20050121Decision Memo.pdf

DECISION MEMORANDUM
TO:CO MMISSI 0 NER KJELLAND ER
COMMISSIONER SMITH
CO MMISSI 0 NER HANSEN
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:DONOVAN E. WALKER
DATE:JANUARY 21, 2005
SUBJECT:P ACIFICORP'S APPLICATION FOR APPROVAL OF REVISIONS TO
THE COMPANY'CUSTOMER GUARANTEE RULE 25 AND
SCHEDULE 300 CASE NO. P AC-04- 7
On December 2 , 2004, PacifiCorp submitted by electronic filing various changes in
customer guarantees and performance standards using a tariff advice proceeding. Because of the
significant changes proposed by the Company, the Commission Staff recommended processing
the proposed changes using Modified Procedure with a comment period. In Order No. 29679 the
Commission ordered the use of Modified Procedure with a comment period ending January 19
2005. The only comments received were those of the Commission Staff.
BACKGROUND
At the time of the merger between PacifiCorp and ScottishPower, the Company agreed to
implement seven Performance Standards and eight Customer Guarantees. See Case No. PAC-
99-1. The Company committed to a five-year term for the program which expires on March 31
2005. According to the Company s current Application, the Customer Guarantee Program has
been very successful with a success rate in meeting the guarantee commitments in Idaho of
99.9%. The Company now proposes to continue both the Customer Guarantee Program and the
Performance Standards Program citing: positive customer, employee, and regulatory feedback
regarding the service standards; the process improvements that have resulted from the service
standards; and the desire to maintain the Company s focus on providing excellent customer
servIce.
THE APPLI CA TI 0 N
The Company requests an effective date for the proposed revisions of April 1 , 2005, as
the current standards expire on March 31 , 2005. Additionally, the Company requests approval of
DECISION MEMORANDUM
the proposed revisions by January 31 , 2005 in order to train employees and make the necessary
system changes to implement the revisions.
Customer Guarantee Program
The Company is proposing several improvements to the current customer guarantees and
the elimination of one guarantee. The Company proposes a three-year duration for the modified
program, with an expiration date of March 31 , 2008, and including an efficacy review of the
program by the Company and Commission Staff at that time to determine what modifications
should be made in the future.
Under the modified program the Company will guarantee the following services:
restoring supply after an outage; 2) meeting appointments; 3) connecting new service; 4)
providing an estimate; 5) responding to billing inquiries; 6) resolving meter problems; and 7)
providing notice on planned interruptions. The Company seeks to eliminate the existing
Customer Guarantee No., Responding to Power Quality Complaints.
Network Performance Standards
The Company proposes to retain four Network Performance Standards and eliminate one.
According to the Application the Company proposes: 1) to improve SAIDI (system average
sustained interruption duration index) results by 6% within the three years to achieve a target
SAID I of no more than 206.minutes; 2) to improve SAIFI (system average sustained
interruption frequency index) results by 6% within the three years to achieve a target of SAIFI of
no more than 2.34 events; 3) to select five under-performing circuits in Idaho on an annual basis
and undertake corrective measures to reduce the CPI (circuit performance indicator) by 20%
within two years; and 4) to restore power outages due to a loss of supply or damage to the
Company s distribution system on average to 80% of customers within three hours.The
Company seeks to eliminate the network performance standard relating to MAIFI (momentary
average interruption frequency index).
Customer Service Performance Standards
The Company is proposing changes in the telephone performance standard and the
complaint performance standard. The Application proposes to adjust the service level for
telephone response from 80% of calls answered in 20 seconds, to 80% of calls answered in 30
seconds, and to focus on the quality of service that customers receive by monitoring customer
satisfaction with the Company s Customer Service Associates and the quality of response the
DECISION MEMORANDUM
customers receive. The Company is also proposing changes to the complaint performance
standard to indicate that the Company will respond to at least 95% of Commission complaints
within 30 days.
STAFF COMMENTS
Staff commends the Company on its willingness to continue monitoring its performance
in several key areas. By establishing standards and guarantees, the Company has reinforced its
commitment to maintaining and, where possible, improving customer relations and network
service quality. Staff prepared "Attachment A" to its comments which summarizes the relevant
merger commitments made by the Company, its performance with respect to those commitments
and how the proposed commitments compare to the existing commitments.
