20181019Comments.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 l4
IDAHO BAR NO. 10446
IN THE MATTER OF THE APPLICATION OF )
AVISTA CORPORATION FOR AN ORDER )
AUTHORIZING APPROVAL OF PROPOSED )IDAHO SERVICE QUALITY PROGRAM AND )
ASSOCIATED REVISIONS TO ITS ELECTRIC )
AND NATURAL GAS TARIFFS. )
Ii[C I IVED
lil ill tli:T I 9 PH 12: I 6
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. AVU.E-18.10/
AVU-G-I8-06
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Edward Jewell, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 34161 on October 3, 2018, in
Case No. AVU-E-18-10/AVU-G-18-06, submits the following comments.
BACKGROUND
On September 10, 2018, Avista Corporation ("Avista" or "Company") filed an
Application seeking approval of the Company's proposed Service Quality Measures Program
and authorizationto revise its associated electric and natural gas tariffs, Schedule 85 and
Schedule 185 respectively. The Company filed an amended Application on October 5,2018
changing the name of the program to the Idaho Service Quality Program ("ISQ Program").
The Company submitted the proposed ISQ Program as required by Commission Order
No. 33953. Under the proposed ISQ Program, the Company will track and report to the
1STAFF COMMENTS ocToBER 19,2018
Commission annually its performance in meeting thirteen electric measures and nine natural gas
measures. The Company requests Commission approval of its proposed ISQ Program with an
effective date of November 1,2078.
STAFF REVIEW
Staff worked with the Company to develop the proposed Idaho Service Quality Program
Some program provisions vary depending on the type of service provided (gas or electric). The
program for electric service consists of four customer service measures, seven customer
guarantees, and two electric system reliability measures. The gas service program consists of
four customer service measures and five customer guarantees. All costs associated with the
payment of customer service guarantees are paid by Avista shareholders. Staff Attachment A
provides a list of measures and guarantees. Staff recommends approval of the ISQ Program as
proposed by Avista.
Program Design
The Idaho program was designed using the current Washington program as a template.
Though Idaho's proposed program is similar to Washington's, there are a number of differences.
The changes build upon the Company's experience in running the program in Washington since
2015. Modifications were made to clarify the metrics and tailor the program to Idaho.
Significant substantive differences are discussed below.
1. Average Response Times to Emergencies
In Idaho, the Company's average response time to electric system emergencies
will not exceed 65 minutes. In Washington, the average response time should not exceed
80 minutes. For gas system emergencies in Idaho, the Company's average response time
will not exceed 55 minutes. The average response time to gas emergencies is the same in
Washington. As part of discussions with Staff, the Company provided the most recent
average response time to electric and gas emergencies in Idaho; 41 minutes for electric
and 40 minutes for gas. Based on the information provided by the Company, the
proposed response times are not stretch goals for the Company. With that said, Staff
does not oppose the proposed response times as the initial benchmarks. Staff intends to
monitor actual response times and may recommend different benchmarks as more data
becomes available in the future.
2STAFF COMMENTS ocroBER 19,2018
2. Tracking and Reporting Commission Complaints
In Washington, the Company is required to measure and report on the number of
complaints per thousand customers filed with the Washington Utilities and
Transportation Commission. The benchmark used is 0.04 complaints per 1000
customers. After discussions with Staff, the Company did not include this measure in its
Idaho proposed programs. While resolving customer complaints in a timely and effective
manner is a critical function for any utility, Staff believes the metric used in Washington
is not particularly meaningful. In the future, Staff may recommend the addition of one or
more measures regarding complaints.
3. Customer Satisfaction Survey
As part of the electric and gas programs in Washington, the Company's contractor
conducts a customer satisfaction survey that asks customers about the Company's
telephone service (call center) and held services. The Company's measure of satisfaction
is derived using data from the Company's entire service territory (Idaho, Oregon, and
Washington). The Washington program requires the Company to report Washington
specific data, if possible. Based on discussions with Staff, the Company did not include a
requirement for Idaho specific data. Staff believes that in this context, measuring total
company performance is sufficient.
Comparison to Rocky Mountain Power's Program
Rocky Mountain Power (RMP) has maintained a service quality program in Idaho since
2005. The program consists of six customer service standards and seven customer service
guarantees. Staff compared Avista's proposed electric program to RMP's Idaho program. Upon
review, Staff found that Avista's proposed program and RMP's program are very similar. The
proposed customer guarantees align with the guarantees and associated credits that RMP has
with regard to connecting service, maintaining appointments, customer notification, etc.
However, there are some differences between the two programs. The significant differences are
discussed below.
1. Electric System Reliability
RMP has a reliability improvement process in place. Avista's program does not
have a similar provision.
JSTAFF COMMENTS ocToBER 19,2078
2. Restoring Service
RMP has a network performance standard regarding restoring electric service
after outages due to supply loss or damaged distribution equipment. The benchmark is to
restore service to 80% of customers within 3 hours. Avista's program does not have a
similar benchmark.
