20040220Parker Direct.pdf

RECEIVD
2004 Feb,.1U 20 PM 4:59
IDAHOPUBUC
UTIL COMMISION
BEFORE THE
IDAHO PUBLIC UllL1T1ES COMMISSION
IN THE MAneR OF THE APPLICAll0N )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-03-13
AUTHORITY TO INCREASE ITS INTERIM )
AND BASE RATES AND CHARGES FOR )ELECTRIC SERVICE. ~
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DIRECT TESllMONY OF MARILYN PARKER
IDAHO PUBLIC UTlLlllES COMMISSION
FEBRUARY 20, 2004
1 Q.Please state your name and address for the
2 record.
3 A.My name is Marilyn Parker. My business
4 address is 472 West Washington Street, Boise, Idaho.
5 Q.By whom are you employed and in what capacity?
6 A.I am employed by the Idaho Public Utilities
7 Commission as a Utilities Compliance Investigator.I
8 accepted that position with the Consumer Assistance Staff
9 in November 2002.
10 Q.What is your educational and professional
11 background?
12 A.Prior to my employment with the Idaho Public
13 Utili ties Commission, I had twenty years experience
14 working in private industry for three different utility
15 companies. In 1973 and 1974, I was employed by Central
16 Alaska Utilities, a water company in Anchorage, Alaskai as
17 the Executive Secretary to the President of the company.
18 From 1982 until 19871 I was employed as a Customer Service
19 Representative for Idaho Power Company in Salmoni Idaho.
20 From February 1989 until November 20021 I was employed by
21 Intermountain Gas Company in Customer Services. During my
22 last six years at Intermountain Gas 1 I supervised
23 representatives at the Customer Service Centerl s Emergency
24 Answering Service.
25 I received a Bachelor of Arts Degree in
CASE NO. IPC-E..03-1302/20/04
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1 Management and Organizational Leadership from George Fox
2 University in Boisei Idaho in June of 2002.
3 In June 2003 i I attended the National Low
4 Income Energy Consortium Annual Conference in Sacramento i
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5 California.
Q.What is the purpose of your testimony in this
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7 proceeding?
A.I will address issues related to: 1) customer
9 comments received by the Commission regarding this case;
10 2) proposed charges and rates; 3) proposed tariff
11 revisions; 4) low-income issuesi payment optionsi and
12 special need customers; 5) Company operations with regard
13 to the Customer Service Center and Outage Management
14 Operations Center; 6) customer relations; andi 7) out-of-
15 cycle meter readings
16 Q.Please summarize Staff's recommendations to
17 the Commission as discussed in your testimony.
18 A.Staff recommends that Idaho Power Company
19 (Company) be commended for improving customer service
20 through the use of technology-based tools such as its
21 customer-friendly Website and Customer Service Center and
22 Outage Management Operations Center Interactive Voice
23 Response System.
24 Staff also recommends the Company be required
25 to do the following:
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On the initial bills for customers whose
service needs a physical connection at the
time service is initiated that the charge be
entitled, "Service Connection Charge" and not
"Reconnect ion Charge" as proposed by the
Company.
Make Staff's suggested changes to Rules D and
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Change its methods or billing system to avoid
the need to prorate bills for Schedules 1 i 7,
and 9.
Add a sentence in Spanish to its bills and
disconnection notices advising Spanish
speakers what to do if the customer is unable
to determine what the statement or notice
says.
Add a message in Spanish for those waiting on
hold advising Spanish-speaking customers that
a Spanish speaker is available upon request
and that many of the Company's important
brochures and information are available in
Spanish.
Consult with organizations such as the Idaho
Migrant Council to gather information about
the customer service needs of Hispanic people
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in its service territory.
7 )Evaluate the need to print bills and
delinquent notices in Spanish.
8 )Change its billing practices so that the
billing period dates given on bills correspond
to the dates that beginning and ending meter
readings were taken.
9 )Establish a protocol that specifies when a new
meter reading should be taken in situations
where service has not been disconnected
between occupants.
10)Continue to work with Staff to revise the
13 Company's bills, forms, and other documents to
14 achieve compliance with the Utility Customer
15 Relations Rules.
17
16 CUSTOMER COMMENTS
Q.Have you reviewed the written customer
18 comments that have been received by the Commission
19 regarding this case?
20 A.Yes. As of February 11, 20041 the Commission
21 received 291 comments from both residential and comITercial
22 customers 1 with the majority coming from residential
23 customers.
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Q.What are the concerns mentioned by customers?
A.The concern mentioned most often was the
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1 increase in the residential monthly customer charge from
2 $2.51 to $10.001 which was mentioned by more than one-
3 third of those commenting. Customers are opposed to the
4 increase and the most often repeated reason for opposing
5 the increased customer charge is its perceived unfairness.
6 Customers feel it would decrease their ability to affect
7 the size of the bill by adjusting usage. For example, a
8 Pocatello customer wrote, "I am opposed to the customer
9 charge increase, which is exorbitant as it will negate my
10 economic incentive to conserve energy. What I am opposed
11 to is the base flat increase over which my conservation
12 efforts have no effect."
13 The second most frequently mentioned issue was
14 the impact of the overall rate increase on low-income 1
15 fixed-income and senior citizen customers. As one retired
16 customer from Caldwell said, "My pension does not come
17 close to keeping up with all the various increases in
18 services the last few years."
19 Another common comment made by customers
20 resul ts from an apparent misunderstanding of the Company's
21 proposal. Some customers expressed outrage because they
22 thought there would be a 400% increase in the customer
23 charge as well as an additional increase for the kilowatt-
24 hour usage of approximately 19%. An example of one of
25 those comments came from a McCall customer who said, "The
CASE NO. IPC-E-03-1302/20/04 PARKER 1 M. (Di) 5
STAFF
1 proposed 20% increase and 400% monthly service charge
2 increase are outrageous and not affordable." Staff
3 addressed these misconceptions in pre.ss releases as well
4 as the workshops held across Idaho Power's service
5 terri tory in January of this year.
6 Some customers commented that the current
7 economic conditions in Idaho should be considered before
8 allowing Idaho Power to increase its rates. Many
9 indicated that the Commission should just tell the
10 Company, "NO!" At the public workshops, the Commission
11 Staff explained the duties of the Commission and the role
12 the Commission Staff has in rate cases.
