20070928Klein direct.pdf

BEFORE THE RECEI D
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IDAHO PUBLIC UTILITIES COMl\tlm!~~J~-.lm~19
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IN THE MATTER OF THE APPLICATION OF
PACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL OF CHANGES
TO ITS ELECTRIC SERVICE SCHEDULES
CASE NO. PAC-07-
DIRECT TESTIMONY OF DANIEL KLEIN
IDAHO PUBLIC UTILITIES COMMISSION
SEPTEMBER 28, 2007
please state your name and business address for the
record.
My name is Daniel Klein.My business address is
472 West Washington Street, Boise, Idaho.
By whom are you employed and in what capacity?
I am employed by the Idaho Public Utilities
Commission (IPUC) as a Utilities Compliance Investigator
What is your educational and professional
background?
Prior to my employment with the Idaho Public
Utilities Commisslon,had two years and nine months
experience working private industry for Qwe s t Corporation
Sales Consul tant in Bolse,Idaho.received Bachelor
of Arts Degree of Communication from Boise State University
in Boise, Idaho, in May of 1998.
Have you previously testified before the
Commission?
No.
What is the purpose of your testimony in this
proceeding?
I will address the following consumer issues:(1 )
proposed changes in connection and reconnection fees;(2 )
proposed change in time period during which arrangements for
reconnection of service can be made;(3) collection agency
fees;(4) customer notification;(5) customer relations; and
CASE NO. PAC-07-
09/28/07
KLEIN, D.
STAFF
(Di)
(6) call center performance.
Please summarize Staff's recommendations to the
Commission as discussed in your testimony.
Staff recommends that the Commission:
(1 )Retain the existing reconnection and after
hours service connection charges and rej ect
the Company s proposal because of the
significant impact on individual customers,
the overstated costs, and the use of
unnecessarily expensive resources in the
Company s cost analysis.
(2 )Not change the Company s after normal office
hours for reconnect ion of service because the
proposed change would have a minimal impact on
Company cost but a significant negative impact
on the affected customers.
(3 )Not pass along collection agency fees or
collection costs to individual customers
because the Company has not provided adequate
justification for shifting those relatively
minor costs from the general body of
ratepayers to individual customers.
PROPOSED CHANGES TO RECONNECTION DURING OFFICE HOURS
The Company proposes to increase its reconnection
charge from $25 to $30 during normal business hours.Does
CASE NO. PAC-07-09/28/07
KLEIN, D.
STAFF
(Di)
Staff support this change?
No.The Company is proposing to recover through
its reconnection charge the cost of both disconnection and
reconnect ion of service.The Company maintains the cost
associated with both disconnecting and reconnecting service
during normal office hours is approximately $43.The cost of
reconnect ion alone is half that amount.Normal office hours
are 8: 00 a. m. to 4: 00 p. m., Monday through Friday.
The Commission has previously supported the
posi tion that reconnection fees should only represent those
costs associated with reconnection of service.In Order Nos.
20600 (Barber Water) and 21939 (Washington Water Power), the
Commission disallowed the proposed fees for disconnection of
service.The Commission stated,
The Commission rej ects imposing a chargefor actual "disconnection of service " for
two reasons: (1) It would add to the financial
burden of customers who are already having
difficulty paying their bills and (2) it is
unreasonable to charge people extra for beingdeprived of service.
Case No. U-1008-289, O.N. 21939, p.
PacifiCorp currently charges $25 for reconnection during
business hours.Because PacifiCorp s reconnect ion charge is
already higher than its actual cost (approximately $22),
there is no justification for increasing its reconnect ion
charge.
How does PacifiCorp s current reconnect ion charge
CASE NO. PAC-07-
09/28/07
KLEIN , D.
STAFF
(Di)
compare to other energy utilities in Idaho?
PacifiCorp currently has one of the highest
reconnect ion charges of the regulated energy utilities in
Idaho.See Exhibit No. 114.
PROPOSED CHANGES TO AFTER HOURS RECONNECTION
The Company proposes to increase its after hours
service reconnection charge from $50 to $100.Does Staff
support this change?
No.The Company is proposing to recover through
its after hours service reconnection charge the cost of both
disconnection and reconnection of service.After hours
charges apply for work performed outside of normal business
hours.The Company maintains the cost associated with both
disconnecting and reconnecting service after normal office
hours is approximately $150.According to the Company, the
cost of reconnect ion alone is approximately $127.The after
hours service reconnect ion charge applies when a customer has
been turned off involuntarily by the Company, subsequently
satisfies all criteria for reconnection, and contacts the
Company between 4:00 p.m. and 7:00 p.m. weekdays or 8:00 a.
to 4: 00 p. m. on weekends or holidays to request reconnection.
