result, Yes Mortgage was
essentially overbilled from April 2008 to October 2015, as they were paying for electric usage
from the neighboring premise, which was in fact higher usage than their actual usage. Per the
requirements outlined in rule 204.02.b of the Commission's Utility Customer Relations Rules
(IDAPA 31.21.01), Avista provided a refund of $1,866.20 for overbillings dating back to 2012 or
36 months as allowed per the rule.
Yes Mortgage acknowledges that the period of remediation is 36 months as detailed in
the rule mentioned above, however, they are seeking a refund for the billing period of April 2008
- August 2012 for the following reasons described in their formal complaint:
l. This is not a situation of a simple billing error, a malfunction in the meter/other
equipment, or a failure to bill but rather it is a situation where we have been billed
for another company's usage for over seven (7) years.
2. In this situation, after several months of high bills, Yes Mortgage contacted
Avista in August 2008 to address my concerns regarding what they considered to
be extremely high bills. Avista responded by sending a technician out to
investigate the situation and assured the Customer that everything was in order.
3. In September 2015, the neighboring office, North Idaho Home Health, vacated
their office when they moved to another location and Yes Mortgage's bills
dramatically decreased. It was obvious to the Customer there was an issue so
they contacted Avista. Avista came out and once again, advised that there were
no issues; the meter and equipment were performing correctly.
4. In October 2015, Yes Mortgage again contacted Avista and asked that they look
at this situation further as there was obviously an issue. It was discovered that the
AVISTA CORPORATION RESPONSE IN AVU-E-16-02
Page2
two (2) meters were incorrectly registered at Avista whereby the Customers usage
was being billed to North Idaho Home Health and their usage was being billed to
the customer. There was a difference not only in the office square feet, but in the
number of employees; therefore, the error negatively affected the Customer for
over seven (7) years.
5. If Avista had properly researched the issue back in 2008 when it was first brought
to their attention, this situation could have been resolved back then; therefore, we
should not be penalized due to their failure to properly address the situation.
II. Historv of the Dispute
On October 15,2015, Yes Mortgage contacted the Company requesting that the meter at
their location be checked to see if it had been switched with the neighboring premises meter. A
field representative from the Company's electric meter shop went to the Customer's location on
October 27,2015 to check for switched electic meters. During that field visit, the representative
identified that the electric meters at the Customer's premise and the neighboring premise were
indeed switched. On October 21, 2016 a natural gas field representative confirmed that the
natural gas meters at the premises were correctly assigned to each premise, therefore the
Customer was correctly billed for their natural gas usage.
Upon confrming that the Customer's electric meter was switched with the neighboring
premise, the Company then calculated the amount the customer had been overbilled from
October 2012,36 months prior to the discovery of the issue, to July 31't 2015. From July 31,
2015 to the date the error was discovered, the Customer was actually being underbilled as usage
from the neighboring premise that they were being billed for was less than their actual usage.
AVISTA CORPORATION RESPONSE IN AW-E-16.02
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From October 2,2012 through August 3,2015, the Customer was billed $6,268.20 for
58,101 kWhs, but should have been billed $4,402.00 for 39,591 kWhs. The Company issued a
refund for the amount of $1,866.20 on November 13, 2015 for the amount which they were
overbilled during the prior 36 months from the time the error was identified. Also, on November
13,2015 a field technician corrected the switched electric meters.
The following table provides a suflrmary of the billings for Yes Mortgage and the
neighboring premise from April 2008 through July 2015, along with the refrrnd already provided
to Yes Mortgage.
Yes Mortgage April 2008 - July 2015 Billed Amount
Neighboring Premise April 2008 - July 2015 Billed Amount
Amount of Overbilling
Amount of Overbilling Refunded from October 2OL2 - October 2015
Amount Not Refunded per IDAPA 3L.21.0L, Rule 204.02.b
577,L48.22
S10,196.01
SG,952.18
s1,866.20
Ss,08s.gg
In the Customer's formal complaint they are seeking the remaining amount of $5,085.98
that they were overbilled to be refunded, however, this amount is outside of the allowable
remediation period of 36 months described in rule 204.02.b of the Commission's Utility
Customer Relations Rules (IDAPA 31.21.01).
III. Additional Information
In the Summons issued on February 1,2016, the Company was asked to respond to the
following questions.
l. Is there evidence (e.g. screen shots of notations in Complainant's account record) of
contact by complainant to Avista:
a. from June through September 2008?
AVISTA CORPORATION RESPONSE IN AVU.E.I6.O2
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The Company does not have evidence of contact by the Complainant to the Company,
including screen shots or notations, from June through September 2008. If the Customer
contacted the Company due to concerns over high bills, the Company would have sent a
technician to the Customer's location, as described by the Customer, to test the meter and ensure
it was reading accwately. At that time, the technician would have no indication that the meter at
the Customer's premise and the neighboring premise could have switched as the Company is not
responsible for the wiring of the building where the premises are located.
b. from September through October 2015? If so, please provide and/or describe.
The Company has no evidence of contact by the Complainant to the Company in
September of 2015. The first contact on file of the Customer contacting Avista regarding a
concern of switched meters at their location was on October 15,2015. Below are screen shots of
notations and activities on the Customer's account from September through October 2015.
Screen Shot #1 - Customer Contact from October 15,2015
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Your Equity Source - Prinmry: ffCI8) 664-9260 Open
User iD
htrls-rols I /[o]o3PM I
Held Ui,ork V
FLDWRK '{ FtsH vtbrk
NlelWach - 56588100t10-2426 N l*rlent Creek Loop Ste A, CDA-ID r,,uanted to deckfor
svstched nEters. Rernemher to deleted shieH cdlectims once investigation b onpleted.
