20230608Answer and Motion to Dismiss REDACTED.pdf

1407 West North Temple, Suite 330 Salt Lake City, Utah 84116 June 8, 2023 VIA ELECTRONIC DELIVERY
Jan Noriyuki Commission Secretary Idaho Public Utilities Commission 11331 W Chinden Blvd. Building 8 Suite 201A
Boise, ID 83714 Re: CASE NO. PAC-E-23-12 FORMAL COMPLAINT OF SHERRY COLE

Dear Ms. Noriyuki:
Please find Rocky Mountain Power’s Answer in the above referenced matter.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at [phone]. Very truly yours,
Joelle Steward Senior Vice President of Regulation and Customer/Community Solutions

RECEIVED
Thursday, June 8, 2023 5:10:15 PM
IDAHO PUBLIC
UTILITIES COMMISSION
1
Joe Dallas (ISB# 10330)
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: [e-mail]
Attorney for Rocky Mountain Power

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

FORMAL COMPLAINT OF SHERRY
COLE VS PACIFICORP D/B/A ROCKY
MOUNTAIN POWER

CASE NO. PAC-E-23-12

ANSWER AND MOTION TO DISMISS

1. In accordance with Rule 57 of the Rules of Procedure of the Idaho Public Utilities
Commission (“Commission”), Rocky Mountain Power, a division of PacifiCorp (“Rocky
Mountain Power” or the “Company”) hereby provides its answer to the formal complaint
(“Complaint”) filed by Sherry Cole (“Complainant” or “Ms. Cole”) with the Commission on April
4, 2023. In addition, the Company moves to dismiss the Complaint in its entirety because
Complainant has failed to state a claim upon which relief can be granted. Complainant has not
alleged that Rocky Mountain Power violated any specific statute, administrative rule, Commission
order, or Company tariff in resolving the billing errors at issue in this proceeding.
2. Communications regarding this Case should be addressed to:
By e-mail (preferred):

[e-mail]
[e-mail]
[e-mail]

By mail: Data Request Response Center
Rocky Mountain Power
825 NE Multnomah St., Suite 2000
Portland, OR 97232
2

Mark Alder
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
Email: [e-mail]

Joe Dallas (ISB# 10330)
Senior Attorney
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: [e-mail]

I. INTRODUCTION
3. The Complainant alleges that the Company owes her $1170.08 for charges that
were mistakenly billed to her due to an error in calculating her billing based on her neighbor's
meter. According to the Complainant, her meter and her neighbor's meter were initially crossed
approximately 5 years ago. The Company initially credited Ms. Cole’s account with $1850.52 in
error, believing that her meter was indeed crossed with her neighbor’s. However, a subsequent
breaker test conducted by the Company confirmed that Ms. Cole’s meter is accurately associated
with her own account. Consequently, the Company reversed the initial credit of $1850.52, but
provided a goodwill compensation of $450 to address the inconvenience caused by the bill credit
and reversal. The Company has carefully reviewed and verified that Ms. Cole has been
appropriately billed for the electric usage associated with her account. Throughout this process,
the Company has acted in good faith and in accordance with its tariffs, specifically Electric Service
Regulation No. 7(a), which allows the Company to rectify certain billing errors. Therefore, based
on the foregoing and the Company’s adherence to its applicable tariffs, the Rocky Mountain Power
respectfully requests that the Complaint be dismissed.
3
II. BACKGROUND INFORMATION ON BILLING ERROR
4. The following is a timeline of events:
 January 3, 2023: Ms. Cole contacted the Company and expressed her belief that her
meter was crossed with her neighbor’s meter. In response, the Company’s customer
service agent initiated a work order to have her meter checked.
 January 13, 2023: The Company’s meter reader visited the location to inspect the
meters. However, during this visit, the meter reader misunderstood the purpose of the
visit and did not conduct a breaker test to electrically verify if the meters were crossed.
A breaker test is a procedure performed to determine whether there is a cross-
connection or misalignment in the electrical wiring between meters. It involves
temporarily disconnecting the electrical supply to each meter and observing any impact
on neighboring meters to identify potential cross-connections. The main service
disconnect breaker is utilized, if available, to turn off the electrical supply downstream
from a specific meter, allowing an individual to assess what is served (or not served)
by that meter. This helps in identifying any cross-connections or misalignments in the
electrical wiring between meters. Instead of conducting a breaker test, the meter reader
concluded that the meters were crossed based on a visual inspection of the meters and
information provided by Ms. Cole.
 January 25, 2023: Based on the information provided by the meter reader, the
Company’s billing agent made adjustments to the billing.1 The adjustment was made
pursuant to Electric Service Regulation No. 7(a) which states that the corrected billing

1 It is important to note that the Company subsequently rectified this error by conducting a subsequent breaker test.
The breaker test confirmed the accurate association of Ms. Cole's meter with her own account, thereby resolving any
doubts or confusion. The Company took prompt action to correct the issue and ensure that Ms. Cole's billing and
meter were properly aligned.
4
should not exceed six months if the time when the malfunction or error began cannot
be reasonable determined. However, the billing agent made a seven-month
adjustment,2 reconciling the neighbor’s and Ms. Cole’s meter. As a result, Ms. Cole
received a bill on January 30, 2023, which removed $1,857.20 in charges and added
$600.75 in charges, resulting in net credit of $1,256.45 for the period from June 2022
to December 2022. The January 30, 2023 bill, detailing these adjustments, is attached
to this Answer as Confidential Exhibit No. 1 – Customer Bills.
 February 8, 2023: A Company meter reader revisited the property and conducted a
breaker test, which confirmed that the meters were not crossed.
 February 20, 2023: The initial billing adjustment made on January 30, 2023, was
reversed which removed $596.20 in charges and added $1850.52 in charges resulting
in $1,254.20 net credit reversal for the months from June 2022 to December 2022. The
net credit reversal was $2.25 less than the net credit due to the Company’s system which
automatically calculates prorations when making monthly adjustments. The details of
this adjustment are included with Ms. Cole’s February 28, 2023 billing statement which
is included in Confidential Exhibit No. 1 – Customer Bills. The calculation for the net
credit and net credit reversal are attached as Exhibit No. 2 – Credit Reversal
Calculations.
 On March 2, 2023, Ms. Cole contacted the Company after receiving the adjusted bill.
She was extremely upset and wanted the charges removed. The Company’s billing
agent attempted to explain the reason for the reversal, but Ms. Cole was convinced that

2 The Company acknowledges that the adjustment made on January 25, 2023 should have been for six months as
required by Electric Service Regulation No. 7(a). However, the Company believes that the customer was not harmed
by this additional month since the Company has since reversed this charge.
5
the meters were crossed and believed she had been paying for her neighbor’s bill for
years. She expressed she would contact the public utility commission and ended the
phone call.
 March 13, 2023: A Company meter reader revisited the location once again and verified
that the meters were not crossed by conducting a second breaker test. The meter reader
performed the breaker test to ensure the accuracy of the meter readings. During this
visit, Ms. Cole was present at home and was informed about the results of the breaker
test.
 March 15, 2023: The Company credited Ms. Cole with a goodwill credit of $450 for
the inconvenience caused by the bill credit and reversal. The credit is on Ms. Cole’s
March 29, 2023 billing statement which is included with Confidential Exhibit No. 1 –
Customer Bills.
 May 17, 2023: The Company confirmed electronic receipt of Complainant’s Complaint
from Staff and notification that the Company would have 21 days from May 18, 2023,
to respond to the Complaint.
III. ANSWER TO COMPLAINANT’S ALLEGATIONS
5. On January 30, 2023, a credit of $1,256.45 was applied to Ms. Cole’s bill in
accordance with Electric Service Regulation No. 7(a). The rule specifies that corrected billing
should not exceed six months if the time when the malfunction or error began cannot be reasonable
determined. The credit was initially given based on the assumption that Ms. Cole’s meter was
crossed with her neighbor’s. However, a breaker test performed by the Company confirmed that
Ms. Cole’s meter was never actually physically crossed with her neighbor’s. Therefore, the credit
of $1,256.45 credit was given in error and was subsequently reversed by the Company. The
6
Company acknowledges that there was an initial error during the January 13 visit when the meter
reader relayed the incorrect information to the customer service representative. As a gesture of
goodwill, the Company credited Ms. Cole $450 for the inconvenience caused by the credit and its
subsequent reversal. The Company recognizes that utility bills can be a substantial fixed costs for
its customers and expresses regret for the initial billing error made in this case.
6. Electric Service Regulation No. 7(a) specifically anticipates the occurrence of
billings errors during operations and outlines the appropriate procedures to follow once an error is
discovered. The Company has acted in good faith and in accordance with this rule throughout the
entire process.3 Furthermore, after thorough investigation, the Company has confirmed that Ms.
Cole’s meter is not crossed with her neighbor’s meter. Both Ms. Cole and her neighbor are being
billed appropriately for their electric usage. The verification of the meters through the breaker tests
confirmed that the billing is accurate and reflective of their actual electricity consumption.
Moreover, the Company has already provided the customer with an adequate credit to address the
inconvenience caused by the billing error. Granting any additional credits or compensation to the
customer would result in an excessively large credit, which would not be aligned with Rocky
Mountain Power’s ability to effectively and reliably serve all of its customers in a cost-effective
manner. Consequently, the Company respectfully requests that the relief sought in the Compliant
be denied based on its compliance with Electric Service Regulation No. 7(a), confirmation of meter
accuracy, and the credit already provided to address the initial billing error.
IV. MOTION TO DISMISS
7. Rocky Mountain Power incorporates by reference paragraphs 4 through 6 as if set
forth herein.

3 Supra footnote 2.
7
8. Based on the foregoing, Rocky Mountain Power moves to dismiss the Complaints
under Rule 256 of the Rules of Procedure of the Idaho Public Utilities Commission for failure to
state a claim. The Complainant has not identified any specific administrative rule, order, statute,
or applicable provision of the Company’s tariff that Rocky Mountain Power violated. The
Company has acted in accordance with Electric Service Regulation No. 7(a) to rectifying the
billing error identified in this case. Additionally, the Company has conducted thorough verification
confirming that the customer’s meter is not crossed with her neighbor’s and has already provided
the customer with an appropriate credit to address the inconvenience caused by the billing error.
Accordingly, the Company requests that the Commission dismiss the Complaint with prejudice.
V. CONCLUSION
9. For the foregoing reasons, the Company requests that the Commission deny the
relief sought in the Compliant and dismiss the Complaint with prejudice.
DATED this 8th day of June, 2023.
Respectfully submitted,
ROCKY MOUNTAIN POWER

______________________________
Joe Dallas (ISB# 10330)
Senior Attorney
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: [e-mail]

Attorney for Rocky Mountain Power

REDACTED EXHIBIT 1
New Mailing Address or Phone?
Please print your new information below and check the box on
the reverse side of this Payment Stub. Thank you.
ACCOUNT NUMBER: 75048095-001 3
LAST FIRST
NEW STREET ADDRESS
CITY
ST ZIP TELEPHONE NUMBER
M.I.
PAGE 2 OF 4
BILLING DATE: Jan 30, 2023 ACCOUNT NUMBER: 75048095-001 3 DUE DATE: Feb 25, 2023 AMOUNT DUE: $0.00
Questions about your bill: Call toll free 1-888-221-7070 rockymountainpower.net
Av
e
r
a
g
e