Which employees perform reconnection on behalf of
the Company?
Both Collectors and Journeyman Linemen perform
service reconnect ions.Only Journeyman Linemen can perform
CASE NO. PAC-E- 07 - 5
09/28/07
KLEIN, D.
STAFF
(Di)
reconnections when pole work or work on three-phase serVlce
is required.The Company was unable to provide Staff with
information on how many after hours reconnections actually
invol ve pole work or three-phase service and therefore
require a Lineman s expertise.Although 34% of all after
hours reconnect ions are performed by Journeyman Linemen , only
12% of all reconnects during normal business hours are done
by Linemen.This suggests that Linemen are reconnecting
service after hours for reasons other than the need for their
technical expertise.To the extent this is true, after hours
reconnection costs are driven up unnecessarily, because a
Journeyman Lineman s activity rate is almost double that of a
Collector.
Another factor that drives up costs is that
Collectors and Linemen are paid for at least two hours for
any work done after normal business hours per labor contract.
However , the Company has indicated that the average time
taken for a reconnection visit is 25 minutes.It appears
that the Company s after hours reconnection costs are heavily
influenced by factors other than the actual cost of providing
the service to customers.
Have other States approved an after hours
reconnect ion fee that is higher than that being proposed in
this case?
Yes.In Oregon, a $175 fee applies for after hours
CASE NO. PAC-E- 07-09/28/07 KLEIN , D.
STAFF
(Di)
reconnections.Staff does not know what the Company s costs
are in Oregon or what factors the Oregon Commission used in
deciding to approve this charge.However , the Oregon charge
only applies to weekend and holidays from 8: 00 a. m. to
6:00 It does not apply to after hours reconnect ions on
weekdays.Therefore , the Oregon charge is not directly
comparable to Idaho.
How does PacifiCorp s current after hours service
reconnect ion charge compare to other energy utilities in
Idaho?
PacifiCorp currently has the highest after hours
service reconnection charge of the regulated energy utilities
in Idaho.See Exhibit No. 114.
PROPOSED CHANGES TO CONNECTION OF SERVICE AFTER HOURS
The Company proposes to increase its after hours
service connection charge from $50 to $100.Does Staff
support thi s change?
No.The after hours service connection charge
applies when a customer contacts the Company between 4: 00
p. m. and 7: 00 p. m. or on weekends or holidays to request new
service or contacts the Company during normal office hours to
request connection after hours.The Company maintains that
it is proposing this change to better reflect the cost of
providing this service.The Company maintains the cost
associated with connecting service after normal office hours
CASE NO. PAC-07-
09/28/07
KLEIN, D.
STAFF
(Di)
is approximately $127.
How does PacifiCorp s current after hours service
connection charge compare to other energy utilities in Idaho?
PacifiCorp currently has the highest after hours
service connection charge of the regulated energy utilities
in Idaho.See Exhibit No. 114.
Is the same cost justification used by the Company
to support its request for a higher connection charge as was
used for its request for a higher reconnection charge?
Yes.The same arguments used by Staff in urging
the Commission not to approve the Company s request to double
its after hours reconnection fee apply to the request to also
double its connection fee.
Have other States approved an after hours
reconnection fee that is higher than that being proposed in
this case?
Yes.The Company indicated that it was allowed to
charge customers a higher after hours connection fee in
California and Oregon than the one proposed currently in
Idaho ( $ 1 0 0) Staff does not know what the Company s costs
are in Oregon and California or what factors the Oregon and
California Commissions used in deciding to approve this
charge.However, the Oregon charge ($175) only applies to
weekends and holidays from 8: 00 a. m. to 6: 00 p. m.The
California charge ($175) applies after 8:00 p.m. and anytime
CASE NO. PAC-E- 07-
09/28/07
KLEIN , D.
STAFF
(Di)
on the weekends or hol idays .In Idaho, the after hours
charge applies during weekdays from 4: 00 p. m. until 7: 00 p. m.
as well as 8: 00 a. m. to 4: 00 p. m. on weekends and holidays.
Therefore, the Oregon and California charges aren t directly
comparable to Idaho.
Does the Company charge customers for service
connection during regular office hours.
