20090902Answer.pdf

LISA D. NORDSTROM
Senior Counsel
esIDA~POR~
An IDACORP Company
September 1, 2009
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-09-23
Everett A. Jameson v. Idaho Power Company
Dear Ms. Jewell:
Please find enclosed for filing an original and seven (7) copies of Idaho Power
Company's Answer in the above-referenced matter.
Very truly yours,
)f~ll.01~
Lisa D. Nordstrom
LDN:csb
Enclosures
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, 10 83702
LISA D. NORDSTROM (ISB No. 5733)
BARTON KLINE (ISB No. 1526)
Idaho Power Company
1221 West Idaho Street
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstrom(aidahopower.com
bkline(aida hopower. com
RECEIVED
2009 SEP -I PH 4= 53
Pl !~'''1 ~..1 D l\ HO .' ~ tj,~¡ t~ (', ,', ~~~',\J
UTILITiES COM~;,IS.)L¡,
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Respondent.
)
)
) Case No. IPC-E-09-23
)
)
) ANSWER
)
)
)
)
EVERETT A. JAMESON,
Complainant,
vs.
IDAHO POWER COMPANY,
Respondent, Idaho Power Company ("Idaho Power" or the "Company"), hereby
answers the Complaint of Everett A. Jameson in the above-entitled case as follows:
I. FACTUAL BACKGROUND
Mr. Everett Jameson is a customer of Idaho Power residing at 3206 McLeod Lane,
New Meadows, Idaho. On January 5, 2009, Mr. Jameson called Idaho Power and
ANSWER-1
requested that he be allowed to make partial payments on his past due account when he is
able to do so. Because he wished to make monthly payments of $30 rather than $56,
which would be half of the Level Pay Plan amount, Mr. Jameson did not qualify for the
Winter Payment Plan set forth in Utility Customer Relations Rule 306 (IDAPA
31.21.01.311). Due to the customer's age and health concerns, the Company's Customer
Service Representative instead placed Mr. Jameson's account under the protection of the
Winter Moratorium (also known as the "Cold Weather Rule") as provided by Utility
Customer Relations Rule 306 (IDAPA 31.21.01.306). The Winter Moratorium protects
customers with children and elderly or infirm residents from disconnection from December
through February regardless of payment amount or whether any payment is made. The
Customer Service Representative explained to Mr. Jameson that the Winter Moratorium
ended on March 1, 2009, and that he would need to make formal payment arrangements
prior to March 2009 for the remaining past due balance to avoid disconnection. The
Customer Service Representative noted the following in the customer's account: "Everett
called. . . set acct on CWR . . . is going to make partial payments when he can. . . aware
ends the end of Feb."
Between his January 5 phone call and disconnection on March 10, 2009, Mr.
Jameson made three payments of $30 each on January 7, January 30, and March 1,2009.
Idaho Power notified Mr. Jameson on four separate occasions after Mr. Jameson's
January 5 phone call that he needed to make payment arrangements. As it did with all
customers with a past due balance or subject to the Winter Moratorium, Idaho Power sent
Mr. Jameson a payment reminder notice on January 29,2009. On February 24,2009, the
Company sent Mr. Jameson an initial disconnection notice stating that disconnection was
ANSWER-2
scheduled for March 9, 2009, unless the account was brought current or payment
arrangements were made. According to the Company's records, Idaho Power's automated
system placed a call to the phone number listed on Mr. Jameson's account on February
27, 2009, at 1 :43 p.m. and left a voice message on a message recording system. On
February 29,2009, Idaho Power sent Mr. Jameson a final disconnection notice stating that
disconnection was scheduled for March 9,2009, unless the account was brought current or
payment arrangements were made. Mr. Jameson did not contact the Company in
response to these four notices.
As of March 10,2009, Mr. Jameson's account had a $482.26 past due balance and
Mr. Jameson had not entered into payment arrangements with the Company.
Consequently, an Idaho Power Meter Specialist disconnected Mr. Jameson's electric
service that day at 3:23 p.m. Mr. Jameson subsequently made a partial payment over the
telephone and power was restored that same day.
Mr. Jameson filed a formal Complaint with the Commission on June 24, 2009, with
regard to the disconnection of his electric service on March 10, 2009. Mr. Jameson's
Complaint also referenced dissatisfaction with the resolution of a damage claim filed with
Idaho Power in 2007.