13 PROPOSED CHARGES AN RATES
14 Q.What concerns have customers expressed
15 regarding the Company's proposal to increase the monthly
16 residential customer charge to $10. OO?
17 A.Many customers that commented about the
18 customer charge stated that they would prefer to have a
19 lower customer charge and higher kilowatt-hour charge.
20 Electric space heating and air-conditioning customers want
21 to have greater control over the size of the bill by
22 turning the thermostat down in the winter and up in the
23 summer.
24 Q.How does the proposed residential customer
25 charge compare with existing customer charges currently
CASE NO. IPC-E-03-13
02/20/04
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1 being billed in Idaho?
2 A.Avista's basic residential customer charge is
3 $4.00 per month for its electric customers and $3.28 for
4 its natural gas customers. Intermountain Gas Company has
5 a customer charge of $2.50 per month for bills April
6 through November and $6.50 for bills December through
7 March. Intermountain's average customer charge is $5.50
8 per month. Utah Power and Light does not have a customer
9 charge but has a $9.57 monthly minimum bill. Currently i
10 Idaho Power's customer charge is $2. 5l per month. Idaho
11 Power's proposed $lO. 00 charge is well outside the range
12 of fixed customer charges previously approved by the
13 Commission.
14 Q.What comments do you have regarding Idaho
15 Power's proposal to change its account initiation and
16 reconnect ion charges?
17 A.Idaho Power is doing more than just proposing
18 to change what it charges for setting up new customer
19 accounts and reconnecting service. It has carried the
20 cost of service approach into the realm of non-recurring
21 charges, and in doing soi has redefined the services it
22 provides. Under the Company's proposal, when a customer
23 signs up for new service and the Company does not have to
24 physically connect service, a flat $20.00 fee applies. If
25 the customer signs up for service at a premise that was
CASE NO. IPC-E-03-1302/20/04 PARKER 1M. (D i) 7
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1 previously disconnected by the Company i the customer will
2 pay a charge that varies by type of customer and time of
3 day the service is rendered. A customer who is
4 disconnected for non-payment would also pay this variable
5 charge.
6 Al though Idaho Power's approach is unique,
7 Staff generally agrees with the underlying concept of
8 aligning charges with costs. Staff notes that where there
9 is no significant difference in cost between setting up an
10 account and reconnecting service i the proposed charges are
11 identical. For example, whether a Company service
12 technician goes out during regular working hours to simply
13 read a meter or to read the meter and physically connect
14 service i a customer served under Schedule 1 i 7 i or 9 will
15 pay $20.00.
16 Q.Are there factors other than cost to take into
17 consideration when determining the amount to charge for
18 reconnect ion?
19 A.Yes. The Commission should be sensitive to
20 the fact that customers who are disconnected for non-
21 payment may be experiencing financial difficulties. The
22 charge should not be set so high as to create a barrier to
23 getting reconnected. On the other handi the charge should
24 be sufficient to encourage customers to payor make
25 payment arrangements and so avoid disconnection. Under
CASE NO. IPC-E- 03 - 13
02/20/04
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1 the Company's proposal, residential (Schedule i) and
2 commercial customers served under Schedules 7 and 9 will
3 see a $5.00 increase forreconnection requested during the
4 hours of 8: 00 a. m. and 6: 00 p. m. i Monday through Friday.
5 Charges for reconnect ion requested outside of those hours
6 or on hol idays and weekends remain unchanged.
7 Q.The Company is also proposing to increase its
8 Field Collection Charge from $15.00 to $20.00. Do the
9 same concerns apply to that charge?
10 A.Yes. This charge is assessed when a customer
11 pays the past due bill to avoid disconnection of service
12 to the Company representative who has been dispatched to
13 disconnect service for non-payment.
14 Q.How do the proposed charges compare with
15 existing charges for other energy utilities?
16 A.Exhibit No. 139 compares the existing charges
17 for all regulated energy utili ties. Idaho Power's
18 proposed Service Establishment Charge will be higher than
19 for any utility except Atlanta Power. Utah Power and
20 Avista do not charge customers for setting up new service
21 during regular business hours. The proposed charge for
22 physically connecting service for customers served under
23 Schedules 11 7, and 9 from 8:00 a.m. to 6:00 p.m. will be
24 the same as or lower than those of other energy utilities.
25 The proposed Field Collection Charge will be higher than
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1 all other energy utilities.
Q.Does Staff support the proposal to change the
3 name of these charges?
4 A.Staff supports the change from Account
5 Initiation Fee to Service Establishment Charge in
6 reference to the fee for setting up new service. However i
7 given the change in circumstances under which the charge
8 for turning on service (Reconnection Fee) will apply i
9 Staff does not support renaming it Service Reconnection
10 Charge. As proposedi the charge will also apply to
11 customers who are just establishing service but require a
12 physical connection as well as customers who recently were
13 disconnected, usually due to non-payment. The term
14 "reconnection" has credit connotations to which a new
15 customer might obj ect . It might also be confusing i since
16 a new customer typically thinks they are connecting rather
17 than reconnecting. For those reasons i Staff recommends
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18 that the charge be called a Service Connection Charge.
Q.Other than the suggested name change i does
20 Staff support Idaho Power's proposal with respect to these
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21 non-recurring charges?
A.Yes. Although the proposed charges will in
23 many cases be higher than the current charges assessed by
24 other energy utilitiesi they are cost-based and not
25 excessive.
CASE NO. IPC-E-03-13
02/20/04
PARKER, M. (Di) 10
STAFF
1 Q.Do you have concerns regarding Idaho Power's
2 proposal for implementing seasonal rates?
3 A.Yes. From the customer service perspective i
4 Staff believes this will generate many phone calls to the
5 Company throughout the summer months from customers
6 complaining about high bills and prorated bill statements.
7 The Company had a difficult time dealing with additional
8 incoming telephone calls when rates were high and the PCA
9 tiered rate structure was in effect from May 2001 to May
10 2002. In 2001 and 20021 actual Company service levels
11 were rarely above its own service level standard of
12 answering 80% of incoming calls within 30 seconds.(Many
13 companies i including Idaho Power i measure call-answering
14 performance using call center industry standards called
15 "service levels." The term "service level" represents the
16 percentage of incoming calls answered within a defined
17 number of seconds.) A seasonal rate structure will have
18 an impact on customers similar to that of tiered rates.
19 If seasonal rates or tiered rates are adoptedi the Company
20 will need to be prepared to handle an increase in the
21 number of incoming calls.
22 According to the Company i because of past
23 experience, the Company's Customer Service Center staff is
24 better prepared to answer customer questions regarding how
25 bills are calculatedi particularly those related to
CASE NO. IPC-E-03-1302/20/04 PARKER, M. (Di) 11
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1 prorating and tiered rates. Additionally i the Customer
2 Service Center now has more part-time employees who can be
3 scheduled to provide adequate telephone coverage.
4 Overall i the Company says it is better positioned to
5 handle the increased volume of calls.
6 Q.What kinds of problems do you foresee with
7 regard to prorating of bills?
8 A.If past events are any indicationi the Company
9 can expect increased calls from confused customers wanting
10 an explanation of the itemization of charges that will
11 appear on the bills at the beginning and end of the summer
12 rate timeframe. That is because the Company's proposal is
13 to make the summer rates effective specifically from June
14 1 to August 31 each year i irrespective of billing periods.
15 To illustrate the prorating problem, if the
16 proposed summer rates become effective on June 1st i a
17 customer in a billing cycle where the meter is read on or
18 about the 15th of each month would receive a bill in June
19 that was calculated based on meter readings dated May 15th
20 to June 15th. However, the bill would have one line item
21 calculating the kWh charge at the non-summer rate from May
22 15th to June 1st and then another line item calculating the
23 summer rate from June 1st to June 15th. Due to billing
24 system limitationsi the Company prorates not only the kWh
25 charges, but all other charges or credits on the bill when
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1 there is more than one kWh rate being used in a billing
2 period. The Federal Columbia River Benefit supplied by
3 BPAi the customer charge, the franchise fee i and demand
4 charges are prorated between the two billing periods. The
5 split entries of prorated charges leads to unwieldy bills
6 and confused customers, many of whom think they are being
7 double billed.
8 Q.Are there any billing alternatives that would
9 eliminate the need for prorating Schedule 1 i 7 i and 9
10 bills?
11 A.Yes.' Intermountain Gas Company has seasonal
12 rates that begin and end based on the customer's billing
13 period rather than specific calendar dates. If Idaho
14 Power adopted this methodology for billing i the Company
15 would state in its tariff that for billing periods ending
16 July through September, the summer rate would be in
17 effect; for billing periods ending October through June i
18 the non-summer rate schedule would be in effect. This
19 methodology eliminates opportunities for error associated
20 with billing outside of established billing periods. It
21 will also avoid confusing customers with unnecessarily
22 complicated billing formats.
23 Another option to reduce the need to prorate
24 bills would be to use a format similar to Idaho Power's
25 own rate design used for its Schedule 24 customers. In
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1 the Schedule 24 tariffs i irrigators are billed beginning
2 with meter readings taken for the first billing period in
3 May and end with the meter readings taken for the
4 September billing. Using billing periods that are not
5 date specific will reduce the need for prorations.
6 Exhibit No. 140 is an example of a customer's prorated
7 bill from May of 2002. An Idaho Power customer with a PhD
8 in Economics provided this bill to the Commission Staff to
9 show how complicated the billing was and how difficult it
10 was to decipher how it was calculated. Given the
11 difficulty this person had in understanding a prorated
12 billi it is not surprising to find that others have
13 trouble interpreting their bills. It should be noted that
14 having a PCA rate go into effect on a specific date in the
15 billing period when summer rates go into effect will cause
16 bills to be prorated i but that would happen only once in
17 the summer and not twice. Another option would be to
18 alter the billing system with respect to regular cycle
19 billings so that any fixed charges or credits are not
20 prorated due to seasonal rates or PCA adjustments.
21 Q.Does Staff have a preferred solution to the
22 problem?
23 A.Yes. Staff recommends that seasonal rates go
24 into effect based on billing periods rather than specific
25 calendar dates. Another acceptable alternative would be
CASE NO. IPC-E- 03 - 1302/20/04 PARKER i M. (Di) 14
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1 to alter the billing system so that fixed charges such as
2 franchise feesi customer charges i and BPA credits are not
3 prorated.
4 PROPOSED TARIFF REVISIONS
5 Q.What comments do you have concerning the
6 Company's proposal to revise Rule D, Section 6, of its
7 tariff?
8 A. Rule D addresses the general topic of
9 metering. Section 6 specifically addresses meter reading.
10 The Company is proposing to add the following sentence:
11 "The Company reserves the right to modify meter reading
12 schedules as required by changing conditions." This
13 proposed change is shown in context on page 14 of Company
14 witness Brilz's Direct Testimonyi Exhibit No. 48. It is
15 unclear what the Company means by its reference to
16 "changing conditions." Staff agrees that the Company
17 should have flexibility in establishing meter-reading
18 schedules. However, in Staff's opinion, this language is
19 overly broadi granting the Company total discretion with
20 no defined parameters. Staff recommends that the
21 Commission not approve the addition of this sentence to
22 the Company's tariff as written.
23 Q.The Company is proposing to change its tariff
24 to include its Rule Li Depositsi as shown on page 51 of
25 Company witness Brilz's Direct Testimony, Exhibit No. 48.
CASE NO. IPC-E-03-1302/20/04 PARKER i M. (Di) 15
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1 Do you agree with the Company's proposal regarding the
2 deposit calculation methodology for Large Commercial and
3 Special Contract Customers?
4 A.In Staff's opinion, this is a good idea. New
5 businesses inherently have a higher level of risk. It is
6 reasonable for the Company to request an amount sufficient
7 to cover anticipated usage over a designated period of
8 time. However i Staff suggests some al ternati ve wording to
9 that proposed by the Company in order to clarify intent.
10 Specifically i the Company indicates it may collect a
11 deposit from an applicant or customer in a situation where
12 "the current status of the Customer's business does not
13 pass an obj ective credit screen." The reference to
14 "current status of the Customer's business" is somewhat
15 vague. Exhibit No. 141 shows Staff's recommended changes
16 to the Company's proposed text.