No.The Company currently does not assess a
connection charge in Idaho during normal business hours.The
Company is not proposing to institute a connection charge
during normal business hours in this case.The Company
considers connection during business hours to be a cost of
doing business to be recovered through rates instead of a fee
directly charged to individual customers.
IMPACT OF PROPOSED FEES
What is the overall revenue impact of the Company
proposed changes to its reconnection , after hours service
reconnection , and after hours connection charges?
The proposed changes to connection and reconnection
fees would result in a total increase in revenue of $14 750
based on the Company s 2006 numbers.If approved, the effect
on rates and revenue would be negligible, but the same cannot
be said for customers who would have to pay these charges.
What is the potential impact on customers?
The proposed changes to connection and reconnect ion
CASE NO. PAC-07-09/28/07
KLEIN, D.
STAFF
(Di)
fees would have a significant impact on customers.The
increases would affect customers who probably already have
problems paying their bills , and the new fees would place an
even greater financial burden on them.
What is Staff's overall recommendation for the
proposed changes to the Company s connection and reconnection
charges?
Staff recommends that the Commission rej ect the
proposed changes to the Company s connection and reconnection
charge s .The Company has not provided sufficient
justification for increasing its fees, especially to the
degree it is proposing.PacifiCorp s current fees are
already the highest approved fees for energy utilities in
Idaho.See Exhibit No. 114.The proposed increase of the
after hours service connection and reconnection fees would
make the Company s fees twice the amount of any other
company s fees during a similar time frame.
PROPOSED CHANGE IN HOURS OF RECONNECTION
Is PacifiCorp proposing any other changes to
reconnect ion of service?
Yes, the Company is proposing to change the hours
during which after hours reconnection of service will be
offered.
What is the procedure for assessing charges for
reconnection of service?
CASE NO. PAC-07-
09/28/07
KLEIN, D.
STAFF
(Di)
For the purpose of reconnecting service and
assessing fees for reconnection, the Company uses the time
the customer satisfies all requirements for reconnection of
service to determine whether the normal business hours or
after hours charge will apply.The actual time that service
is reconnected is immaterial.The Company currently offers
after hours reconnection from 4: 00 p. m. and 7: 00 p. m., Monday
through Friday, excluding holidays.The Company is proposing
to change the cutoff time for reconnect ions during weekdays
to 6:00 p.Last year 115 customers contacted the Company
and requested reconnection between 4:00 p.m. and 7:00 p.
Very few (twelve) of those customers contacted the Company
between 6:00 p.m. and 7:00 p.If the Company were allowed
to shorten the hours that it offers after hours service
reconnect ion as requested , these twelve customers would not
have been reconnected until the following day, even if all
condi tions for reconnection had been satisfied.Leaving the
cut off at 7: 00 p. m. allows customers a greater opportunity
to restore service that same day.Not every customer that is
disconnected involuntarily will have the opportunity to
discover that their service has been disconnected by the
6: 00 p. m. cutoff, let alone make payment or arrangements to
restore service.Staff recommends that the Company retain
its after office hours of 4: 00 p. m. to 7: 00 p. m., providing
affected customers with a three-hour window of opportunity to
CASE NO. PAC-E- 07-
09/28/07
KLEIN, D.
STAFF
(Di)
get reconnected that same day.
COLLECTION AGENCY FEES
The Company proposes changes to Regulation No. 10.
Does Staff support this change?
No.The Company proposes to add language to
Regulation No. lOR. 8 to indicate that customers are
responsible for reasonable court costs, at torney s fees
and/or collection agency fees incurred in the collection of
unpaid debt.
In general, what are the terms offered by
collection agencies in collecting debts owed to a business?
Businesses often send accounts to a quick collect
type of agency that charges a flat fee to try and collect the
debt wi thin 30 days.The account is returned to the business
at no charge if it is not successful.Businesses will then
send the account to a full service collection agency, which
will pursue the debt to its fullest extent, including
charging interest and taking debtors to court.This type of
collection agency generally does not charge the business any
fees; it takes a percentage of the money collected from the
debtor.If a debtor was taken to court, a collection agency
may keep as much as 50% of the collected debt.under thi s
type of arrangement, the business does not receive the entire
amount owed by the debtor.It is unclear whether the Company
wishes to recover from its former customers collection
CASE NO. PAC-E- 07 - 509/28/07
KLEIN , D.
STAFF
(Di)
expenses over and above what collection agencies charge the
debtor.
