20210817Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTTLITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9917
Street Address for Express Mail:
I I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
r,rj '\, I ':aii L':iJ
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO REVISE ELECTRIC SERVICE
SCHEDULE NO. 3OO-REGULATION
CHARGES
CASE NO. PAC.E,-2I-I'
COMMENTS OF THE
COMMISSION STAFF
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STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of record,
Dayn Hardie, Deputy Attorney General, submits the following comments.
BACKGROUND
On June 23,2021, PacifiCorp dba Rocky Mountain Power ("Company") applied to the
Commission for authority to revise Electric Service Schedule No. 300 ("Schedule No. 300"F
Regulation Charges-to add a fee for remote reconnection of service. The Company requests an
effective date of September 1,2021, and that its Application be processed by Modified Procedure.
The Company has begun installation of the held area network for advanced metering
infrastructure ("AMI") in its ldaho service territory. Installation of AMI meters will commence in
the fourth quarter of calendar year 2021. The Company anticipates completing replacement of
existing electric service meters by fall of 2022.
AMI in ldaho will provide a secure network that will allow two-way communications from
smart meters. AMI will provide functionality that enables efficiencies in metering and operations,
1STAFF COMMENTS AUGUST 17,2O2I
including the ability to remotely disconnect and reconnect customer service for non-payment and
move-in and move-outs. I
When the AMI is installed and the network is fully in place and operational, the Company
anticipates using the remote disconnection and reconnection functions, eliminating the need to
dispatch any personnel for these tasks. The Company proposes a remote reconnect fee subject to
the terms stated in Rule l0-Termination of Service and Payment Arrangements-for
disconnections due to non-payment.
Until AMI capability is operational, if the Company must dispatch personnel to a customer's
home, the currently authorized Schedule No. 300 reconnection fees of $25 or $50 will apply.
Once the AMI meters are installed and have capabilities to disconnect and reconnect
remotely, the Company proposes a remote reconnection fee based on the resources required to
process a customer's initial request for a quote to have power turned on but excluding truck or field
labor expenses. The proposed remote reconnection fee is $7 and would be included in Schedule
No. 300, if approved.
STAFF ANALYSIS
Staff reviewed the Company's Application and accompanying tariff revisions and supports
the Company's proposal to add a $7 fee for the remote reconnect fee for customers who have AMI
meters. The Commission previously found it "reasonable and in the public interest for Idaho Power
and Avista to reduce their reconnection charges as proposed ...." See Order No. 33229 at I 1.
Additionally, for customers with an AMI meter and remote connect/disconnect capability, the $7
proposed fee would be a considerable cost reduction in the reconnection fees currently authorized to
be collected and it eliminates the need for a variable reconnection fee based on the time-of-day
reconnection occurs.
Reconnection Charges
Presently, the amount charged for reconnection to restore service depends on when the
customer makes the reconnection request. The Company is currently authorized to collect a
Reconnection Charge of $25 for reconnections during normal business hours and a $50 for
I For a complete list of the efficiencies in metering and operations provided by AMI infrastructure please see the
Company's Application at 2.
2STAFF COMMENTS AUGUST I7,2O2I
reconnections outside of normal business hours. The Company's normal office hours are 8:00 am to
4:00 pm Monday through Friday. In situations where the Company has installed meters with
remote connect/disconnect capability, Staff believes the reconnection charge should be reduced to
recognize the cost savings associated with remote disconnection and reconnection of service.
In Case No. GNR-U-14-01, the Commission approved a reduced Reconnection Charge of
$12 during normal business hours and $24 for reconnection outside of normal business for similarly
situated Avista customers. See OrderNo. 33229 at 11. Additionally in Case No. SUZ-W-I9-01,
the Commission ordered Suez to reduce its Reconnection Charge by 50% where Suez installed
meters with remote connect/disconnect capabilities2. See Order No. 34405 at 5. In this case, Staff
recommends the Commission adopt the Company's proposal.
Staff agrees with the Company that there should be no changes to the current non-remote
reconnection fees at this time. As previously mentioned, during the AMI rollout, not all meters will
have the ability to remotely disconnect or reconnect service. Until the meter can utilize its full AMI
capabilities and the Company must dispatch personnel to a customer's home, the currently
authorized Schedule No. 300 non-remote reconnection fees should apply.
Reconnection Process
Once meters have remote disconnection and reconnection capabilities, the Company plans
to implement an automated reconnection process. When payment is received through one of the
Company's payment channels following involuntary disconnect of service, an order to reconnect
service will be automatically generated eliminating the need for the customer to make another
phone call to veriff payment and request reconnection of service.3 Linking the payment process to
the remote connection technology will reduce costs and subsequently lower customers' fees.
An additional beneht is the ability to reconnect service quickly. The Company estimates
that once an order to reconnect service is generated, service can be reconnected in less than 60
minutes.4
2 Reconnection charge reduced from $20 to $10 during normal business hours and from $30 to $15 outside ofnormal
business hours.3 See Response to Staff Production Request No. 14.a See Response to Staff Production Request No. I 3.
3STAFF COMMENTS AUGUST I7,2O2I
The Company expects AMI will eliminate most, but not all onsite visits to disconnect and
reconnect service. The Company intends to review reconnection charges, including the need for
non-remote reconnection charges, once full AMI deployment is complete.s
Fee Calculation
Staff recommends that the Company improve its method for calculating reconnection fees
going forward to better align the fee with actual costs to reconnect customers. The proposed $7 fee
is based on the Company's average operations and maintenance cost for each call answered by the
Company's call center employees in2017.6 The Company used 2017 datato align its reconnection
fee across its multi-state service territory.T Using more recent data may have led to a higher
reconnection fee.8 However, it is not clear that customer agent calls are correlated with customer
reconnection. The Company said that it does not track calls specific to reconnection and that
customers are not required to call the Company to request reconnection.e
Staff recommends that as the Company reconsiders its remote reconnection fee, it should
consider fees based on the most recent, Idaho specific data, and should be based on costs directly
related to remote reconnection.
Customer Notification and Customer Comments
The Commission established a comment deadline of August 17,2021. As of August 16,
2021, no customer comments were filed.
STAFF RECOMMENDATION
After examining the Company's Application, proposed tariff revisions, and worksheets,
Staff recommends the Commission approve the following:
1. The Commission approve the establishment of a new $7 fee for remote reconnection of
service for customers who have a meter with remote connect/disconnect capability;
2. The Company improve its method for determining reconnection fees based on recent
Idaho specific data.
5 See Response to Staff Production Request No. 3.6 See Page 3 of the Application and Workpaper "PAC-E-21-15 RMP Workpapers 6-23-2l.pd?'7 See Response to Staff Production Request No. 8.8 See Response to Staff Production Request No. 4.e See Response to Staff Production Request No. 5.
4STAFF COMMENTS AUGUST I7,2O2I
Respecttully sutmitted this t@ *rof Ar.rgust 2fr21.
Dayn
DeputyAttonrey Geneml
TechnioalStatr KevinKeyt
Brad Iverson-Long
Yao Yin
Curtis Thaden
i:umisc/oomrmnts/pace2l. I Sdhktolyyct mmmht
5STAFF COMMENTS AUGUST I7,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I7S DAY OF AUGUST 2021,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC.E-21-15, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
TED WESTON
ROCKY MOLTNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : ted.weston@pacifi corp. com
idahodockets@oacifi com.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pac i fi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE