20210527Nottingham Direct.pdf

BEFORE TIIE IDAIIO PTIBLIC UTILITTES COMMISSION
IN TIIE IUATTER OF THE
APPLICATION OF ROCI(Y
MOI]NTAIN POWER FOR
AUIHORITY TO INCREASE ITS
RATES AIID CHARGES IN IDAHO
AND APPROVAL OF PROPOSEI)
ELECTRIC SERYICE SCHEDULES
AND REGULATIONS
CASE NO. PAC-E-2I47
Direct Testimony of Melissa S. Nottingham
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ROCI(T MOUNTAIN POWER
CASE NO. PAC.E.2bA7
M:ay 2021
TABLE OF CONTENTS
I. INTRODUCTIONANDQUALIFICATIONS
II. PI.JRPOSE OF TESTIMONTY
ru. SCHEDULE 3OO
Returned Check Charge
Temporary Service Charge......
Paperless Bill Credit
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Iv. HOUSEKEEPING........
V. CONCLUSION..........
ATTACIIED EXHIBITS
Exhibit No. 3S-{alculations Supporting Proposed Charges and Credit
Nottingham, Dr - r
Rocky Mountain Power
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I. INTRODUCTIONANDQUALIFICATIONS
Please state your name, business address, and present position with PacifiCorp
dlbla Rocky Mountain Power (the "Company").
My name is Melissa S. Nottingham and my business address is 825 NE Multnomah
Street, Suite 2000, Portland, Oregon 97232. I am currently employed as Manager,
CustomerAdvocacy and TariffPolicy. I am testiffing for the Company.
Please describe your education and professional experience.
I have a Bachelor of Arts in English from Arizona State University. I began working
for the Company in 1996, I and worked in various positions with progressive
responsibility for the past 20 years. For the past 10 years, I have been the Manager of
CustomerAdvocacy and TariffPolicy in the Company's Regulation department.
Please describe your current duties.
My current duties include overseeing a team of regulatory analysts who respond to
consumer commission complaints, sponsoring tariff changes, ensuring compliance
with the Company's tariff regulations, and participating in general rate cases and other
regulatory proceedings for the Company's six state service territory. In addition, I
oversee a team of business analysts responsible for the administration of the contracts
for new electrical load and the implementation and operation of the Company's
customer guarantee program. As my team supports the Company's tariffregulations in
each state, we also support changes to Schedule 300, which are the charges associated
with the implementation of the regulations.
Nottingham, Di - I
Rocky Mountain Power
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Ilave you appeared as a witness in other regulatory proceedings?
Yes. I have testified in proceedings before the California Public Utilities Commission,
the Oregon Public Utility Commission, the Washington Utilities and Transportation
Commission, the Utah Public Service Commission, and the Wyoming Public Service
Commission.
II. PURPOSE OF TESTIMONY
What is the purpose of your testimony in this case?
My testimony supports proposed updates to charges in Schedule 300 and a proposal for
customers to receive a credit for selecting paperless billing. Additionally, I propose
housekeeping changes to Schedule 300 regarding the referenced regulations.
Why is the Company proposing these changes?
The proposed changes reflect the Company's continued commitment to keep costs
lower for our customers, update charges to align with current labors costs, and to
empower customers to control their monthly bills.
Please provide a summary of your testimony and the proposed changes.
My testimony supports the Company's proposal to update several customer charges in
Schedule 300. The Company reviewed the costs associated with Schedule 300 charges
and identified areas where costs have changed. A variety of factors, including
automation of returned checks and increased labor costs, have contributed to a change
in actual costs to perform work. Accordingly, the Company is proposing to align
customer charges to more accurately reflect current costs.
My testimony also supports the Company's proposal to implement a monthly
bill credit for customers who choose paperless billing ("Paperless Bill Credit"). The
Nottingham,Di - 2
Rocky Mountain Power
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proposed Paperless Bill Credit will incentivize customers to either remain on or select
this lower cost option and pass the cost savings to those customers. The credit is
reflected in proposed tariff changes to Regulation 8 and Schedule 300, which are
included in Company witness Mr. Robert M. Meredith's Exhibit No. 49.
All of the proposed changes are a continuation of PacifiCorp's ongoing
commitment to provide fair and reasonable charges by closely managing expenses
while still meeting customers' increasing expectations.
UI. SCHEDULE 3OO
Please describe the changes the Company is proposing to the Schedule 300
charges.
Table I shows the regulation, a description of the charge, the current charge, and the
proposed charge.
Table 1r
14 Returned Check Charge
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Please describe the Returned Check Charge.
If a customer presents a payment that is returned by the customer's bank, the Company
incurs a cost to process the returned payment. Payments can be returned for a variety
I The Company proposes to consolidate the single phase and three phase into one Temporary Service Charge,
with the same charge amount.
Nottingham, Di - 3
Rocky Mountain Power
Regulation Description of Charge Current Proposed
8R.2 Returned Check Charge $20 $12
12R.11 Temp Service Charge - Single Phase $8s $200
l2R.l I Temp Service Charge - Three Phase $l1s $200
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of reasons, including, but not limited to, insuffrcient funds, incorrect account numbers,
or closed accounts.
What is the current Returned Check Charge?
The current Returned Check Charge is $20.
What is the proposed change to the Returned Check Charge?
The Company proposes to reduce the Returned Check Charge from $20 to $12.
Additionally, the Company proposes to change the name of the Returned Check Charge
to Returned Payment Charge in Regulation 8R.2. As noted above, payments are made
in multiple different ways besides a check and can be returned by a financial institution.
The change brings the charge in line with current payment activities.
Why is the Company proposing this change?