PacifiCorp stated that it spent $24,000 in
collection agency fees to collect $88,000 in debt or $.27 on
every dollar collected.This does not appear to be an
excessive expense.If the Commission allowed recovery of
these fees, it would not materially affect revenue or rates.
The Commission currently allows the recovery of uncollectible
costs to be recovered through rates.No other regulated
energy utility in Idaho is allowed to pass collection agency
costs to individual customers who have outstanding bills.
Utilities are allowed to assess interest on past due amounts
when customers do not pay their bills in a timely manner.
the extent that a Company decides to employ collection
agencies instead of pursuing collection through its own
efforts, the Company should bear those costs associated with
that business decision.Staff does not agree that PacifiCorp
should pass along collection agency fees to individual
customers.
CUSTOMER NOTICE AND PRESS RELEASE
Did Staff review the Customer Notice and Press
Release?
Yes.The Customer Notice and Press Release were
included in PacifiCorp s Application.The Application was
received on June 8, 2007.Staff reviewed the Customer Notice
CASE NO. PAC-07-
09/28/07
KLEIN, D.
STAFF
(Di)
and Press Release and determined they were in compliance with
the requirements of IDAPA 31.21.02.102.
CUSTOMER RELATIONS
Please describe how many and what type of
complaints and inquiries the Commission has received
regarding PacifiCorp.
Exhibit No. 115 shows the number of informal
complaints and inquiries received over the past four years.
What did your analysis of complaints and inquiries
received by the Commission from 2005 to 2007 YTD reveal?
Of the complaints and inquiries received by the
Commission for 2004 and 2005, about one-third involved credit
and collection issues.Most of those were from customers who
had been disconnected due to non-payment of their accounts or
had been notified that they were in jeopardy of losing their
service due to non-payment.Concerns about line extensions
and billing together comprised over 40% of total contacts
with customers during 2004 and 2005.
In 2006, the Commission received fewer complaints
and inquiries from PacifiCorp customers when compared with
the prior year.Complaints and inquiries regarding credit
and collection issues decreased, but concerns about line
extension remained relatively high, comprising over 40% of
the total contacts in 2006.
Currently in 2007, credit and collection (26%) and
CASE NO. PAC-07-
09/28/07
KLEIN , D.
STAFF
(Di)
line extension (23%) issues continue to be the major concerns
expressed by customers.
Staff reviewed all PacifiCorp complaints concerning
Line Extension/Installation and Service Outage/Repair for
2005, 2006, and year to date 2007, and did not find any
trends or patterns that warranted further investigation.
regard to line extensions, the issues raised most often were
in regard to cost and who is responsible to pay for that cost
as well as delays caused by either weather, changes made by
the customer, or the actions of the customer.Staff found
that the Company had followed its tariff in all accounts.
The complaints that pertained to billing dealt with rate
schedules, billing due to slow or dead meters, and recurring
and non-recurring charges not related to usage.
To what might PacifiCorp s good performance with
regard to the low number of complaints and inquiries be
attributed?
When PacifiCorp merged with Scottish Power in 1999,
eight customer service guarantees and seven performance
standards were established.The guarantees and standards
were subsequently modified in 2005.When the Commission
approved MidAmerican Energy Holdings Company (MEHC)
acquisition of PacifiCorp in 2006 (Case No. PAC-05-8), the
seven customer service guarantees and six performance
standards in effect at that time were retained.Exhibi t
CASE NO. PAC-07-
09/28/07
KLEIN, D.
STAFF
(Di)
No. 116 describes these guarantees and standards in greater
detail.MEHC and PacifiCorp committed to continue the
guarantees and standards through 2011.The guarantees
provided conditions under which customers received payouts
from the Company when the Customer service guarantees were
not met.Customer service guarantees provide clear
performance goals for employees and provide motivation for
bet ter customer service.
wi th respect to the customer guarantees and
performance standards, how is the Company performing?
The standards and guarantees have been successful
in driving performance improvements.The Company regularly
reports on its performance and meets with Staff to discuss
its progress in meeting its goals.
Is PacifiCorp responsive to the Commission
Utility Compliance Investigators during complaint
investigation?
Yes.Rule 404 in the Utility Customer Relations
Rules states that within ten business days of receiving
notification from the Commission that an informal complaint
involving the Company has been filed with the Commission,
utilities must either respond orally or in writing to the
Commission.YTD 2007 the average length of time to resolve
informal PacifiCorp complaints was 4.32 days.PacifiCorp is
well wi thin the acceptable parameters set by the UCRR.