II. DISCONNECTION NOTICE
In his formal Complaint to the Commission dated June 24, 2009, Mr. Jameson
alleges that Idaho Power "disconnected my service on March 6, 2009 without a phone call
or any written notice of their intent to do so" (date in original). Moreover, he claims Idaho
Power did not knock on his door to provide him with a final opportunity to pay in person.
ANSWER-3
Mr. Jameson also alleges that the Company did not leave a notice at the residence as
required by Utilty Customer Relations Rule 311 (IDAPA 31.21.01.311).
The Meter Specialist who disconnected Mr. Jameson's service states that it is his
usual practice, when he arrives at the residence of a customer with a past due account, to
pull up the account information on his mobile computer so that he can discuss the past due
amount with the customer. He then knocks on the front door; if the customer answers the
door, the Meter Specialist explains the amount owed and either accepts full/partial payment
or disconnects the power. If the customer does not answer the door, the Meter Specialist
leaves a door hanger explaining the time and grounds for disconnection of service, the
steps the customer can take to secure reconnection, and the telephone number to call to
have reconnection authorized. After disconnecting the power, the Meter Specialist
completes the order on his mobile computer. This is Idaho Power's standard practice and
is consistent with the training the Company provides its employees responsible for carring
out collection activities.
The Idaho Power Meter Specialist that disconnected Mr. Jameson's service
completed 359 collections and 289 connections/disconnections in the greater McCall area
during the four months between March 2009 and June 2009. Although he does not recall
the specific instance during which he disconnected Mr. Jameson's service, the Meter
Specialist is adamant that he knocked on Mr. Jameson's front door. The purpose of the
Meter Specialist's visit was to collect the past due balance and to disconnect service only if
the past due balance could not be collected. Failng to knock on the door would not have
achieved the primary purpose of his visit - collecting the past due account balance.
ANSWER-4
During the week of March 9, 2009, Idaho Power rolled out its new Mobile Workforce
Management system in the McCall area. The Mobile Workforce Management system is a
computer-aided dispatching and data communication system that optimizes Idaho Power's
crews and resources in the field. Prior to the Mobile Workforce Management System,
Meter Specialists printed out their credit and collection orders prior to leaving the office.
The second page of the collection order contained the specific account and reconnection
information required by Utilty Customer Relations Rule 311 (IDAPA 31.21.01.311) and was
left at the customer premises. With the new Mobile Workforce Management System, the
credit and collection information is electronic. The employees responsible for carrying out
collection activities were instructed to fil out a new door hanger form with customer-specific
account information. An example of the door hanger Idaho Power currently uses is
enclosed as Attachment NO.1.
Uncertain about some of the new processes used during the implementation of
Idaho Power's new Mobile Workforce Management system, the Meter Specialist who
disconnected Mr. Jameson's service admits that he did not have the new door hanger
forms for a short period of time coinciding with the first week of the system's rollout.
Therefore, it is possible that a door hanger was not left on Mr. Jameson's door. When the
Meter Specialist realized that he did not have the capability to print door hangers in the
field and did not have the preprinted forms, he contacted a field office outside the McCall
area for advice. (Due to the small number of customers in the McCall area, this Meter
Specialist was the only employee in the McCall field office trained to do credit and
collections.) The field office immediately sent him a supply of door hanger forms and
instructed him to conduct only collection activities (not disconnections) until he received the
ANSWER-5
new forms. Idaho Power has employed the Meter Specialist in question since August 2004
and has no record of prior complaints or discipline. In short, Idaho Power believes this
Meter Specialist to be an excellent employee.
Once made aware of the event by Mr. Jameson's Complaint, Idaho Power's
management scheduled a meeting with its field leadership to review and reinforce
compliance with the practices required by the Commission's Utility Customer Relations
Rules. All field employees wil have completed this review by the end of September 2009.
In addition, the same requirements wil be reinforced in the Company's refresher course on
proper collection, disconnection, and reconnection practices that takes place each year in
October and February.
II. 2007 DAMAGE CLAIM
Mr. Jameson's Complaint also references a 2007 claim he made seeking
reimbursement for damage to his television. On August 7,2007, at approximately 4:30
p.m., a wind storm caused tree limbs to fall onto an Idaho Power distribution line near Mr.
Jameson's residence and locked out the recloser. When closing the recloser, a step-down
transformer failed and needed to be changed out. When the new step-down transformer
was energized at approximately 9 p.m. that evening, several customers received high
voltage resulting in damage to electric appliances.