17 LOW-INCOME ISSUES, PAYMENT OPTIONS, AN SPECIAL NEED
18 CUSTOMERS
19 Q.What impact will the overall rate design have
20 on low-income residential customers?
21 A. Under the Company's rate proposal, all
22 customers i including low-income customers i will be
23 impacted based upon usage. With the proposed rate designi
24 the more power a customer uses, the less he or she will be
25 impacted. For example i in a chart prepared by the Company
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1 (see Company witness Brilz Direct Testimonyi Exhibit No.
2 441 page 1) 1 a customer who uses an average of SOO kWh per
3 month will see a 23.34% increase under the proposed
4 design. By comparisoni a customer who uses an average of
5 1,200 kWh per month will see a 17.72% increasei and a
6 customer who averages 2,000 kWh per month will see a
7 13.07% overall increase.
S Q.Do Idaho Power's low-income customers have any
9 options if they have difficulty paying their bills?
10 A.Yes. Customers who meet the eligibility
11 guidelines can receive help through the federally funded
12 Low Income Home Energy Assistance Program (LIHEAP).
13 Customers can apply for financial assistance by contacting
14 their local Community Action Agency. Other fuel funds are
15 also available. For example 1 customers seeking Proj ect
16 Share funds can contact the Salvation Army anywhere in the
17 Idaho Power service territory.
1S Addi tionally, some low- income customers may
19 qualify to have their homes weatherized at no charge
20 through the Weatherization Assistance Program (WAP). This
21 program is also administered by local community action
22 agencies. Customers can call the Company or the
23 Commission to get information about where to go or who to
24 call about LIHEAP1 Project Sharei weatherization or energy
25 conservation. Idaho Power provides detailed information
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1 about LIHEAP to its customers in bill inserts. The
2 January 2004 edition of "Consumer Connection," the
3 Company's monthly customer newsletter 1 also listed the
4 contact information for community action agencies
5 throughout the service terri tory.
6 Q.Does Idaho Power make contributions to low-
7 income programs?
8 A.Idaho Power shareholders give $25/000 annually
9 to the Proj ect Share fund. Idaho Power also gives
10 $252/000 annually to WAP; this amount is included in Idaho
11 Power's rate base as an energy conservation expenditure.
12 Idaho Power also collects and forwards to the Salvation
13 Army Proj ect Share contributions made by customers who
14 voluntarily include extra amounts when paying their power
15 bills. Company shareholders 1 in turni pay the Salvation
16 Army an administration fee equal to 10% of whatever is
17 collected each year from its customers who give to Project
18 Share. For example, in 20021 a total of $179/817.83 was
19 collected in donations from customers for Proj ect Share.
20 Idaho Power shareholders gave the Salvation Army
21 $17/981.78 for an administration fee in that year.
22 Q.Does Idaho Power promote the Winter Pay
23 Program when customers call to declare the need for winter
24 moratorium protection?
25 A.The Winter Pay Program is required by Rule 306
CASE NO. IPC-E- 03 - 1302/20/04 PARKER 1 M . (D i) 18
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1 of the Utility Customer Relations Rules (UCRR) to be
2 offered to any residential customer who calls a regulated
3 gas or electric company to declare protection from
4 disconnection during the winter months because he or she
5 is unable to pay a bill in full and whose home includes
6 children, elderlyi or infirm. The Winter Pay Program
7 al lows a customer to pay each month an amount equal to
8 one-half of what a Level Pay amount would be for that
9 residence. The other significant benefit to the
10 participating customer is that, provided payments are made
11 as required each monthi he or she is afforded two extra
12 months of protection from disconnectioni i. e. 1 November
13 and March. Ordinarily 1 the protection from disconnection
14 is for the three winter months of December 1 January 1 and
15 February.
16 In a survey of the four maj or Idaho electric
17 and gas utilitiesi Idaho Power had 178 customers on the
18 Winter Pay program for the heating season of 2002-03.
19 This exceeded the participation rate of the other surveyed
20 companies. Two of the companies had no one signed up for
21 Winter Pay and the other company had 7 customers signed
22 up.
23 Q.Do you believe Idaho Power does an adequate
24 job of accommodating customers who cannot pay a bill in
25 full?
CASE NO. IPC-E-03-1302/20/04 PARKER 1 M . (D i) 19
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1 A.The Company centralized its customer service
2 functions several years ago. One of the goals and
3 benefits of centralization is to ensure that all customers
4 are treated equitably. Since the last rate case (Case
5 No. IPC-E-94-5) 1 the Company implemented an Interactive
6 Voice Response (IVR) system that allows customers to call
7 and make payment arrangements over the phone without
8 having to wait "on hold" to talk to a customer service
9 representative. Customers who feel uncomfortable with
10 this type of technology still have the option to wait for
11 the next available representative. The Company is willing
12 to enter into payment arrangements with customers.
13 Q.What payment options are available to
14 customers?
15 A.One of the options for a payment arrangement
16 is levelized billing. Simply stated 1 levelized billing
17 establishes 12 equal monthly installments by combining the
18 amount past due divided by 12 with the customer's
19 projected 12-month average bill. The customer would be
20 required to pay that amount every month on time. When the
21 customer is given a levelized billing payment plan and
22 misses a payment 1 the Company is not as lenient when
23 second payment arrangements are requested.
24 Customers who have a history of broken payment
25 arrangements are held to a stricter standard because they
CASE NO. IPC-E- 03 - 13
02/20/04
PARKER 1 M . (D i) 20
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1 pose a greater credit risk to the Company. Staff believes
2 the majority of customers calling the Company to ask for
3 payment arrangements are treated fairly. In those
4 instances where the customer does not believe they have
5 received fair treatment, he or she has the option of
6 contacting the Commission to file a complaint. Idaho
7 Power Customer Service Representatives are required by
8 Commission Rule 305 to advise aggrieved customers of their
9 right to file a complaint.