CASE NO. PAC-07-
09/28/07
KLEIN, D.
STAFF
(Di)
CALL CENTER PERFORMANCE
What are PacifiCorp s performance objectives for
its call centers?
PacifiCorp s performance objective is to answer 80%
of its calls within 30 seconds.
Is PacifiCorp s goal reasonable?
In Staff's opinion , service levels of 80% ofYes.
calls answered wi thin the range of 20 - 3 0 seconds . are
reasonable.
How have PacifiCorp s call centers performed?
Very well.Staff requested call center data for
2005, 2006, and year to date 2007.The Company provided 30
months of data.The Company s call centers achieved their
performance obj ecti ves in 20 of those months.The lowest
service level during that time period was 75% and the high
was 85%.During the last 15 months of data, the Company
achieved a service level of 79% or higher.
Does this conclude your direct testimony in this
proceeding?
Yes, it does.
CASE NO. PAC-E- 07-
09/28/07
KLEIN, D.
STAFF
(Di)
ENERGY UTILITIES
ESTABLISHMENT OF SERVICE CHARGES
Atlanta Power - Connection Charge
$25
Schedule page
The charge applies to a customer establishing service for the first time at a service
location.
Idaho Power - Service Establishment Charge
$20 for Schedules 1 , 7, 9, 19 24 & 25
Sheet F-, Rule F; Sheet 66-Schedule
The charge applies to a customer establishing service at a location where service is
currently energized. See list of Reconnect ion Charges for charges applicable to a
customer establishing service at a location where service is not currently energized. An
owner/manager with a Continuous Service Agreement will not be charged a Service
Establishment Charge. Instead, he/she is charged a Continuous Service Reversion
Charge each time service reverts to the owner/manager s name. A tenant establishing
service at a location with a Continuous Service Agreement will pay the Service
Establishment Charge.
Intermountain Gas - Account Initiation Fee
$14 during normal business hours; $40 all other times
Sheet Section A
The charge applies to each new account opened. It does not apply to rental property
covered by a continuous service agreement or to safety inspections of new buildings or
equipment prior to turn on.
Rocky Mountain Power - Service Connection Charge
$50 from 4 to 7 p., Monday-Friday, except holidays; $50 from 8 a.m. to 4 p.
weekends or holidays
Sheets 3R.l and 300., Schedule 300
There is no charge for establishment of service during normal office hours, 8 a.m. to
4 p., Monday-Friday, except holidays. A charge applies to each new account opened
at times other than normal office hours.
Page I of 4
Exhibit No. 114
Case No. PAC-07-
D. Klein, Staff
9/28/07 Page 1 of 4
Avista - New Customer Turn-On Charge
$48 after normal business hours
Electric: Sheet 70-, Rule
Gas: Sheet 170-, Rule
There is no charge for establishing service during normal business hours. The charge
applies to each new gas or electric customer service connection at times other than
normal office hours. If gas and electric service connections are performed at same time
only one $48 charge applies.
Page 2 of 4
Exhibit No. 114
Case No. PAC-07-
D. Klein, Staff
9/28/07 Page 2 of 4
ENERGY UTILITIES
RECONNECTION CHARGES
Atlanta Power - Reconnection Charge
$25 for customers disconnected for a period of 30 days or less; $200 for customers
disconnected for more than 30 days
Schedule page
Idaho Power - Service Connection Charge
Schedules 1. 7 & 9
Connect/reconnect on weekdays
$20 for customer request from 7:30 a.m. to 6 p.
$45 for customer request from 6:01 p.m. to 9 p.
$80 for customer request from 9:01 p.m. to 7:29 a.
Connect/reconnect on weekends & holidays
$45 for customer request from 7:30 a.m. to 9:00 p.
$80 for customer request from 9:01 p.m. to 7:29 a.
Schedules 15. 19.24.25.40.41 & 42
Connect/reconnect on weekdays
$40 for customer request from 7:30 a.m. to 6 p.
$65 for customer request from 6:01 p.m. to 9 p.
$100 for customer request from 9:01 p.m. to 7:29 a.
Connect/reconnect on weekends & holidays
$65 for customer request from 7:30 a.m. to 9:00 p.
$100 for customerrequest from 9:01 p.m. to 7:29 a.
Sheet F-, Rule F; Sheets 66-2 & 66-Schedule
The charge applies to customers who are establishing service or requesting reconnection
of service at a premise where service is not currently energized.
Intermountain Gas - Reconnection Charge
$20 for reconnections performed during normal business hours (8 a.- 5:00 p.
Monday- Friday, except holidays); $40 all other times
Sheet Section A
The charge applies to reconnection performed after involuntary disconnection of
servIce.
Page 3 of 4
Exhibit No. 114
Case No. PAC-07-
D. Klein, Staff
9/28/07 PagEt 3 of 4
Rocky Mountain Power - Reconnection Charge
$25 during hours of 8 a.m. to 4 p., Monday-Friday, except holidays
$50 from 4 to 7 p., Monday-Friday, except holidays
$50 from 8 a.m. to 4 p., weekends or holidays
Sheets OR. 7 & 10R.8; Sheet 300., Schedule 300
The charge applies to reconnection performed after the customer is disconnected
involuntarily. It the customer pays or makes satisfactory arrangements during the hours
of 8 a.m. to 7 p.m. weekdays, excluding holidays, or 8 a.m. to 4 p., weekends and
holidays, reconnect will be done the same day. If payment or arrangements are made at
other times, the company will reconnect service the following day, except in the case of
medical emergencies and disconnect in error, which will be done the same day.
Avista - Reconnection Charge (involuntary disconnects) & Gas Service Reestablishment
Charge or Electric Reestablishment Charge (voluntary or seasonal disconnects)
Gas & electric service
$24 during hours of 8 a.m. to 4 p., Monday-Friday, except holidays
$48 from 4 to 7 p., Monday-Friday, except holidays
$48 weekends or holidays
Gas: Sheet 170-, Rule 15.1; Sheet 170-, Rule 15.
Electric: Sheet 70-, Rules 14.1 & 14.
The Reconnection Charge applies to reconnection performed after the customer is
disconnected involuntarily. It the customer pays or makes satisfactory arrangements
during the hours of 8 a.m. to 7 p.m. weekdays, excluding holidays, or 8 a.m. to 4 p.
weekends and holidays, reconnect will be done the same day. If payment or
arrangements are made at other times, the company will reconnect service the following
day, except in the case of medical emergencies and disconnect in error, which will be
done the same day.
The Gas Service Reestablishment Charge or Electric Reestablishment Charge applies if
service is reestablished after the customer voluntarily requests disconnection, including
seasonal disconnection of service. If arrangements for reconnection are made during
hours of 8 a.m. to 7 p.m. weekdays, excluding holidays, reconnection will take place the
same day. If arrangements are made on holidays, weekends, or hours between 7 p.
and 8 a.m. weekdays, the company will reconnect service the following day, except in
the case of medical emergencies and disconnect in error, which will be done the same
day. If service is reestablished within 12 months of the date of voluntary or seasonal
disconnection, the customer must also pay the monthly minimum charge for each month
during which service was disconnected.
Page 4 of 4
Exhibit No. 114
Case No. PAC-07-
D. Klein, Staff
9/28/07 Page 4 of 4
PacifiCorp Idaho Complaints
2004 - 2007
2004 2005 2006 2007
All Other
PacifiCorp Idaho Inquiries
2004 - 2007
2004 2005 2005 2007
.( , .. , '
5/1. , r
Line Extensionllnstallatione.~J"" "e.'e:,aL'
", ,-""""
Billing ~Z"dD
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PacifiCorp Idaho Complaints & Inquiries
2004 - 2007
2004 2005 2006 2007
Exhibit No. 115
Case No. PAC-07-
D. Klein, Staff
9/28/07
'ROCKY MOUNTAIN
~ e9~~c~o"e
IDAHO
. Service Quality Review
April 2006 - December 2006
EXECUTIVE SUMMARY
Rocky Mountain Power Power Delivery has a number of Customer Service Standards and Service
Quality Measures with performance reporting mechanisms currently in place. These standards and
measures define Rocky Mountain Power s target performance (both personnel and network reliability
performance) in delivering quality customer service. The Company developed these standards and
measures using industry standards (to the extent they exist) for collecting and reporting performance
data. In some cases , Rocky Mountain Power has decided to exceed these industry standards. In other
cases, largely where the industry has no established standards , Rocky Mountain Power
has developed metrics , targets and reporting. These standards and measures can be used over time
both historically and prospectively, to measure the service quality delivered to our customers.
Service Standards Program Summary
Effective April 2005 through March 31 , 2008
Rocky Mountain Power Customer Guarantees
Customer Guarantee 1 :The Company will restore supply after an
Restoring Supply After an Outage outage within 24 hours of notification with
certain exceptions as described in Rule 25.