Staff recommends that the Commission accept the Company s proposal, with four
relatively minor changes/additions. First of all, in the Staffs Comments, Staff recommends that
the Commission not approve the proposed revision regarding the definition of a "major event"
(Staff Comments p. 5 Recommendation 4).However, subsequent to the filing of Staff
Comments the Company provided additional information that the proposed definition is actually
an accepted and officially adopted definition by the Institute of Electrical and Electronics
Engineers, Inc. (IEEE). Therefore, Staffs recommendation is that Section 3, on Sheet 25R.4
refer to the "IEEE Guide for Electric Power Distribution Reliability Indices, Standard 1366tm-
2003." (Please see, Attachment 1 to this Memorandum).
With regard to the Company s proposed changes to Customer Guarantees, Staff
recommends approval of the changes provided that: 1) rather than stating that the Guarantees
are applicable to all active metered residential, Schedule 23 and Schedule 23A Customers" that
sheet 25R.1 be modified to list each schedule ~ Schedule 1 , 6A, 10, 23 , 23A, and 36, in order to
clarify the customer classes that the Guarantees apply to; and 2) rather than stating "two days
(Customer Guarantee 7 - Notifying of Planned Interruptions) as proposed by the Company, that
Sheet 25R.3 be modified to specify "two calendar days" in order to clarify the time period and to
be consistent with other Guarantee provisions which reference "two working days" and "two
calendar days.
With regard to the Company s proposed changes to Network Performance Standards
Staff recommends approval of the changes, including the elimination of the standard relating
Momentary Average Interruption Frequency Index (MAIFI) provided that the Company
DECISION MEMORANDUM
develops its alternative plan for full-system momentary detection and provides a specific
proposal to Staff as soon as possible. The Company has been measuring this index by breaker
counts and has found that this does not result in an adequate measurement of MAIF!. The
Company also believes that adding momentary detection to each circuit is cost-prohibitive and
data-intensive to investigate using current technology. The Company proposes to manage
momentary events within the delivery system and will rely on customer feedback to identify high
momentary outage activity. The Colnpany has assured the Staff that it remains committed to
improving the network performance and customer concerns related to momentary events, and
will delineate cost-effective methods for full-system momentary detection deployment.
STAFF RECOMMENDATION
Staff recommends that the Commission accept the Company s proposal provided that the
following changes are made: (Attachment 1 shows the Staffs recommended changes/additions)
1. That all Customer Guarantees apply to customers served under Schedules 1
, 10, 23, 23A, and 36 and that Sheet 25R.1 be modified to list those
schedules.
2. That the Customer Guarantee regarding notification of planned interruptions
(Sheet No. 25R.3) be modified to specify "two calendar days.
3. That the Company provides a specific proposal to continue monitoring
momentary events as soon as possible.
4. That Sheet 25RA, Section 3 regarding the definition of "major event" refer to
the "IEEE Guide for Electric Power Distribution Reliability Indices, Standard
1366tm-2003.
COMMISSION DECISION
Does the Commission wish to approve the Company s proposed revisions to its Customer
Guarantees and Performance Standards to take effect on April 1 , 2005, and expire on March 31
2008?
If so, does the Commission wish to adopt Staffs proposed changes to the Company
proposed revisions?
M:P ACEO407 dw2
DECISION MEMORANDUM
BlahII."
C. No. 28
First Revision of Sheet No. 25R.
Cancelin2 Original Sheet No. 25R.
ELECTRIC SERVICE REGULATION NO. 25
STATE OF IDAHO
GENERAL RULES AND REGULATIONS
CUSTOMER GUARANTEES
This Rule provides general terms and conditions for the Company s Customer Guarantees which are
I applicable to all active metered~ol. SclIegule 23 and Sd..:qg/t; 2JA Customers or Applicants utilizing
the services of the Company. 2..)2..~Pr CotJ.~lO1. CUSTOMER GUARANTEE CREDIT:
For failure to meet a Customer Guarantee for Customer Guarantees 1 and 7, Customers must make a
claim for compensation. Valid compensation claims for Customer Guarantees 1 and 7 submitted
within 30 days of the date of an outage will be credited to the Customer s account. If the Company
fails to meet a Customer Guarantee for Customer Guarantees 2 through 6 and Customer Guarantee 8
the credit will automatically be applied to the Customer s account. Where a Customer Guarantee
applies to an Applicant, the Company will mail the guarantee payment to the Applicant. See
Schedule 300 for a description of the Customer Guarantee credits.
DESCRIPTION OF CUSTOMER GUARANTEES:
. (a) Customer Guarantee 1: Restoring Supply After An Outage
In the event of an outage, the Company will restore a Customer s electric supply within 24
hours of being notified except where:
(1)
(2)
(3)
(4)
The Customer agreed to remain without supply;
The Company offered the Customer a generator as an alternative means of supply;
There were problems or safety-related issues with the Customer internal
equipment; or
Specialized equipment was required to restore the supply. *
* Also see General Exceptions.