Banks are now able to electronically transfer money from one bank to another bank
with less human interaction. This automation of a portion of the return payment process
has led to reduced costs to the Company when a payment is returned. Each time the
Company's bank receives a returned item, the bank assesses a fee to the Company.
These fees account for the majority of the cost to the Company when a customer's
payment is not acknowledged as valid. The fee can vary from $11 to $16 based on the
bank presenting the returned payment, the amount of the payment, and the number of
times the payment is presented for payment.
While processing these payments has become more automated, labor costs are
not completely eliminated. Each returned item requires that a Company employee
update the account information and reverse the payment if the billing system has
already posted the payment to the account. The labor costs range from $l to $6 per
Nottingham, Di - 4
Rocky Mountain Power
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1 transaction. The Company proposes a $12 Returned Payment Charge as it closely
2 represents the low-end of the average costs of both the labor and the bank fees
3 associated with these returned payments. See Exhibit No. 38 for the calculation of the
4 proposed charge.
5 Temporary Service Charge
6 Q. Please describe the Temporary Service Charge.
7 A. A Temporary Service Charge applies when a customer requests the energization of a
8 temporary pedestal for temporary electric service. Temporary pedestals are typically
9 needed for periods when a premise is under construction. The Temporary Service
l0 Charge covers the labor cost to bring either a single-phase or three-phase service line
I I to the temporary pedestal and energize the service. Once the service is energized, the
12 requesting customer is billed for the energy used. After the structure is completed, the
13 temporary service is de-energized and the meter is relocated to the permanent meter
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15 a. What is the current Temporary Service Charge?
16 A. The current Temporary Service Charge is $85 for single-phase service and $ll5 for
17 three-phase service.
18 a. What are the proposed changes to the Temporary Service Charge?
19 A. The Company proposes to increase the Temporary Service Charge to $200 for all
20 temporary service installations and combine all phases into one charge. The $200
2l charge is based on the current loaded rate for one hour and 30 minutes ofjourneyman
22 time, which is the average time to install temporary service for customers.
Nottingham, Di - 5
Rocky Mountain Power
1 Q. Why is the Company proposing a change to the Temporary Service Charge?
2 A. The Temporary Service Charge has not been regularly updated and does not reflect the
3 Company's current cost to provide this service. See Exhibit No. 38 for a summary of
4 the cost calculation.
5 Paperless Bill Credit
6 Q. Please describe the Paperless Bill Credit.
7 A. The Company proposes to add a credit to Schedule 300 and Regulation 8 to provide
8 customers a monthly credit if they have enrolled in paperless billing.
9 Q. What is the proposed amount of the Paperless Bill Credit?
l0 A. The proposed monthly credit is $0.50.
I I a. Why is the Company proposing a monthly credit for paperless billing?
12 A. The Company proposes a Paperless Bill Credit that is correlated to the savings and
l3 benefits of not sending a paper bill to a customer when that customer voluntarily enrolls
14 in paperless billing. Electronic delivery of the customer's monthly bill eliminates the
15 cost of the bill paper, the envelope, printing and stuffing of the envelope, and the
16 postage to mail the bill. Eliminating these costs results in savings of approximately
17 $0.49 per metered service. By passing this savings to the customer in a $0.50 monthly
18 credit, the Company is encouraging customers to utilize a billing option that is both
19 lower cost and more environmentally friendly. All customers, whether they are
20 currently participating in or are new to paperless billing, are eligible to receive a credit
2l as long as they are enrolled in paperless billing. Please see Exhibit No. 38 for more
22 detail on the calculation of the credit and Mr. Meredith's Exhibit No. 49 for the
23 proposed tariffchanges to Schedule 300 and Regulation 8.
Nottingham, Di - 6
Rocky Mountain Power
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IV. HOUSEKEEPING
What housekeeping changes is the Company proposing?
The Company is proposing housekeeping changes to Sheet Nos. 300.1 and 300.2 in
Schedule 300 to correct inaccurate sheet references and to Regulation 8.2 to change the
name from Returned Check Charge to Returned Payment Charge. Table 2 below
summarizes the proposed changes to these tariff sheets that can be found in Mr.
Meredith's Exhibit No. 49.
Thble 2
V. CONCLUSION
Please summarize your testimony.
The proposed changes to the Company's Schedule 300 represent both the ongoing
commitment by the Company to keep operational costs low for customers and align
Nottingham,Di-7
Rocky Mountain Power
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Housekeeping Changes
Sheet No.300.1
Name of the Charse Old Sheet No.New Sheet No.
Meter Test forAccuracy 7R.l 7P..2
Fee paid to mobile home operators who sub-meter tenants 7P..2 7R.3
Name of the Charge New Name of the Charse
Retumed Check Charge Returned Payment Charge
Sheet No.300.2
Name of the Charse OId Sheet No.New Sheet No.
Security Deposit for New Service 9R.2 9R.4
Sheet No.300.4
Name of the Charge Old Sheet No.New Sheet No.
Customer Guarantee Credit 5: Respondine to Bill Inquiries 25R.2 25R.3
Rule 8, Sheet 8R.2
Name of the Charse New Name of the Charse
Retumed Check Charge Returned Payment Charge
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customer charges with cost. The proposed Paperless Bill Credit creates an opportunity
for customers to manage costs and directly receive the benefits of their choices.
What is your recommendation regardlng changes to Schedule 300, Regulation 8n
and the proposed Paperless Bill Credit?
I recommend that the Commission approve the updated charges in Schedule 300, the
proposed Paperless Bill Credit in Regulation 8, and the identified housekeepiug
changes.
Does this conclude your direct testimony?
Yes.
Nottingham, Di - 8
RockyMountain Power