k
w
h
/
d
a
y
J F M A M J J A S O N D J
6
12
18
24
30
20232022
NEW CHARGES 05/22 CONTINUED UNITS COST PER UNIT CHARGE
St Anthony Franchise Fee 0.0100000 0.04
Total New Charges 4.43
ADJUSTMENTS CHARGE
05/22 Fee Waived -1.35
06/22 Billed From Incorrect Meter 05/25/22 - 06/24/22 -122.11
06/22 Fee Waived -0.65
07/22 Billed From Incorrect Meter 06/24/22 - 07/27/22 -213.31
08/22 Billed From Incorrect Meter 07/27/22 - 08/25/22 -149.61
09/22 Billed From Incorrect Meter 08/25/22 - 09/26/22 -159.55
10/22 Billed From Incorrect Meter 09/26/22 - 10/25/22 -209.09
11/22 Billed From Incorrect Meter 10/25/22 - 11/28/22 -507.18
12/22 Adjusted Estimated Read 11/28/22 - 12/28/22 -494.35
Total Adjustments -1,857.20
ITEM 9 - ELECTRIC SERVICE
Residential Schedule 1
METER
NUMBER
SERVICE PERIOD
From To
ELAPSED
DAYS
METER READINGS
Previous Current
METER
MULTIPLIER
AMOUNT USED
THIS MONTH
342852591 Dec 28, 2022 Dec 28, 2022 8390 8390 1.0
341834327 Dec 29, 2022 Jan 27, 2023 8390 9043 1.0
Total 30 653 kwh
Next scheduled read date: 02-27. Date may vary due to scheduling or weather.
NEW CHARGES 01/23 UNITS COST PER UNIT CHARGE
Basic Charge - Single Phase 8.00
Energy Charge Winter Block 1 653 kwh 0.0933050 60.93
Energy Cost Adjustment 653 kwh 0.0073300 4.79
Customer Efficiency Services 0.0250000 1.84
Tax Act Adjustment 653 kwh -0.0018200 -1.19
B P A Columbia River Benefits 653 kwh -0.0101330 -6.62
St Anthony Franchise Fee 0.0100000 0.68
Total New Charges 68.43
NEW CHARGES 12/22 UNITS COST PER UNIT CHARGE
Basic Charge - Single Phase 8.00
Energy Charge Winter Block 1 685 kwh 0.0933050 63.91
Energy Cost Adjustment 685 kwh 0.0073300 5.02
Historical Data - ITEM 9
Your Average Daily kwh Usage by Month
PERIOD ENDING Jan 2023 Jan 2022
Avg. Daily Temp. 21 17
Total kwh 653 0
Avg. kwh per Day 22 0
Cost per Day $2.28 $0.00
REDACTED
PAGE 3 OF 4
BILLING DATE: Jan 30, 2023 ACCOUNT NUMBER: 75048095-001 3 DUE DATE: Feb 25, 2023 AMOUNT DUE: $0.00
Questions about your bill: Call toll free 1-888-221-7070 rockymountainpower.net
NEW CHARGES 12/22 CONTINUED UNITS COST PER UNIT CHARGE
Customer Efficiency Services 0.0250000 1.92
Tax Act Adjustment 685 kwh -0.0018200 -1.25
B P A Columbia River Benefits 685 kwh -0.0101330 -6.94
St Anthony Franchise Fee 0.0100000 0.71
Total New Charges 71.37
NEW CHARGES 11/22 UNITS COST PER UNIT CHARGE
Basic Charge - Single Phase 8.00
Energy Charge Summer Block 1 for 6 day(s)123 kwh 0.1119660 13.77
Energy Charge Winter Block 1 for 28 day(s)574 kwh 0.0933050 53.56
Energy Cost Adjustment 697 kwh 0.0073300 5.11
Customer Efficiency Services 0.0250000 2.01
Tax Act Adjustment 697 kwh -0.0018200 -1.27
B P A Columbia River Benefits 697 kwh -0.0101330 -7.06
St Anthony Franchise Fee 0.0100000 0.74
Total New Charges 74.86
NEW CHARGES 10/22 UNITS COST PER UNIT CHARGE
Basic Charge - Single Phase 8.00
Energy Charge Summer Block 1 534 kwh 0.1119660 59.79
Energy Cost Adjustment 534 kwh 0.0073300 3.91
Customer Efficiency Services
for 25 day(s)0.0250000 1.55
for 4 day(s)0.0225000 0.22
Tax Act Adjustment 534 kwh -0.0018200 -0.97
B P A Columbia River Benefits 534 kwh -0.0101330 -5.41