10 Q.What is the difference between Budget Pay and
11 Levelized Pay?
12 A.Budget Pay is promoted on residential and
13 small commercial bills three times a year. However 1 a
14 customer in good standing with no past due amounts can
15 call in at any time to sign up for Budget Pay. Budget Pay
16 is equal to the 12 -month average of a customer's kilowatt-
17 hour usage times the current rate. On the one-year
18 anniversary date the amount is reviewed andi if necessaryi
19 adjusted. Because customers on Budget Pay are considered
20 by the Company to have a good credit rating, they have
21 more leeway on when payments can be made. A customer on
22 Budget Pay would not be sent a Reminder Notice until a
23 bill was two months past due. Levelized Pay 1 on the other
24 handi is similar to Budget Pay in its calculation but
25 requires strict adherence to monthly payments being made
CASE NO. IPC-E- 03 - 1302/20/04 PARKER i M. (Di) 21
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1 on time because it is considered a payment arrangement.
3 customers who have severe disabilities 1 diminished mental
Q.How does the Company address the needs of
4 capacity or are otherwise in need of additional
5 assistance?
6 A.In a situation where a front line customer
7 service representative determined more personal attention
8 should be given to a special needs customer 1 the customer
9 would normally be transferred to one of five Idaho Power
10 Customer Service Coaches or two Coach Assistants. Coaches
11 and Coach Assistants are experienced Idaho Power customer
12 service representatives in lead or supervisory roles.
13 CUSTOMER SERVICE CENTER AN OUTAGE MAAGEMENT OPERATIONS
14 CENTER
15 Q.Quicki easy access to information and
16 assistance and responsiveness to customers' concerns are
17 essential elements of good customer service. How has
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18 Idaho Power performed in these two areas?
A.Idaho Power has taken steps to remedy problems
20 it has identified. Improvements in accessibility and
2 1 responsiveness have been achieved primarily through
22 technological enhancements in the Customer Service Center
23 and Outage Management Operations Center.
24 Q.How does Idaho Power compare to other energy
25 companies regarding its ability to answer incoming
CASE NO. IPC-E-03-1302/20/04 PARKER, M. (Di) 22
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1 customer service calls in a timely manner?
2 A.According to the Edison Electric
3 Institute/American Gas Association (EEI/AGA) in its 2002
4 annual data source survey 1 the average service level (the
5 percentage of calls answered within a defined number of
6 seconds) among the 62 reporting utility companies was
7 73.8% of calls answered in 32.3 seconds. Idaho Power set
8 its internal service level goal at answering 80% of
9 incoming customer calls within 30 seconds 1 slightly better
10 than the average service level among the companies
11 included in the EEI/AGA survey.
12 Q.Is Idaho Power's goal reasonable?
13 A.Yes. In Staff's opinion, service levels of
14 80% of calls answered within the range of 20-30 seconds
15 are reasonable.
16 Q.In the past three years 1 has the Company met
17 its goal?
18 A.No. There were three spans of time in the
19 past three years where the Company fell short of its
20 internal service level goal. Those times were January
21 through June of 20011 September through December of 20011
22 and January through July of 2002. During the block of
23 time from January through June 20011 the Company pointed
24 to a 16% reduction in staffing due to attrition. In the
25 September through December 2001 time periodi the Company
CASE NO. IPC-E- 03 - 13
02/20/04
PARKER i M. (Di) 23
STAFF
1 was still recovering from staffing reductions 1 the tiered
2 rate questions, as well as a learning curve associated
3 with implementation of a new customer information computer
4 system installed in November 2001. The Company stated
5 that in January of 2002 through July 20021 the volume of
6 inbound calls increased by 6% and call-handling time was
7 longer. According to the Company 1 many customers were
8 confused as to how the bills were calculated under the
9 tiered rate design. It took more time for customer
10 service representatives to help customers understand their
12
11 bills.
Q.Has the Company improved its performance
14
13 recently?
A.Yes. It has been meeting or exceeding its
15 service level goal since July of 2002.
16 Q.To what does the Company attribute its success
17 regarding its ability to answer 80% of incoming calls
19
18 within 30 seconds?
A.In April 20021 the Company hired temporary
20 agents to assist during periods of increased call volumes
21 and call handling times. Additionally 1 the tiered
22 residential rate design was discontinued in May 20021
23 eliminating one cause of customer confusion and
24 discontent. The Company also implemented a customer
25 service oriented training program that helped customer
CASE NO. IPC-E- 03 - 1302/20/04 PARKER, M. (Di) 24
STAFF
1 service representatives better manage incoming calls.
2 According to the Company, this program emphasizes multi-
3 tasking and first call resolution and is still a part of
4 its customer service-training regimen.
5 Q.How does the Company handle calls from
6 customers who are reporting outages or emergencies?
7 A.The Company has a separate Outage Management
8 Operations Center. Customers calling the outage telephone
9 number reach an IVR with prompts to direct the call to the
10 proper customer service representative. Most customers who
11 call the outage telephone number are calling to verify that
12 the Company knows there is a power outage in their area.
13 The power outage customer information messaging system is
14 updated within minutes of confirmed outages. The recorded
15 message continues to be updated at least every twenty
16 minutes or as more information is obtained. The message
17 also tells the customer what the Company is doing with
18 regard to the outage andi when possible 1 gives an estimated
19 time of repair. If the customer determines that his or her
20 area is not identified as having an outage i he or she is
21 then advised how to report the outage to a customer service
22 representative. If the customer is experiencing a life..
23 threatening emergency related to the outage i he or she is
24 directed to immediately call 9- 1 - 1. The message to call
25 9-1-1 comes immediately following the customer saying
CASE NO. IPC-E-03-13
02/20/04
PARKER i M. (Di) 25
STAFF
1 "Outage."
2 Service levels are also measured for the
3 Outage Management System. From January through October of
4 20031 performance has been extremely good with an overall
5 service level of 96.7% of its calls answered within 30
6 seconds.
7 Q.In what other ways has the Company improved
8 its responsiveness to outages?
9 A.In the years prior to the establishment of the
10 Outage Management Operation Center in the summer of 20021
11 Idaho Power realized it had communication issues between
12 the Company and its customers during outages. This was
13 especially true as it related to relaying accurate
14 information about outages from customers to the proper
15 personnel so that repairs could be handled quickly and
16 efficiently. The Outage Management Operations Center has
17 centralized dispatching and integrated operations with the
18 Customer Service Center. Because they are trained in
19 customer service skillsi staff from the Customer Service
20 Center is now assigned to the Outage Management Operations
21 Center. Dispatchers and other technical staff are now able
22 to focus on restoring service while the Customer Service
23 Representatives interact with the customers.
24 Q.How has the Outage Management Operations
25 Center benefited the Company and its customers?
CASE NO. IPC-E- 03 - 1302/20/04 PARKER i M. (Di) 26
STAFF
1 A.Most customers that call regarding an outage
2 merely want to know if the Company is aware of an outage
3 and to find out if any information is available regarding
4 the estimated time of repair. The maj ori ty of customers
5 are now finding answers to their questions within moments
6 of placing the call. For the Company 1 this system has
7 allowed it to provide good customer service by keeping
8 customers informed and updatedi particularly during those
9 times when large numbers of customers are affected by an
10 outage. The IVR has also reduced the need to hire
11 additional customer service representatives to answer calls
12 that are handled efficiently and effectively by the IVR
13 system.
14 CUSTOMER RELATIONS
15 Q.Please describe how many and what type of
16 complaints and inquiries the Commission has received
1 7 regarding Idaho Power?
18 A.Exhibi t No. 142 shows the number of informal
19 complaints and inquiries received over the past four
20 years. The Commission received significantly more
21 complaints and inquiries in 2001 and 2002 than in 2000 and
22 2003. During 2001 and 20021 complaints fell into three
23 main categories: credit and collections, billing, and
24 rates and policies. This is not surprising because during
25 that timeframe customers paid more per kilowatt-hour than
CASE NO. IPC-E-03-1302/20/04 PARKER i M. (Di) 27
STAFF
1 they had ever paid, tiered rates were introducedi and a
2 new billing system installed. As Exhibit No. 142 shows i
3 the number of complaints and inquiries dropped off
4 considerably in 20031 returning to similar levels recorded
5 four years ago.
6 Q.What did your analysis of complaints received
7 by the Commission in 2003 reveal?
8 A.The majority of complaints still fall within
9 the three categories mentioned above. Of the 612
10 complaints receivedi the majority (58%) concerned credit
11 and collection issues. Most of these credit and
12 collections issues involved actual or threatened
13 disconnection of service, a clear indication that some
14 customers continue to have difficulty paying their Idaho
16
15 Power bills.
18
17 customers?
Q.Was the Commission able to help these
A.In 52% of the 329 complaints involving
19 disconnection, the Company's original course of action was
20 modified during the Staff's investigation. In most
21 instances 1 Staff was able to assist the customer in
23
22 negotiating acceptable payment arrangements.
Q.How does Idaho Power compare with other maj or
24 Idaho energy companies with regard to the number of
25 complaints and inquiries to the Commission?
CASE NO. IPC-E- 03 - 1302/20/04 PARKER i M. (Di) 28
STAFF
1 A.Except for the year 20001 the number of
2 complaints and inquiries per 1,000 customers was higher
3 for Idaho Power than other regulated energy utilities.
4 The numbers reflected in Exhibit No. 143 are not
5 indicative of a particular problem with Idaho Power's
6 customer relations other than the obvious impact that
7 increasing rates and higher bills have on customers.
8 Q.Is Idaho Power responsive to the Commission's
9 Utility Compliance Investigators during complaint
10 investigations?
11 A.Yes. The average length of time in which
12 Staff was able to resolve Idaho Power's customer
13 complaints during 2003 was 3.31 days. The average time
14 among all Idaho regulated electric companies was 3.93
15 days.
16 Q.What observations do you have about the
18
17 Company' s Website?
A.The Company' s Website is easy to navigate.
19 There are many customer service features available that
20 save the Company and the customer time and money. For
21 example 1 a customer can pay a bill using a credit card or
22 check-by-phone using the Company's Website. A customer
23 can use the Website to locate the nearest pay station. If
24 a customer wants to receive monthly billing statements
25 onlinei the customer can set up on the Website and
CASE NO. IPC-E- 03 - 13
02/20/04
PARKER i M. (Di) 29
STAFF
1 eliminate the need for the Company to print and mail a
2 paper bill. Many customers are signing up to receive
3 bills over the Internet. Currently about 6/000 customers
4 have signed up for this service, which is handled by a
5 third-party vendor.
6 Two significant functions that are not
7 available online are customer requests to connect or
8 disconnect service. A customer that wishes to signup for
9 service or disconnect service must still call the Customer
10 Service Center.
11 Q.Has the Company added any other significant
12 technology-based customer service features recently?
13 A.Yes. A few years ago 1 Idaho Power added the
14 previously mentioned IVR system that allows customers to
15 call the Company at any time of day or night. By
16 following the prompts 1 customers can get a recording that
17 informs the customer of what amount is due on the
18 customer's account, when the customer made the last
19 payment 1 and the amount of the last payment. The customer
20 is also able to make payment arrangements on past due
21 bills using the IVR. In 2004, the Company enhanced the
22 system with speech recognition capabilities. After being
23 greeted with "Thank you for calling Idaho Power," the
24 customer is told to say one of the following: "Outage,
25 Residential Services, Irrigation or Commercial, or New
CASE NO. IPC-E-03-1302/20/04 PARKER 1 M. (Di) 30
STAFF
1 Construction or Electricians." This new, friendlier
2 approach to IVR use should help put some elderly 1
3 technology-challengedi or physically limited customers at
4 ease when calling the Company.
5 The other significant benefit of this system
6 is that there is only one number to call. For example i a
7 customer no longer needs to search through the telephone
8 book to find a separate number to report a power outage.
9 Q.Do you believe Idaho Power provides adequate
10 customer assistance for non-English speaking customers?
11 A.The Company has indicated to Staff that it
12 always has at least one Spanish-speaking person available
13 on any given shift. If the customer calling indicates he
14 or she would like to speak to a Company representative
15 that speaks something other than English or Spanishi the
16 Company utilizes a third-party interpretation service that
17 provides three-way telephone calling capabilities.