Customer Guarantee 2:The Company will keep mutually agreed upon
Appointments appointments which will be scheduled within a
two-hour time window.
Customer Guarantee 3:The Company will switch on power within 24
Switching on Power hours of the customer or applicant's request
provided no construction is required , all
government inspections are met and
communicated to the Company and required
payments are made. Disconnections for
nonpayment, subterfuge or theft/diversion of
service are excluded.
Customer Guarantee 4:The Company will provide an estimate for new
Estimates For New Supply supply to the applicant or customer within 15
working days after the initial meeting and all
necessary information is provided to the
Company,
Customer Guarantee 5:The Company will respond to most billing
Respond To Billing Inquiries inquiries at the time of the initial contact.For
those that require further investigation, the
Company will investigate and respond to the
Customer within 10 working days.
Customer Guarantee 6:The Company will investigate and respond to
Resolving Meter Problems reported problems with a meter or conduct a
meter test and report results to the customer
within 10 workinq days,
Customer Guarantee 7:The Company will provide the customer with at
Notification of Planned Interruptions least two days notice prior to turning off power
for planned interruptions.
Exhibit No. 116
Case No. PAC-07-
D. Klein, Staff
9/28/07 Page 1 of
ROCKY MOUNTAIN
~ ~9~~c~o",
IDAHO
Service Quality Review
April 2006 - December 2006
2 Rocky Mountain Power Performance Standards
Network Performance Standard 1:The Company will improve SAlOl by 6% by
Improve System Average Interruption Duration March 31 , 2008,
Index (SAlOl)
Network Performance Standard 2:The Company will improve SAIFI by 6% by
Improve System Average Interruption March 31 , 2008.
Frequency Index (SAIFI)
Network r-erformance Standard 3:The Company will reduce by 20% the circuit
Improve Under Performing Circuits performance indicator (CPI) for a maximum of
five under performing circuits on an annual
basis within five years after selection.
Network Performance Standard 4:The Company will restore power outages due
Supply Restoration to loss of supply or damage to the distribution
system on average to 80% of customers within
three hours.
Customer Service Performance Standard 5:The Company will answer 80% of telephone
Telephone Service Level calls within 30 seconds. The Company will
monitor customer satisfaction with the
Company s Customer Service Associates and
quality of response received by customers
through the Company s eQuality monitoring
system.
Customer Service Performance Standard 6:The Company will a) respond to at least 95%
Commission Complaint Response/Resolution of non-disconnect Commission complaints
within three working days and will b) respond
to at least 95% of disconnect Commission
complaints within four working hours , and will
c) resolve 95% of informal Commission
complaints within 30 days.
tvote.'
Performance Standards , 2 & 4 are for underlying performance days and exclude those classified
Major Events.
Exhibit No. 116
Case No. PAC-07-
D. Klein, Staff
9/28/07 Page 2 of 4
ROCKY MOUNTAJN
e2~~c~o.e
IDAHO
Service Quality Review
April 2006 - December 2006
Reliability Definitions
This section will define the various terms used when referring to interruption types , performance
metrics and the internal measures developed to meet its performance plans.
Interruption Types
Below are the definitions for interruption events.
Standard for Reliability Indices.
For further details , refer to IEEE P1366-2003
Sustained Outage
A sustained outage is defined as an outage of equal to or greater than 5 minutes in duration.
Momentary Outage
A momentary outage is defined as an outage of less than 5 minutes in duration. Rocky Mountain
Power has historically captured this data using substation breaker fault counts.
Reliability Indices
SAID!
SAlOl (sustained average interruption duration index) is an industry-defined term to define the
average duration summed for all sustained outages a customer experiences in a given time-frame. It
is calculated by summing all customer minutes lost for sustained outages (those exceeding 5
minutes) and dividing by all customers served within the study area. When not explicitly stated
otherwise, this value can be assumed to be for a one-year period.
Daily SAID!
In order to evaluate trends during a year and to establish Major Event Thresholds , a daily SAlOl value
is often used as a measure. This concept was introduced in IEEE Standard P1366-2003. This is the
day s total customer minutes out of service divided by the static customer count for the year. It is the
total average outage duration customers experienced for that given day. When these daily values are
accumulated through the year, it yields the year s SAlOl results.
SA!FI
SAIFI (sustained average interruption frequency index) is an industry-defined term that attempts to
identify the frequency of all sustained outages that the average customer experiences during a given
time-frame. It is calculated by summing all customer interruptions for sustained outages (those
exceeding 5 minutes in duration) and dividing by all customers served within the study area.
GEM!
CEMI is an acronym for Customers Experiencing Multiple (Sustained and Momentary) Interruptions.
This index depicts repetition of outages across the period being reported and can be an indicator of
recent portions of the system that have experienced reliability challenges. This metric is used to
evaluate customer-speCific reliability
GPI99
CPI99 is an acronym for Circuit Performance Indicator, which uses key reliability metrics (such as
SAlOl and SAIFI) to identify underperforming circuits. It excludes Major Event and Loss of Supply or
Transmission outages.
1 P1366-2003 was adopted by the IEEE Commissioners on December 23 2003. The definitions and methodology
detailed therein are now industry standards.Exhibit No. 116
Case No. PAC-07-
D. Klein, Staff
9/28/07 Page 3 of 4
~ ~9~fo
~OUNTAIN
IDAHO
Service Quality Review
April 2006 - December 2006
CPIO5
CPI05 is an acronym for Circuit Performance Indicator, which uses key reliability metrics (such as
SAlOl and SAIFI) to identify underperforming circuits, Unlike CPlgg it includes Major Event and Loss
of Supply or Transmission outages.
Performance Types & Commitments
Rocky Mountain Power recognizes two categories of performance: underlying performance and
major events. Major events represent the atypical , with extraordinary numbers and durations for
outages beyond the usual. Ordinary outages are incorporated within underlying performance. These
types of events are further defined below.
Major Events
A Major Event is defined as a 24-hour period where SAlOl exceeds a statistically-derived threshold
value , Reliability Standard IEEE P1366-2003.
Underlying Events
Within the industry, there has been a great need to develop methodologies to evaluate year-on-year
performance. This has led to the development of methods for segregating outlier days, via the
approaches described above. Those days which fall below the statistically-derived threshold
represent "underlying " performance , and are valid (with some minor considerations for changes
reporting practices) for establishing and evaluating meaningful performance trends over time.
Post-Merger Commitment Target
Because of the benefits that the Company and its customers and regulators experienced from the
Service Standards Program , the Company filed and received approval to continue the program
through 3/31/2008. From a reliability perspective, the Company continues to develop stretch goals
that will deliver important improvements to its customers.
Exhibit No. 116
Case No. PAC-O7-
D. Klein, Staff
9/28/07 Page 4 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF SEPTEMBER 2007
SERVED THE FOREGOING DIRECT TESTIMONY OF DANIEL KLEIN, IN CASE
NO. PAC-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
mSTIN BROWN
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
MAIL: iustin.brown~pacificorp.com
DATA REQUEST RESPONSE CENTER
ACIFICORP
825 NE MULTNOMAH STE 2000
PORTLAND OR 97232
MAIL: datarequest~pacificorp.com
(ELECTRONIC COPIES ONLY)
JAMES R SMITH
MONSANTO COMPANY
PO BOX 816
SODA SPRINGS ID 83276
MAIL: jim.r.smith~monsanto.com
ERIC L OLSEN
RACINE OLSON NYE BUDGE & BAILEY
PO BOX 1391
POCATELLO ID 83201-1391
MAIL: elo~racinelaw.net
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
MAIL: cew~givenspursley.com
BRIAN DICKMAN
MANAGER, ID REGULATORY AFFAIRS
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
MAIL: brian.dickman~JJacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE BUDGE & BAILEY
PO BOX 1391
POCATELLO ID 83201-1391
MAIL: rcb~racinelaw.net
MAURICE BRUBAKER
KATIE IVERSON
BRUBAKER & ASSOCIATES
1215 FERN RIDGE PARKWAY
SUITE 208
ST LOUIS MO 63141
MAIL: mbrubaker~consu1tbai.com
ki verson~consu1tbai. com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
MAIL: tony~yanke1.net
DENNIS E PESEAU, Ph.
UTILITY RESOURCES INC
1500 LIBERTY ST SE STE 250
SALEM OR 97302
MAIL: dpeseau~excite.com
CERTIFICATE OF SERVICE
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
MAIL: bmpurdv~hotmai1.com
KEVIN B HOMER
ATTORNEY AT LAW
1565 SOUTH BOULEVARD
IDAHO FALLS ID 83404
MAIL: kbh~khomer1aw.com
TIMOTHY SHURTZ
411 S. MAIN
FIRTH ID 83236
E- MAIL: tim~idahosupreme.com
CERTIFICATE OF SERVICE