St Anthony Franchise Fee 0.0100000 0.67
Total New Charges 67.76
NEW CHARGES 09/22 UNITS COST PER UNIT CHARGE
Basic Charge - Single Phase 8.00
Energy Charge Summer Block 1 635 kwh 0.1119660 71.10
Energy Cost Adjustment 635 kwh 0.0073300 4.65
Customer Efficiency Services 0.0225000 1.88
Tax Act Adjustment 635 kwh -0.0018200 -1.16
B P A Columbia River Benefits 635 kwh -0.0101330 -6.43
St Anthony Franchise Fee 0.0100000 0.78
Total New Charges 78.82
NEW CHARGES 08/22 UNITS COST PER UNIT CHARGE
Basic Charge - Single Phase 8.00
Energy Charge Summer Block 1 700 kwh 0.1119660 78.38
Energy Charge Summer Block 2 158 kwh 0.1309990 20.70
Energy Cost Adjustment 858 kwh 0.0073300 6.29
Customer Efficiency Services 0.0225000 2.55
Tax Act Adjustment 858 kwh -0.0018200 -1.56
B P A Columbia River Benefits 858 kwh -0.0101330 -8.69
St Anthony Franchise Fee 0.0100000 1.06
Total New Charges 106.73
NEW CHARGES 07/22 UNITS COST PER UNIT CHARGE
Basic Charge - Single Phase 8.00
Energy Charge Summer Block 1 700 kwh 0.1119660 78.38
Energy Charge Summer Block 2 281 kwh 0.1309990 36.81
Energy Cost Adjustment 981 kwh 0.0073300 7.19
Customer Efficiency Services 0.0225000 2.93
Tax Act Adjustment 981 kwh -0.0018200 -1.79
B P A Columbia River Benefits 981 kwh -0.0101330 -9.94
St Anthony Franchise Fee 0.0100000 1.22
Total New Charges 122.80
NEW CHARGES 06/22 UNITS COST PER UNIT CHARGE
Basic Charge - Single Phase for 29 day(s)7.73
Energy Charge Summer Block 1 for 24 day(s) 510 kwh 0.1119660 57.10
Energy Charge Winter Block 1 for 5 day(s)106 kwh 0.0933050 9.89
Energy Cost Adjustment
for 24 day(s)510 kwh 0.0073300 3.74
PAGE 4 OF 4
BILLING DATE: Jan 30, 2023 ACCOUNT NUMBER: 75048095-001 3 DUE DATE: Feb 25, 2023 AMOUNT DUE: $0.00
Questions about your bill: Call toll free 1-888-221-7070 rockymountainpower.net
NEW CHARGES 06/22 CONTINUED UNITS COST PER UNIT CHARGE
for 5 day(s)106 kwh 0.0035400 0.38
Customer Efficiency Services 0.0225000 1.77
Tax Act Adjustment for 29 day(s)616 kwh -0.0018200 -1.12
B P A Columbia River Benefits for 29 day(s)616 kwh -0.0101330 -6.24
St Anthony Franchise Fee 0.0100000 0.73
Total New Charges 73.98
When you provide a check as payment, you authorize us to use the information from your check either to make a one-time
electronic fund transfer from your account or to process the payment as a check transaction. When we use information from
your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as we receive your pay-
ment and you will not receive your check back from your financial institution. If you would like to opt out of this program and
continue processing your payment as a check transaction, please call 1-800-895-0561. If you have opted out previously,
please disregard this message.
Manage your account with ease
Popular billing options include Auto Pay, Equal Pay and choice of due dates. You can even earn a credit each month when you
sign up for paperless billing. See details and enroll at rockymountainpower.net/billoptions
Looking for other ways to pay?
Visit rockymountainpower.net/pay for all your options. You can choose to pay on your device using our mobile app, on our
website, at a pay station in your community, or pay over the phone by calling 1-888-221-7070.
REDACTED
New Mailing Address or Phone?
Please print your new information below and check the box on
the reverse side of this Payment Stub. Thank you.
ACCOUNT NUMBER: 75048095-001 3
LAST FIRST
NEW STREET ADDRESS
CITY
ST ZIP TELEPHONE NUMBER
M.I.
PAGE 2 OF 2
BILLING DATE: Feb 28, 2023 ACCOUNT NUMBER: 75048095-001 3 DUE DATE: Mar 25, 2023 AMOUNT DUE: $1,154.13
Questions about your bill: Call toll free 1-888-221-7070 rockymountainpower.net
NEW CHARGES 02/23 CONTINUED UNITS COST PER UNIT CHARGE
St Anthony Franchise Fee 0.0100000 5.01
Total New Charges 505.54
ADJUSTMENTS CHARGE
01/23 Billed From Incorrect Meter 12/28/22 - 01/27/23 366.88
06/22 Billed From Incorrect Meter 05/26/22 - 06/24/22 43.45
07/22 Billed From Incorrect Meter 06/24/22 - 07/27/22 90.51
08/22 Billed From Incorrect Meter 07/27/22 - 08/25/22 42.88
09/22 Billed From Incorrect Meter 08/25/22 - 09/26/22 80.73
10/22 Billed From Incorrect Meter 09/26/22 - 10/25/22 141.33
11/22 Billed From Incorrect Meter 10/25/22 - 11/28/22 432.32
12/22 Billed From Incorrect Meter 11/28/22 - 12/28/22 422.98
Total Adjustments 1,621.08
When you provide a check as payment, you authorize us to use the information from your check either to make a one-time
electronic fund transfer from your account or to process the payment as a check transaction. When we use information from
your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as we receive your pay-
ment and you will not receive your check back from your financial institution. If you would like to opt out of this program and
continue processing your payment as a check transaction, please call 1-800-895-0561. If you have opted out previously,
please disregard this message.
Manage your account with ease
Popular billing options include Auto Pay, Equal Pay and choice of due dates. You can even earn a credit each month when you
sign up for paperless billing. See details and enroll at rockymountainpower.net/billoptions
Make a positive impact on the environment. Match all or part of your electricity usage with clean energy. Visit RockyMountain-
Power.net/BlueSky or call 1-800-769-3717 to learn more.
Looking for other ways to pay?
Visit rockymountainpower.net/pay for all your options. You can choose to pay on your device using our mobile app, on our
website, at a pay station in your community, or pay over the phone by calling 1-888-221-7070.
New Mailing Address or Phone?
Please print your new information below and check the box on
the reverse side of this Payment Stub. Thank you.
ACCOUNT NUMBER: 75048095-001 3
LAST FIRST
NEW STREET ADDRESS
CITY
ST ZIP TELEPHONE NUMBER
M.I.
PAGE 2 OF 2
BILLING DATE: Mar 29, 2023 ACCOUNT NUMBER: 75048095-001 3 DUE DATE: Apr 25, 2023 AMOUNT DUE: $925.20
Questions about your bill: Call toll free 1-888-221-7070 rockymountainpower.net
continue processing your payment as a check transaction, please call 1-800-895-0561. If you have opted out previously,
please disregard this message.