18 Because the interpretation service has the ability to
19 translate 108 languages, Staff believes this is an
20 exceptional service provided for anyone who speaks
21 languages other than English and Spanish. Idaho Power
22 also uses this service if the Company's on-shift Spanish-
23 speaking representative is already assisting another
24 customer.
25 Q.Does Idaho Power provide adequate bill -related
CASE NO. IPC-E-03-1302/20/04 PARKER, M. (Di) 31
STAFF
2
1 and/or other information for Spanish-speaking customers?
A.The Company does not print any of its bills or
3 disconnect notices in Spanish. However 1 the Company has
4 seven brochures and pamphlets that are available in
5 Spanishi including a brochure on conservation as well as a
6 Summary of the Utility Customer Relations Rules. Staff
7 recommends that the Company add a sentence in Spanish in a
8 prominent location on bills and disconnect notices to
9 inform Spanish speakers that if help is needed
10 understanding what the customer's statement or notice
11 saysi that he or she may call the Company for further
13
12 information.
Q.Are the Company's available Spanish resources
14 frequently used by customers?
15 A.Unfortunately 1 the information and services
16 available are underutilizedi perhaps because customers are
17 not aware of what is offered. The Company should better
18 promote the information and services available to Spanish-
19 speaking customers. One way this could be accomplished is
20 by adding a prompt in Spanish for those waiting on hold
21 that a Spanish-speaking representative is available upon
22 request. Spanish-speaking customer service
23 representatives should always inform Spanish-speaking
24 customers of the written information available in Spanish.
25 The Company indicated that its Spanish
CASE NO. IPC-E- 03 - 1302/20/04 PARKER i M. (Di) 32
STAFF
1 language brochures are available to those who request
2 them. This is a Catch-22 for Spanish-speaking customers i
3 in that they are expected to ask for something that they
4 do not know exists. The Company informed Staff that it
5 was currently working on improving its Spanish-language
6 communications. In February of this year i a sentence in
7 Spanish was added to all the English versions of the
8 Summary of the Utility Customer Relations Rules indicating
9 that a Spanish version was available upon request.
10 Q.What is the Hispanic population in the
12
11 counties served by Idaho Power?
A.According to the 2000 Census i ioii 690
13 Hispanics resided in Idaho. In the 28 counties served by
14 Idaho Power i there were 81 i 758 Hispanics. The overall
15 percentage of Hispanics in Idaho in 2000 was 7.9 percent.
16 In counties served by Idaho Power, the average percentage
17 was 11.5 percent. Some counties served by Idaho Power had
18 substantially higher Hispanic populations than others.
19 For example i Canyon i Cassiai Gooding i Jerome i Minidokai
20 and Power counties all had Hispanic populations greater
21 than 1 7 percent i wi th Minidoka having the highest
22 percentage at 25.5%. Given the significant number of
23 Hispanic people in Idaho Power's service terri tory, it is
24 certainly necessary that the Company determine how to
25 effectively communicate with its Spanish-speaking
CASE NO. IPC-E-03-1302/20/04 PARKER i M. (Di) 33
STAFF
1 customers.
2 Q.Do you think the number of Hispanic people in
3 Idaho Power's service territory indicates the Company
4 should be doing more for its Spanish-speaking customers?
5 A.In its review of Spanish communications i the
6 Company should evaluate the need for bills and delinquent
7 notices to be printed in Spanish. The Company should
8 consult with organizations such as the Idaho Migrant
9 Council to gather information about the customer service-
10 related needs of Hispanic people in the Company's service
11 territory.
12 Q.Do you think the Company should provide better
13 customer service for customers who speak languages other
14 than English or Spanishi such as Bosnian or Russian?
15 A.The fact that a person who speaks Bosnian or
16 Russian can request a third-party translator is adequate
17 at this time. The Consumer Staff has never received a
18 complaint on behalf of a person who speaks a language
19 other than English or Spanish saying they thought the
20 Company ought to provide them with more options in their
21 native language. The small population of people that
22 speak languages other than English and Spanish in Idaho at
23 this time does not justify requiring the Company to
24 develop brochures and pamphlets in additional languages.
25
CASE NO. IPC-E- 03 - 1302/20/04 PARKER i M. (Di) 34
STAFF
1 OUT-OF-CYCLE METER READINGS
2 Q.In your review of Company procedures wi th
3 regard to out-of -cycle meter reading and billing i did you
4 find anything of concern?
5 A.Yes. Out-of-cycle meter readings are
6 necessary when customers move i change billing
7 responsibilityi or request physical disconnection of
8 service. An Idaho Power bill resulting from an out-of-
9 cycle meter reading reflects the customer's requested date
10 of action - not the date the meter was actually read.
11 Staff believes this practice should be changed. Customers
12 expect bills to be based on beginning and ending meter
13 readings that correspond to the billing period. Using
14 meter-reading dates that do not correspond to the billing
15 period misleads customers and undermines the integrity of
16 the billing process.
17 Q.What is the Company's process when a customer
18 informs the Company he or she is moving and to stop
19 billing?
20 A.The Company indicated that with respect to
21 residential and small commercial customers i it does not
22 routinely disconnect service between occupants because
23 typically there is little time delay in new customers
24 signing up for service after the former customer requests
25 disconnection.
CASE NO. IPC-E-03-1302/20/04 PARKER i M. (Di) 35
STAFF
1 In situations where an out-of-cycle meter
2 reading is taken to close an account and the meter is not
3 physically disconnected, the Company indicated that
4 approximately 93% of the readings for residential and
5 small commercial customers are taken within 3 calendar
6 days i approximately 5% of the readings are taken within 4-
7 5 calendar days i and the remaining 2% are not read for
8 more than 5 calendar days. In 2003 i Idaho Power performed
9 more than 100,000 out-of -cycle meter readings for
10 residential and small commercial accounts where power was
11 not disconnected.
12 Q.Are there circumstances where the Company
13 physically disconnects service?
14 A.The Company indicated that when a service
15 technician arrives at a premises and it is obvious that no
16 one is occupying the home or business and no new customer
17 has signed up for servicei the meter is always
18 disconnected. According to Idaho Power i for those
19 accounts where service was physically disconnected in
20 20031 95% of residential and small commercial meters were
21 read and disconnected within 3 calendar days of the
22 customer's requested date. Approximately 2% of requests
23 were processed within 4-5 calendar days after the
24 customer's requested date and the remaining 3% took more
25 than 5 calendar days to complete. Idaho Power conducted
CASE NO. IPC-E-03-13
02/20/04
PARKER i M. (Di) 36
STAFF
1 more than 20 i 000 actual residential and small commercial
2 disconnects last year.