AVISTA CORPORATION RESPONSE IN AW-E-I6-02
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Screen Shot #2 - Natural Gas Field Activity created as a result of Customer contact on
October 15,2015
Screen Shot #3 - Electric Field Activity created as a result of Customer contact on October
15,2015
AVISTA CORPORATION RESPONSE IN AVU-E-16-02
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@-- ResHenthlcaScyde Day 3/Route 030909/2426 N MERRTTTCREK LooP STEA,
n.rry coEuR DALEI,IE, ID. 93914/Connected
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iHrhd ldalro IndepenM Banh hc be&veo B pryfBfc $rfre B.
if tr2f-20f S vetrhd ryae A and rer * Xl8t71 ue mtnect€d Cdfrrnd wilh It[ AH ok on gE Cde[
E
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Non Resfilenthl Eedrfircyc{e Day 3fioute 030909P426 N ITGRRITT CREEK LOOP SIE A,
COEUR DALENE, ID, 83814/Connected
E$lrwestlgate $nltched MTHflrfrted Wirhg
Creted on 10-1$2015 03:03PM [t user l-AF3&*3.
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@l }thl tmdr O 7zFIlS$lSq, he ulotfl Io to be here r*en you dre* rntea Thb b b6ted hr Rler Store
fdohotn@delt Bamli, hc bekee b pryingffr$m B.
1{F27-2O15 iltrs TriU6270 (Rd f,m04 ild Tr2r0ffir $d 2lS8) wre arffrcd.;
Screen Shot #4 - Customer Contact from November 412015
(ustcrner Contact [nfo Your Equty Sourcg BdlinglBilhg, Contacted 11-04-2015
PersonID €You E+ity Sqrc - Prinry: (208) 664-960
Preferred dontact f,lethod T----- Vl
Coniart DaterTime
Cortat Class
ConiaciTvpe
Coflrflrents
Reiated
Letter
Screen Shot #5 - Notation on Customer account regarding conclusion of bill correction
analysis
Custcme. Contaci Info Your Equty Source, Biflhg/Swtched Heter, Contacted 11-13-2015
Per:onID €Your EquitySoura -Primary: (Zts) 66{4260
Billmg V
q,
l1r{+ro1sl / [0tu1+]l I
]6ll-{a;lE
fuie|5658810000 2426 N Merritt creek- Cust wanted to know when he was going to get his
credt - I talked to billlng, they sail it can take a few weeks. He asked if he Ls going to get
crediied for 6 years. - I toH him we haven't fgured out what side of the fence he is on
yet Whether he pd fiiore thiln what he u€s suppoge to or hss. - I let hlm know we will
contact him as s(x)fl as we know.
Op,
ultPr-eferred Contaci r"lethod
Contact ilaie.,'Time
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t{ llenitt Creek Loop Ste lr/acct 5658810000 Per FA 233808 on t012712015 electric
meter r4as swtched wlth acct 3298870000 (2426 N MenEt ffeek Loop Ste B)...customer
w?s overbiled untllSte B wcatedTl3LlLS, bted $6268.20 from L0lzlLZ to 8/3/2015 for
58101 knrhs & *touH have been billed *4402.00 for 39591 kwhs. Credl[ed difference of
S1866.20, letter sent to custorner to advise, ennfud GIS
2. Is there evidence that Avista sent a technician to service Complainant's meter in 2008? If
so, please provide and/or describe what the technician did, and what assurances, if any,
were made to Complainant regarding Complainant's concerns.
Please see response to Question No.l above.
3. Does the reimbursement proposed or offered by Avista to Complainant include interest
from the date of original collection?
The refund provided to the customer in the amount of $1,866.20 does not include interest.
AVISTA CORPORATION RESPONSE IN AW-E-I6-02
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4. Is Avista aware of, or does it have any, evidence that Complainant had insulation
installed at Complainant's service-site?
The Company is not aware nor does it have any evidence that the Complainant had
insulation installed at their location.
IV. Efforts to Resolve
As described above, the Company attempted to resolve this issue promptly after being
contacted by the Customer and identifying that the meter at their location was indeed switched
with the neighboring premise. The Company issued a refund for the time period allowed per rule
204.02.b of the Commission's Utility Customer Relations Rules (IDAPA 31.21.01).
Y. Proposed Outcome
The Company has provided Yes Mortgage a refund for the overbilling they experienced
as required in rule 204.02.b of the Commission's Utility Customer Relations Rules (IDAPA
31.21.01). There was no way for the Company to know that the meters were switched in this
situation as both premises involved were occupied from April 2008 through July 2015 and the
meters were accurately recording usage. The Company understands the Customer's concerns
and desire to seek a refund back to the time they moved into their location, however the
Company has resolved the issue in accordance with rule 204.02.b of the Commission's Utility
Customer Relations Rules (IDAPA 31.21.01).
As a result, the Company respectfully requests that the Commission deem Avista's
efforts to resolve this dispute to be sufficient and otherwise dismiss this complaint.
AVISTA CORPORATION RESPONSE IN AW-8.16.02
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Respectfully submitted this 19 day of February 2016.
AVISTA CORPORATION
Lr"o^74zr-or rt"
DAVID MEYE&
Vice President, Chief Counsel, Regulatory
and Government Affairs
AVISTA CORPORATION RESPONSE IN AW-8.16.02
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