Continued)
I Submitted Under Advice No. 04-1000 04
ISSUED: December 2. 2004May 11.2000 EFFECTIVE: April.1, 2005J lily 1 , 2000
Blah
I lJUM
. I.C. No. 28
First Revision of Sheet No. 25R.
Cancelin Original Sheet No. 25R.
DESCRIPTION OF CUSTOMER GUARANTEES: (continued)
(d) Customer Guarantee 4: Estimates For Ne~" Supply (continued)
(3)The Company was unable to contact the Customer or Applicant at the address or
telephone number provided by the Customer or Applicant; or
Thc Company rescheduled the appointment with at least 21 hours of notice. *(4)
* Also see General Exceptions.
(e) Customer Guarantee 5: Responding To Bill Inquiries
The Company will respond to most billing inquiries at the time of the initial contact from the
Customer. For those inquiries that require further investigation, the Company will
investigate and respond to the Customer as soon as possible or at least within 10 workingdays.
(f) Customer Guarantee 6: Resolving Meter Problems
The Company will investigate and respond to reported problems with a Customer s meter
or conduct a meter test and report the results to the Customer, within l~ working days. If
more than one requested test is made in twelve months, the Customer will pay in advance a
charge as specified in Schedule 300.
(g) Customer Guarantee 7: Notifying Of Planned Interruptions cAte.-~
The Company will provide the Customer with at least two v.'orking d ays notice prior to
turning off power for planned interruptions except where:
~~~~
The Customer agreed to less than twoA ' . b ays notice;
The interruption was due to work on meters or a meter test;
The interruption was a momentary interruption of less than 5 minutes;
Pennanent repairs were carried out within three working days ,of completing
temporary repairs following an unplanned interruption;
The Customer was notified of a planned interruption which did not occur; or
The safety of the public Company personnel or imminent failUre of Company
equipment is a factor leading to an immediate interruption to carry out repair work.
(1)
(2)
(3)
(4)
(5)
(6)
* Also see General Exceptions
(Continued)
I Submitted Under Advice No. 04-1000 0'1
ISSUED: December 2, 2004May 11, 2000 EFFECTIVE: April L 2005July 1,2000
Blah
I IJP
C. No. 28
First Revision of Sheet No. 25RA
Cancelin Original Sheet No. 25R.
DESCRIPTION OF CUSTOIVIER CU..AAR.i~NTEES: (continued)
To receive a credit, a Customer must make a claim for compensation within 30
calendar days of the date of the planned interruption.
(h) Customer Guara ee 8: Responding To Power Quality CORlplaiBts
The Company will begin an investigation of a pmver quality complaint and respond to the
Customer \vithin seven 'vorking days or explain a known. problem to the C~l:;tomer within
five 'Norking days.
4\)
-i
........
GENERAL EXCEPTIONS:
Payment for the failure to meet a Customer Guarantee shall not be made if any of the following
general exceptions occur:
(1) ~e ~ustomer or Applicant canceled ,the requ~st ~.ndJor did not keep the ap~intment. This
will mclude the Customer or Apphcant notifymg the Company they did not want the V)
Company to start action, or take any further action.
The Customer or Applicant agreed that the action taken by the Company met the ~
requirements of the guarantee.
, . . ~
The Customer or Applicant did not provide necessary infonnation or supplied incorrect
information. . WInability to access Company, Customer or Applicant's facilities beyond the control of theCompany. -e:-
An action . or default by someone other than a Company employee that is outside of the
Company s control, for example, road closures.
Major events, such as storms, as currently defined~ the Institute of Electrical and
..:..:;
Electronics Engineers, Inc. (lEE~)t Ga4uLA. .St
~~,~
c..dU ~tr;
~~ ~
Instances where resources reqUIted to meet the guarantees were re-deployed to restore
supplies during a major event in another operating area or utility.
Safety-related issues which preclude the Company from meeting the guarantees.
Causes related to force majeure, which include but are not limited to: injunction or other
decree or order of any court or governmental agency having jurisdiction, strikes or other
labor disputes such as lockouts, slowdowns or work stoppages, sabotage, riot insurrection,
acts of the public enemy, fire, flood, explosion, extraordinary action of the elements
earthquake or other acts of God, or accidental destruction of or damage to facilities.
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(Continued)
I Submitted Under Advice No. 04-1000 0,1
ISSUED: December 2. 20041-1ay 11 2000 EFFECTIVE: April.l, 2005July 1,2000