3 Q.Should the Company be required to always read
4 meters and/or disconnect service on the date customers
6
5 request?
A.No. The Company needs a reasonable amount of
7 time to respond to a customer's request. A work
8 completion interval of up to 3 calendar days in the
9 majority of circumstances is reasonable. An interval of
10 up to 5 calendar days is reasonable for chose situations
11 where weather, the customer's remote location, or other
12 issues delay work. One example where the Company might
13 justifiably not be able to take an out-of-cycle meter read
14 within 3 days is in a remote service area such as Garden
15 Valley. The Company routinely goes to Garden Valley twice
16 a weeki but depending upon some factors such as weather
18
17 may only go once a week.
Q.If a customer requests disconnection of
19 service for a specific date and the Company does not read
20 the meter and disconnect service for 5 days beyond the
21 requested datei who pays for the additional 5 days worth
23
22 of service?
A.The customer who was disconnecting service
24 would be responsible for payment up until the time of
25 disconnection. However, as stated earlier, the customer's
CASE NO. IPC-E- 03 - 13
02/20/04
PARKER, M. (Di) 37
STAFF
1 final bill would not reflect the actual date service was
2 disconnected.
3 Q.You stated earlier that Idaho Power does not
4 routinely disconnect service for residential and small
5 commercial customers. If service is not physically
6 disconnected between occupants i can other billing issues
7 arise?
8 A.Yes. Unless the date Idaho Power reads the
9 meter exactly coincides with both the date the departing
10 customer moves out and the date the new customer moves ini
11 the billing period will not match. The wider the gap of
12 time between requested dates and actual meter reading
13 and/ or disconnection dates i the more problematic billings
14 become. The Company needs to minimize the gaps that
15 exceed 3 calendar days.
16 Q.Are there any other scenarios where the
17 procedure of not actually turning off meters between
18 occupants can lead to billing issues?
19 A.Yes. Many landlords have verbal agreements
20 with the Company to not disconnect their rentals between
21 tenants. The agreement is that when a tenant moves out
22 and places a request to close his or her account i the
23 Company is allowed to simply transfer the billing
24 responsibili ty of the account into the landlord's name at
25 the time the tenant says he or she is moving out. Service
CASE NO. IPC-E-03-1302/20/04 PARKER, M. (Di) 38
STAFF
1 is not disconnected between tenants and the landlord is
2 responsible for paying for usage while the residence is
3 vacant. This introduces another level of complexity to
4 the billings and meter reading process because three
5 customers (the departing tenant i the landlordi and the new
6 tenant) are involved.
7 Q.Does Staff have other concerns with regard to
8 Idaho Power's handling of out-of-cycle meter readings and
9 disconnections?
10 A.Yes. It is not clear to Staff how the Company
11 determines what to use as a beginning reading for a new
12 customer moving into a location where the power was not
13 actually disconnected between occupants. It appears that
14 in some cases, the meter reading is used from when the
15 last occupant moved out; in other casesi it appears that a
16 new reading is obtained. It is staff's opinion that the
17 Company should establish a protocol that specifies when a
18 new reading should be taken.
19 Q.What do you consider a reasonable approach to
2 0 solving billing issues related to the Company's handling
21 of out-of-cycle meter readings?
22 A.Staff's position is that the billing period
23 ending date entered into the computer system and printed
24 on the customer's final bill should match the actual date
25 the meter was read and/or disconnected. Customers are
CASE NO. IPC-E- 03 - 1302/20/04 PARKER i M. (Di) 39
STAFF
1 entitled to accurate billing information. By providing
2 the correct date, the customer would have the option to
3 negotiate with the Company if he or she had an issue with
4 the length of time it took to read and/or disconnect the
5 meter. Likewise i the starting date on bills should
6 correspond with the actual reading date on which the bill
7 is based. In situations where the meter was physically
8 disconnectedi the meter reading should always be verified
9 at the time of reconnect ion for the new customer to make
10 certain the reading matches that taken on disconnection
11 date of the prior occupant.
12 Q.Have you discussed this matter with the
13 Company?
14 A.Yes. The Company understood Staff's concerns
15 and is examining its processes now. Staff anticipates
16 discussing proposed solutions with the Company by April of
17 this year.
18 Q.Did you review the Company's bills, notices,
19 forms i and other documents to ascertain compliance with
20 the Utility Customer Relations Rules (UCRR)?
21 A.Yes. Staff found that the Company was
22 generally in compliance with the UCRR. For those areas
23 where changes were necessary i Staff and the Company agreed
24 on solutions for bringing the Company into compliance.
25 Q.What were the significant non-compliant areas
CASE NO. IPC-E-03-1302/20/04 PARKER, M. (Di) 40
STAFF
1 in need of change?
2 A.Although required by UCRR 4011 4021 and 403,
3 the Company was not keeping a written record of complaints
4 and requests for conferences it received directly from
5 customers. The Company indicated it would begin tracking
6 complaints in accordance with the UCRR. The Company had
7 been keeping a detailed record of the complaints referred
8 to them by the Commission. However i the purpose of this
9 rule requirement is to encourage the Company to analyze
10 its own policies and processes using the valuable feedback
11 given by customers.
12 The second area of non-compliance was that the
13 Company had not developed a Summary of Utility Customer
14 Relations Rules for customers billed under Schedules 7 i 9 i
15 and 24 as required in Rule 701. In response to Staff's
16 findings i the Company prepared and began sending the
17 Summary with bills to these customers in February.
18 Staff also found that the Summary of Utility
19 Customer Relations Rules was not being provided to each
20 new customer upon commencement of service as required by
21 Rule 701. The Company committed to having the Summary
22 inserted into the initial bills of each new customer
23 within two months.
24 Q.Does this conclude your testimony?
25 A.Yes it does.
CASE NO. IPC-E- 03 - 13
02/20/04
PARKER i M. (Di) 41
STAFF