EXHIBIT 2

Date Billing Transaction Payment Adjustment New Charges End Balance
04/26/22 Beginning Balance 99.37$ 
4/27/2022 Regular Bill 235.32$         334.69$ 
5/18/2022 Payment 200.00$     134.69$ 
5/26/2022 Regular Bill 130.44$         265.13$ 
6/2/2022 Payment 200.00$     65.13$ 
6/27/2022 Regular Bill 122.76$         187.89$ 
7/11/2022 Payment 187.89$     ‐$ 
7/28/2022 Regular Bill 213.31$         213.31$ 
8/2/2022 Payment 213.31$     ‐$ 
8/29/2022 Regular Bill 149.61$         149.61$ 
9/12/2022 Payment 150.00$     (0.39)$ 
9/28/2022 Regular Bill 159.55$         159.16$ 
10/5/2022 Payment 215.00$     (55.84)$ 
10/27/2022 Regular Bill 209.09$         153.25$ 
11/8/2022 Payment 639.25$     (486.00)$ 
11/30/2022 Regular Bill 507.18$         21.18$ 
12/2/2022 Payment 150.00$     (128.82)$ 
12/30/2022 Regular Bill 494.35$         365.53$ 
1/3/2023 Payment 150.00$     215.53$ 
1/30/2023 Regular Bill ‐ January 2023 68.43$        (972.49)$ 
1/30/2023 Removed January 2023 (68.43)$       (1,040.92)$              
1/30/2023 Corrected January 2023 435.31$      648.59$ 
2/28/2023 Regular Bill ‐ February 2023 505.54$      1,154.13$                
3/3/2023 Payment 150.00$     1,004.13$                
3/15/2023 Good Will Payment 450.00$     554.13$ 
3/29/2023 Regular Bill ‐ March 2023 371.07$         925.20$ 
4/5/2023 Payment 125.00$     800.20$ 
4/27/2023 Regular Bill ‐ April 2023 275.53$         1,075.73$                
4/28/2023 Payment 150.00$     925.73$ 
Exhibit 2 Page 1 of 5
1/30/2023 Removed Dec 2022 Crossed Meter ‐494.35 ‐278.82
1/30/2023 Removed Nov 2022 ‐507.18 ‐786
1/30/2023 Removed Oct 2022 ‐209.09 ‐995.09
1/30/2023 Removed Sept 2022 ‐159.55 ‐1154.64
1/30/2023 Removed Aug 2022 ‐149.61 ‐1304.25
1/30/2023 Removed July 2022 ‐213.31 ‐1517.56
1/30/2023 Removed June 2022 ‐122.11 ‐1639.67
1/30/2023 Removed June 2022 Late fee ‐0.65 ‐1640.32
1/30/2023 Removed late fee ‐1.35 ‐1641.67
1/30/2023 Billed closing charge 4.43 ‐1637.24
1/30/2023 Corrected June 2022 73.98 ‐1563.26
1/30/2023 Corrected July 2022 122.8 ‐1440.46
1/30/2023 Corrected August 2022 106.73 ‐1333.73
1/30/2023 Corrected Sept 2022 78.82 ‐1254.91
1/30/2023 Corrected Oct 2022 67.76 ‐1187.15
1/30/2023 Corrected Nov 2022 74.86 ‐1112.29
1/30/2023 Corrected Dec 2022 71.37 ‐1040.92
Net Credit ‐1256.45
Net Credit Calculation
Exhibit 2 Page 2 of 5
2/28/2023 Removed Dec 2022 ‐71.37 ‐1112.29
2/28/2023 Removed Nov 2022 ‐74.86 ‐1187.15
2/28/2023 Removed Oct 2022 ‐67.76 ‐1254.91
2/28/2023 Removed Sept 2022 ‐78.82 ‐1333.73
2/28/2023 Removed August 2022 ‐106.73 ‐1440.46
2/28/2023 Removed July 2022 ‐122.8 ‐1563.26
2/28/2023 Removed June 2022 ‐73.98 ‐1637.24
2/28/2023 Corrected June 2022 117.43 ‐1519.81
2/28/2023 Corrected July 2022 213.31 ‐1306.5
2/28/2023 Corrected August 2022 149.61 ‐1156.89
2/28/2023 Corrected September 2022 159.55 ‐997.34