3. Responding to Commission Complaints
RMP is required to: 1) respondto 95o/o of non-disconnect Commission complaints
within three days; 2) respond to 95o/o of disconnect Commission complaints within 4
working hours; and 3) resolve 95% of informal Commission complaints in 30 days.
There are no similar provisions in Avista's program.
4. Providing Cost Estimates
RMP is required to provide customers or applicants cost estimates for new service
within 15 working days. Avista is required to provide the same documentation to
customers within l0 business days.
5. Resolving Meter Problems
RMP is required to investigate and respond to reported meter problems or conduct
a meter test and report the findings to the customer within l0 business days. Avista is
required to investigate or conduct a meter test and report within 20 business days.
6. Telephone Service
RMP is required to answer at least 80% of customer calls within 30 seconds.
Avista's program requires the Company to answer 80o/o of customer calls within 60
seconds.
Though there are a number of differences, Staff recognizes that each utility's program
should be designed to provide meaningful information and incentives to maintain and improve
customer service and system reliability for the benefit of the utility's customers. In the absence
of past performance problems, Staff believes it is not necessary to add provisions similar to those
identified above for system reliability, restoring service or responding to complaints. Staff
believes the performance measures and guarantees in Avista's proposed Idaho programs are
appropriate for Avista. Additionally, closely aligning the Idaho program with Washington's
program will expedite the launch of its Idaho program. Staff will review Avista's program in the
future and may recommend additional provisions and/or different benchmarks.
STAFF COMMENTS ocToBER 79,20184
STAFF RECOMMENDATION
Staff recommends that the Commission approve Avista's proposed Idaho Service Quality
Program and the associated tariff sheets submitted with its Application.
Respectfully submitted this Y,V day of October 2018.
Deputy General
Technical Staff: Johnathan Farley
Kevin Ke1.t
i:umisc:comments/avue 18. I 0_avug I 8.6ejkkjf comments
5STAFF COMMENTS ocroBER 19,2018
Customer Service Measures
Customer Service Measure {Electric and Gas}
Telephone Service
The Company will measure the level of customer
satisfaction with the Company's telephone (call
center) service with a goal of 90% of those
customers surveyed reporting they were satisfied
or very satisfied with the Company
Customer Service Measure (Electric and Gasl
Field Services
The Company will measure the level of customer
satisfaction with the Company's field service with
a goal of 90% of those customers surveyed
reporting they were satisfied or very satisfied with
the Company
Customer Service lteaSwe lElcqAic and Gas)
Call Center Response
At least 8O% of all customer calls will be answered
within 60 seconds for the calendar year
Customer Service Measure (Electric Only)
Response to Electrical System Emergencies
The Company's average response time to
electrical system emergencies will not exceed 65
minutes for the calendar year
Customer Service Measure (Gas Onlvl
Response to NaturalGas System Emergencies
The Company's average response time to gas
system emergencies will not exceed 55 minutes
for the calendar year
Customer Service Measure (Electric OnlVl
System Average lnterruption Frequency lndex
(sArFr)
The Company will report the frequency of
electrical system interruptions per customer for
the calendar year
Customer Service MeaSUfq Gleclflg Only)
System Average lnterruption Duration lndex
(sAlDl)
The Company will report the duration of electrical
system interruptions per customer for the
calendar year
Attachmcnt A
Case No. AVU-E-18-10/
AVU-c-18-06
Staff Comrnentstq19/18 Page I of 2
Customer Service Guara ntees
Customer Service Guarantee (Electric and Gasl
Keeping Appointments*
The Company will keep mutually agreed upon
appointments for service as scheduled within the
windows of 8am-12pm or 12pm -5pm
Customer Service Guarantee {Electric and Gas}
Providing Cost Estimates
The Company will provide customers and
applicants cost estimates for new service within
10 business days upon receipt of all necessary
information
Customer Service Guarantee (Electric and Gas)
Responding to Bill lnquiries
The Company will investigate and respond to
customer initiated bill inquiries at the time of
initial contacU for those involving further
investigation, the Company will respond within 10
business days
Customer Service Guarantee (Electric and Gas)
Resotving Meter Problems
The Company will investigate customer reported
problems or conduct a meter test and report the
results to the customer within 20 business days
Customer Service Guarantee (Electric and Gas)
Notification of Scheduled lnterruptions*
The Company will provide customers with at least
24 hours notice prior to a scheduled interruption
of service
Customer Service Guarantee {Electric Onlv}
Restoring Service*
The Company will restore service to a customer
within 24 hours after an interruption
Customer Service Guarantee (Electric Onlv)
Turning on Power*
The Company will turn on power the same day the
customer or applicant requests service
eustomer Service Guarantee
Connecting Gas Service*
The Company will connect gas service on the same
day the customer or applicant requests service
* Certain exceptions apply
Attachment A
Case No. AVU-tr-18-10/
AVU-G-18-06
Stalf ComrnentsraA9llS Page 2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS lgth DAY OF OCTOBER 2018,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. AVU-E-I8-10/AVU-G.l8-06, BY MAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWNG:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-MAIL: linda. [e-mail]
avistadockets@,avi stacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3127
E-MAIL: [e-mail]
ARY
CERTIFICATE OF SERVICE