150220_GNRulewaiver.pdf

Case No. GNR-U-14-01, Order No. 33229
Contact: Gene Fadness [phone], 890-2712
www.puc.idaho.gov

Commission grants utilities’ request for waiver
from rule requiring face-to-face bill collection

BOISE (Feb. 20, 2015) – State regulators have granted a request by Idaho’s three major electric
utilities to be exempted from a requirement that they attempt to make face-to-face contact
with a customer to either collect payment or terminate electric service for nonpayment.

A section of the Idaho Public Utilities Commission’s Customer Relations Rules requires that
utilities try to meet customers at their homes or businesses to give them a final chance to pay a
past-due bill to avoid disconnection and also tell customers how they can later have their
service restored if they do not pay. However, Avista Utilities, Idaho Power Company and Rocky
Mountain Power say advances in metering, communication and electronic payments negate the
need for face-to-face visits and bill collection. Automated meters give utilities the ability to
disconnect and re-connect customers from a remote location. Re-connection is quicker with
automated metering and customers avoid the extra charge that is imposed – up to $20 – when
an on-site visit is required. The utilities say waiver from the rule will reduce operating costs for
customers and increase the safety of utility employees without sacrificing customer service.

Customers already receive multiple notices prior to disconnection, including mailed past-due
notices seven days and again three days before disconnection. Twenty-four hours before
disconnection, customers receive a telephonic notice or an in-person visit.
Avista and Idaho Power’s waiver rule applies to those customers with remote metering
capability. But even with the waiver, Avista, which operates in northern Idaho, and Idaho
Power, in southern Idaho, are still required to knock and leave a door hanger at businesses and
residences that are not equipped for remote disconnection. Rocky Mountain Power, which
operates in eastern Idaho, does not have the type of meters that allow for remote disconnect
capability, so it must leave a door hangar notifying customers of upcoming manual disconnect.
The waiver does exempt all three utilities from being required to make face-to-face contact and
collect payments, per each company’s implementation plan.
Idaho Power has installed 14,500 meters with automated connect-disconnect ability. The utility
claims that its one-time investment of $1 million in automated connect and disconnect meters
will reduce annual operating expenses by about $700,000. Avista has done the same in its
north Idaho territory with 600 meters. PacifiCorp, parent company of Rocky Mountain Power,
has already discontinued taking payments at the door in Utah, Wyoming, Oregon and California
and reports no escalated customer service issues or increased complaints.

The commission attached conditions to the waiver, including the following:
 Utilities must “diligently” attempt to notify customers by phone or in person at least 24
hours before disconnection. The commission declined to quantify “diligent” with a
precise number of attempts, but commended Avista for its practice of trying to call
customers up to seven times.
 Utilities must educate their personnel and customers about the changes that will occur
under the exemption. Idaho Power and Avista must submit a revised plan within 30 days
that details how they will notify customers and train employees. The commission
accepted Rocky Mountain Power’s plan.
 Idaho Power and Avista must reduce their reconnection charges to reflect the lower
cost to utilities to reconnect without having to dispatch field personnel.
 Utilities’ must notify a third-party designated by the customer at least one week before
an impending disconnection.

The Community Action Partnership Association of Idaho (CAPAI) said the commission should
deny the utilities’ petition, but, if granted, should do only under limited conditions. CAPAI
claimed the utilities were not able to meet the rules’ requirement to prove that the rules create
an “unreasonable hardship” and that the change discriminates against low-income customers.
CAPAI argued that utilities did not present evidence of physical harm to employees who were
trying to collect overdue payments. However, PacifiCorp (Rocky Mountain Power’s parent
company) reported 13 physical incidents in its six-state territory during 2012-13 including
employees being spit upon, one employee’s leg slammed in a company truck door, one
involved in a pit bull attack, one customer attempting to engage an employee in a fistfight, one
customer turning a hose on an employee and eight employees involved with customers
brandishing firearms. In Idaho, the company reports nine sites where “aggressive customer
behavior” was documented. All utilities report aggressive dogs are sometimes used to deter
utility personnel.
Waiver from the rule, the commission said, will reduce safety risks to both utility employees
and customers and allow customers to realize the benefits of modern metering technologies.
The current rule, for example, forces Avista and Idaho Power customers to unnecessarily incur
labor and transportation costs, expense that will be avoided through remote disconnection and
reconnection. Idaho Power, for example, estimates to save $700,000 each year. Customers will
also avoid the field visit charge, $16 for Avista customers and $20 for Idaho Power and Rocky
Mountain customers.
CAPAI’s claim that a waiver from the rule discriminates against low-income customers is not
borne out by an Idaho Power statistic that only 8% of its 12,743 remote connect/disconnect
customers are installed at locations where customers were receiving low-income heating
assistance.
The commission did grant CAPAI requests to monitor the exemption’s effects on low-income
persons as part of their monthly report to the commission and that a third-party designee is
contacted at least a week prior to disconnection.
All three utilities claim they have expanded payment methods beyond traditional U.S. mail or
payment at local offices. Online and payment-by-telephone options allow customers to make
payments from their homes, from any Internet connection or through their mobile phones. The
vast majority of customers now make their payments by mail or by online banking methods.
Commission staff noted that few customers pay at the door to avoid disconnection, with only
20% of Avista and Idaho Power customers and 14% of Rocky Mountain Power customers paying
at the door during a disconnection visit in 2013.
The commission’s order, along with other documents related to this case, is available on the
commission’s Web site at www.puc.idaho.gov. Click on “File Room” at the top of the page, then
on “Multi-Utility Cases” under “Cases” and scroll down to Case No. GNR-U-14-01.
Interested parties may petition for reconsideration by no later than March 10, 2015. Petitions
for reconsideration must set forth specifically why the petitioner contends that the order is
unreasonable, unlawful or erroneous. Petitions should include a statement of the nature and
quantity of evidence the petitioner will offer if reconsideration is granted.
Petitions can be delivered to the commission at 472 W. Washington St. in Boise, mailed to P.O.
Box 83720, Boise, ID, 83720-0074, or faxed to 208-334-3762.

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