Idaho Power determined the new step-down transformer was faulty and replaced it,
restoring service to customers. The Company hired an independent adjuster to interview
employees about the event. Idaho Power brought the faulty transformer by semi truck to
its Transformer Testing Department at the Boise Operations Center for inspection and
ANSWER-6
contacted Howard Industries, the transformer manufacturer, to put them on notice of the
problem and the seventeen pending claims Idaho Power had received.
Each Customer presenting a claim was mailed a claim packet, including a claim
form, and contacted by telephone. They were advised of the pending liabilty investigation
and that this could take some time to resolve. The transformer was then sent to the
manufacturer, per its request. The manufacturer ultimately determined that the transformer
had been assembled incorrectly. Idaho Power determined that its crew had properly
installed the transformer. Consequently, the customers' damages - including Mr.
Jameson's - resulted directly from the defective transformer and not from negligence or
fault on the part of Idaho Power.
Idaho Power expected Howard Industries to accept responsibilty for the resulting
damages, and it initially appeared that it would as the manufacturer requested information
on all of the claims. However, Howard Industries continued to delay settlement and Idaho
Power ultimately decided in January 2008 to issue payments on the claims. These
payments were not made to compensate for any liabilty on the Company's part but as a
good wil gesture to its customers.
Howard Industries has admitted fault but stil has not paid Idaho Power. A copy of
the manufacturer's Root Cause Analysis Report admitting fault is enclosed as Attachment
NO.2 to this Answer. Idaho Power received a letter from Howard Industries dated August
11,2009, stating that it wil reimburse Idaho Power for the amounts it paid on the related
claims. Idaho Power is optimistic that the manufacturer wil reimburse the Company soon.
With regard to Mr. Jameson's specific claim, it should be noted that although he
reported the power outage and indicated that he heard a loud pop in his television on
ANSWER-7
August 7, 2007, Mr. Jameson did not notify the Company that his television had been
damaged or indicate that he wished to make a damage claim unti August 13, 2007. Idaho
Power immediately set up a claim and mailed a claim packet to him. Idaho Power
attempted to call Mr. Jameson on August 14, 2007, to discuss his damage claim and left a
message on his message machine. The Company also mailed a damage claim status
letter to all affected customers, including Mr. Jameson, on September 7,2007.
On September 10,2007, Idaho Power's Damage Claims department received a call
from Mr. Jameson. Mr. Jameson advised the Company that he is an electrical engineer
and believes Idaho Power installed the transformer incorrectly, that this caused the failure,
and as a result Idaho Power should pay his damages. He also advised the Company that
he threw away the claim form as he was too angry to look at it.
On October 27, 2007, Idaho Power sent Mr. Jameson another damage claim status
letter along with another claim form. Idaho Power received Mr. Jameson's completed claim
form on November 1, 2007, requesting Idaho Power pay damages in the amount of
$1,600. Mr. Jameson reiterated that he knows the transformer was not defective and that
it was installed incorrectly.
After receiving a copy of the manufacturer's Root Cause Analysis Report
(Attachment No.2) that indicated a manufacturing defect, Idaho Power mailed a claim
denial letter to Mr. Jameson on November 23, 2007. During a December 3, 2007,
telephone call, Idaho Power supplied Mr. Jameson with the manufacturer's contact
information; Mr. Jameson advised that he would contact them about presenting a damage
claim.
ANSWER-8
When Idaho Power advised Mr. Jameson on January 17, 2008, that Idaho Power
would reimburse the affected customers as a good wil gesture for damages caused by the
defective transformer, Mr. Jameson indicated that he did not retain the damaged television
and did not have any pricing information on it. The model number Mr. Jameson provided
Idaho Power was invalid according to the television's manufacturer. Idaho Power's
Damage Claims department then searched for a comparable product to determine the
value of his equipment. Idaho Power contacted Mr. Jameson on January 29, 2008, to
advise him of its findings and that a check would be forthcoming in the amount of $1,600-
the entire amount claimed by Mr. Jameson. Idaho Power mailed Mr. Jameson a check in
satisfaction of the damage claim on February 7, 2008.
IV. COMPANY POSITION
The Company contends that it substantially complied with the Commission's Utiity
Customer Relations Rules as they pertain to the March 10, 2009, disconnection of Mr.
Jameson's electric service. Idaho Power has since instituted measures to reinforce the
practices required by the Utility Customer Relations Rules, emphasizing which practices
are required by the Commission in addition to the Company's standard practices.
The Company also contends that it provided an appropriate response to Mr.
Jameson's 2007 damage claim. Although Mr. Jameson continues to blame the Company
for causing damage to his television, Idaho Power went beyond what was legally required
of the Company when it paid claims for which it was not ultimately responsible in an effort
to give customers a timely resolution.
ANSWER-9
V. COMMUNICATIONS AND SERVICE OF PLEADINGS
Service of pleadings and communications with reference to this case should be sent
to the following:
Lisa Nordstrom
Barton L. Kline
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702
Inordstrom(aidahopower.com
blkine(aidahopower.com
Ric Gale
Scott Sparks
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702
rgale(aidahopower.com
ssparks(aidahopower.com
Vi. REQUESTED RELIEF
For the reasons stated above, Idaho Power requests that the Commission deny Mr.
Jameson's Complaint.
Dated this 1st day of September 2009.
cZ~ L~Jd
LISA D. NÓRDST OM
Attorney for Idaho Power Company
ANSWER-10
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 1 st day of September 2009 I served a true and
correct copy of the within and foregoing ANSWER upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Don Howell
Lead Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83702
-- Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email Don.HoweIlßùpuc.idaho.gov
Everett A. Jameson
3206 McLeod Lane
New Meadows, Idaho 83654
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
Email
(;~¡¿~~
Lisa D. Nordstrom
ANSWER -11
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. IPC-E-09-23
IDAHO POWER COMPANY
ATTACHMENT NO.1
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. IPC-E-09-23
IDAHO POWER COMPANY
ATTACHMENT NO.2
HOWARD INDUSTRIES, POLETYPE DIV.
CUSTOMER COMPLAINT ACTION MEMO
ROOT CAUSE ANAL YSIS REPORT
Page 1 of2
..~~. ... -_..... .
i
;!
CUSTOMER:
SERIAL NUMBER:
KVA: 500
CCAM: 25968
HI PROBLEM CODE:
PROBLEM PART "PROBLEM SUBJECT
COIL FAILURE ASSEMBLED WRONG
INITIAL PROBLEM AS REPORTED BY CUSTOMER/AGENT:
An email from Jeff Foxworh in HI Marketing stted, "Tis is th one Gary Bett called about a few days ago. They
had a storm come through and took one unit out. They replaced it wi this unit and it blew the top after it was
energized." Photos supplied by custmer showed the jumper connecton at the left white block on LV side to be
loose. A later email from Rene Jones of Idaho Power to Tile Beasley at RogersStrong stated, "Our damage
claims departent was needing to know what the cause of the failure was. this is the unit that caused customer
equipment to be desoyed. Idaho Power has outnding claims from our customers for persnal propert damage.
Is this information available?" Date of insallaton and failure were not report. Trasformer onf#nally shipped
from HI to Idaho Power on 12/19/06. -
FINDINGS-DESCRIPTION OF UNIT AS RECEIVED:
Customer had previously opened trnsformer. PRV pull ring and bug- disc were missing. Cusomer had
removed the arrters. Both cover mounted buhings wer stll mounte seurely to the coer. There was no oil
spray around the PRV. XO bushing was stll connected to tank wall with copper ground straps. PRV Was holding
vacuum. Customer had drained oil to halfy of coil. Remaining oil was black with a burned odor. We found no
rust or water in the tank. The nut at the left white block electril connecon on L:V side was loos. The
transformer was incorrecty connected internally. The point that should have be conneed to the X1 bushing was .
instead connected to the XO bushng and vice vers. Coil teardown analysis revealed turn to tum and layer to layer
failure in the HV winding. The coil failed under iron left and ñght side at the top and bottom edges of the layers on
the HV and LV quadrants. The HV conductor was pushed appoximately 5" off the paper folds. '1
ROOT CAUSE OF PROBLEM (REPORT WRTER'S ANALYSIS)
The transformer was incorrectly connected internally. If the transformer wa inslled in a step-own application,
19920V would have been placed acr a 12720V porton of the winding, and the resultng secondary voltage would
have been above 7200V. If the transformer was instlled in a slp applicaon, the reulting voltge would have
been less than 19920V. The incorre intemal connecons explain the volte isses but do not necearily
explain the cause of the coil failure. The roo cause of the coil failure was undeteimlnable.
IDAHO POWER CO.
549081-4406 CUSTOMER 10 NO.: 1345
HI CATALOG NUMBER: 1494-418569-800
VOLTAGE: 34500Grd/19920 - 12470GrdVn200
FURTHER INITIAL DETAILS
Failed when energd-connecte wrong internally
¡
i
¡
l
l
l
,i
Tes record indicate this transformer paed'all electrcal tes duñng oñginal manufacture including ratio and
polarity. The transformer would have pas these te if the tes leads on the XU and X1 bushngs were reversed.
CORRECTIVE ACTION:
QA Manager asked nies Beasey of Rogerstrong to contact Idaho Power to locate sister trnsformer SIN
54082-4406. Ms. Beasley emailed a reues to Idaho Power on 10/1617 to detrmne whether this sistr
trnsformer had been instlled alrea. There has been no rey as of 11/5/07. This sister transfrmer needs to be
insected and rato tesed before installation if it has no alrea been insled. If this sister trnsformer is already
in service, then we have no reason to believe that it is conected incorec intrnlly.
We reviewed test connecton diagrams in the te manuals and found thm to be correct. Poletpe Engineenng will
NUM 01FOO.6100ISSUE DATE: 10.1- REION: 07. RE. DATE: 1(117-0. AUT BY: Oa Br. PAGE: I OF 1 QA do Il fr 2 pe mi wi 1M lI ne.
DOCUIl CKAIGl KIS Riv 01 GMui ci... "R Pnli.. '" .. "' c:,, ll ti 1O Ail kVA..d Vlil '" rtpo RlVn lMllVt d..Qllftl...,., ¡.,r..ltplo..ll.'..'p....lIllidHro..io............ ø.M ll27 ......--ilr_ai..lilto..tI.rei.....U. ..d_vi.iI
ßt.r........i. Rov05 OH.RoR.,..ii...orGA....'_...,_ .....2HAiIT_-.toit.._rft.k1 Rov.071G1111Ch..øo "QoA ....t. A.ily.' Ie "RllWoi' AoOl'
CUSTOMER COMPLAINT ACTION MEMO
ROOT CAUSE ANAL YSIS REPORT
Page 2 of2
---_... ...... ..-,.
549081.4406 CUSTOMER ID NO.: 1345SERIAL NUMBER:
CCAM: 25968
review this complaint with electrical testers and review proper tesing connections per the test manuals.
General Foremen over the Poletpe producton lines have be notfied of this complaint and will review it during a
dally pre-shift meeting with electcal tesers and stes importnce of stctly following test manual connection
diagrams.
THE ERROR WAS DETERMINED TO BE THE RESPONSIBIUTY OF: MFG & QC
DATE REPAIRS COMPLETED:
REPAIRS PERFORMED:
Transformer coil has been replaced under warranty. QA Manager has verified proper internal electrical
connections. Transormer will be sent to producon line and sujec to all routine production line electrical tets.
REPORT DATE: Wednesay, Noverer07, 2007
REPORT WRTER: Sign~
¡;
Darrn Brown
Poletype Div., QA Manager
OR
Tom Anderson
Poletype Div., QA Specialist
APPROVAL:Signature
INVESTIGATING PERSONNEL
Ri Hollingsrt De Enrig Maag. Polety Divion
Darn Bro, Qulity Asce Ma, Polet Divion
Deis Tayl, Field Faiure Rep Tcçhnicia Polet Division
Joh Mor Coil Teawn Anys Pole Division
Hongbo Fan, Desgn Engieer, Polc Divisin
'11t
NUMBER: O1FOO.6100 ISUE DATE 10.1. REION: 07. RE. DATE 10-17-l, AUT. BY: Da Il PAGE: 1 OF 1 QA doll fi 2 ye mù, wi re. as ne.
DOl! ClGEHlsrRY, R..n _ ei.."R....Io"H..., c.do"; R... G2 lQ.AdKVA ..Yo.. '" "1Mit R."OI lI...... 'ocm'iic.nt iif.'..lolo..-of.....lIlhe....f_...llc1n........ _II 1_ ....io__...I_lOoilsio.oi .....__fll."...,..I. Roes, Of.2Si.Rop"'Rnllt'II_GA....iimiwr_-. Ro."~~T__.."llpo_rrll R...llfll1l:
ciOlSO' "G-A. Man..,", A.ii"lo "IWir' Aii