2/28/2023 Corrected October 2022 209.09 ‐788.25
2/28/2023 Corrected November 2022 507.18 ‐281.07
2/28/2023 Corrected December 2022 494.35 213.28
Net Credit Reversal 1254.20
Net Credit Reversal Calculation
Exhibit 2 Page 3 of 5
4/28/2023 Payment -150 925.73 925.73
4/27/2023 er Read Hi -125 275.53 1075.73 1075.73
3/29/2023 Regular Bil -150 371.07 925.2 925.2
3/15/2023 odwill Pay -450 704.13 704.13
2/28/2023 Meter #:342852591
Account #:75048095 001 3
Read Date Source * Days Meter Read Usage
Invoice
Amount
02/27/23 E 31 30775 4733 $505.54
01/27/23 J 30 26042 4086 $435.31
12/28/22 J 30 21956 4630 $494.35
11/28/22 J 34 17326 4576 $507.18
10/25/22 J 29 12750 1637 $209.09
09/26/22 J 32 11113 1262 $159.55
08/25/22 J 29 9851 1186 $149.61
07/27/22 J 33 8665 1673 $213.31
06/24/22 J 29 6992 976 $117.43
05/26/22 M 0 6016
05/26/22 S 1 6016 45 $4.43
05/25/22 E 29 5971 1315 $129.09
04/26/22 E 29 4656 2324 $234.33
03/28/22 I 31 2332 3452 $352.01
02/25/22 I 28 11629 4164 $426.28
01/28/22 I 30 7465 4316 $442.36
12/29/21 I 33 3149 3829 $392.45
11/26/21 I 32 302230 2160 $225.41
10/25/21 I 28 300070 1682 $221.12
09/27/21 I 32 298388 1147 $145.47
08/26/21 I 30 297241 1323 $171.21
07/27/21 R 32 295918 1490 $195.66
06/25/21 I 30 294428 1019 $127.13
05/26/21 I 30 293409 1335 $169.29
04/26/21 I 31 292074 2522 $260.04
03/26/21 I 29 289552 3186 $335.09
02/25/21 I 29 286366 3612 $383.20
01/27/21 I 30 282754 4481 $481.41
12/28/20 I 34 278273 4767 $513.72
11/24/20 I 32 273506 3532 $406.21
10/23/20 I 29 269974 1346 $177.61
09/24/20 I 30 268628 1058 $134.81
08/25/20 I 29 267570 1222 $159.19
07/27/20 I 33 266348 1384 $183.24
06/24/20 I 29 264964 1011 $127.38
05/26/20 I 32 263953 1102 $130.57
04/24/20 I 29 262851 1844 $178.58
03/26/20 I 28 261007 2169 $214.44
02/27/20 I 28 258838 3181 $326.13
01/30/20 I 31 255657 3129 $320.39
Billing Analysis
Meter Read History
Exhibit 2 Page 4 of 5
Read Date Source * Days Meter Read Usage
Invoice
Amount
12/30/19 I 35 252528 3777 $391.91
11/25/19 I 32 248751 3007 $330.90
10/24/19 I 29 245744 2084 $281.76
09/25/19 I 30 243660 803 $94.83
08/26/19 I 31 242857 1001 $123.71
07/26/19 I 31 241856 690 $78.73
06/25/19 I 32 241166 1073 $134.26
05/24/19 I 29 240093 1457 $181.15
04/25/19 I 29 238636 1709 $163.95
03/27/19 I 28 236927 2962 $302.51
02/27/19 I 29 233965 3634 $378.55
01/29/19 I 32 230331 4207 $442.19
12/28/18 I 31 226124 3814
11/27/18 I 34 222310 3270
10/24/18 I 29 219040 1733
09/25/18 I 31 217307 976
08/24/18 I 32 216331 942
07/26/18 I 29 215389 935
06/25/18 I 31 214454 747
05/24/18 I 32 213707 988
04/25/18 I 29 212719 1747
03/27/18 I 29 210972 2848
02/26/18 I 29 208124 3862
A=Adjustment, C=Customer, E=Remote Read, F=Field Read, I=Itron Read (regular),
M=Manual (regular), O=Office Estimate, P=Postcard, S=System Estimate, J=Out of
Exhibit 2 Page 5 of 5