20140930Joint Petition.pdf

38ffi*.
li I C i: li-/ i:: ;': An rDAcoRP companv
28it; StP 30 Ptl h:07LISA D. NORDSTROM
Lead Counsel i,.t.'ii,j.,, lrt.,,:;. [e-mail] | -l il. i;i=i rii,,...; r. l;i.!i,j...:
September 30,20'14
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. GNR-U-14-01
Exemption from UCRR 311 - Joint Utilities Application and Testimony
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and seven (7)
copies of the Joint Petition for Exemption.
Also enclosed for filing are nine (9) copies each of the Direct Testimonies of Tami
White and Barbara Coughlin. One copy of each of the aforementioned testimonies has
been designated as the "Reporteds Copy." ln addition, a disk containing Word versions
of Ms. White's and Ms. Coughlin's testimonies is enclosed for the Reporter.
lf you have any questions about the enclosed documents, please do not hesitate
to contact me.
Very truly yours,
1221 W. ldaho St. (83702)
PO. Box 70
Boise. lD 83707
8--,a%-*ll*,-
Lisa D. Nordstrom
LDN:evp
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom@ idahopower. co m
Attorney for ldaho Power Company
DANIEL E. SOLANDER (lSB No. 8931)
Rocky Mountain Power
201 South Main Street, Suite 23OO
Salt Lake City, Utah 84111
Telephone: (801 ) 220-4014
Facsimile: (801 ) 220-3299
d a n iel. sola nd e r@pacificorp. com
Attomey for Rocky Mountain Power
IN THE MATTER OF THE JOINT
PETITION OF AVISTA CORPORATION,
IDAHO POWER COMPANY AND
ROCKY MOUNTAIN POWER COMPANY
FOR AN EXEMPTION FROM UTILITY
cusToMER RELATTONS RULE 31 1(4)
and (5).
DAVID J. MEYER (lSB. No. 8317)
Avista Corporation
1411 East Mission Avenue-- MSC-23
P.O. Box 3727
Spokane, Washington 99202
Telephone: [phone]
Facsimile: (509\777 -5468
david. mever@avistacorp. com
Attorney for Avista Corporation
C.-{r-li-
r- -l:J:i--i.
(-1 -
:'. i-''li ':::-'
!..J j,.
I l-:
::l
",i
CASE NO. GNR.U.14.O1
JO!NT PETITION FOR
EXEMPT!ON
l\'?
farl .*-t-E ITIu)fio r?'l;-t; :^a't--*
!-,
O
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW, Avista Corporation ("Avista"), ldaho Power Company ("ldaho
Powef'), and PacifiCorp dba Rocky Mountain Power ("Rocky Mountain Powe/' or
"Pacificorp") (collectively referred to as the "Utilities" or "Petitioners"), in accordance
with Rule of Procedure 053 and Utility Customer Relations Rules ('UCRR") 003 and
009, hereby request that the ldaho Public Utilities Commission ("Commission") issue an
JOINT PETITION FOR EXEMPTION - 1
Order on or before December 31, 2014, exempting the Utilities from the provisions of
UCRR 311 (4) and (5) effective March 1,2015.
UCRR 311(4) requires that immediately preceding termination of service, utility
personnel must attempt to make face-to-face contact with the customer or other
responsible adult on the premises to accept payment on an outstanding bill. UCRR
311(5) requires the utility employee designated to terminate service to notify the
customer in person or with a conspicuously placed notice of the procedure to reconnect
service. Given advances in metering, communication, and electronic payment
technologies, along with increased concern for the safety of employees and the public,
the Petitioners request an exemption from UCRR 311(4) and (5) to allow the Utilities the
option to discontinue collection of payment at the door and to permit the Utilities to use
other forms of customer notice in lieu of mandatory on-site personal or paper notice at
the time of disconnection.
This Joint Petition is based on the following:
I. BACKGROUND
1. The Petitioners comprise three of the largest investor-owned energy
utilities in the state of ldaho. Avista provides electric and natural gas service to
approximately 203,000 customers in northern ldaho. ldaho Power provides electric
service to approximately 500,000 customers in southem Idaho. Rocky Mountain Power
provides electric service to approximately 73,000 customers in southeastern ldaho.
2. Utility Customer Relations Rule 311 (IDAPA 31.21.01.311) governs times
when service may be terminated and outlines opportunities to avoid termination of
service. Subsections (4) and (5) require the utility to attempt to make face-to-face
JOINT PETITION FOR EXEMPTION.2
contact with the customer immediately prior to terminating service to accept payment on
an outstanding bill and/or notify the customer of steps to be taken in order to reconnect
service, to wit:
04. Opportunity to Prevent Termination of Service.
Immediately preceding termination of service, the employee
designated to terminate service shall identify himself or herself
to the customer or other responsible adult upon the premises
and shall announce the purpose of the employee's presence.
This employee shall have in his or her possession the past
due account record of the customer and shall request any
available verification that the outstanding bills are satisfied or
currently in dispute before this Commission. Upon
presentation of evidence that outstanding bills are satisfied
or currently in dispute before this Commission, service shall
not be terminated. The employee shall be authorized to
accept full payment, or, at the discretion of the utility,
partial payment, and in such case shall not terminate
service. Nothing in this rule prevents a utility from
proceeding with termination of service if the customer or
other responsible adult is not on the premises.
05. Notice of Procedure for Reconnecting Service.
The utility employee designated to terminate service shall give
to the customer or leave in a conspicuous location at the
affected service address, a notice showing the time of and
grounds for termination, steps to be taken to secure
reconnection, and the telephone numbers of utility personnel
or other authorized representatives who are available to
a uthorize reconnection.
3. The Utilities use a variety of metering technology ranging from traditional
mechanical meters to Advanced Metering lnfrastructures ('AMl")1. Some fully
automated meters have the capability to remotely connect and disconnect service. The
remote connecUdisconnect technology only applies to meters that are 12Ol24O volt up to
1 Advanced metering systems are comprised of state-of-the-art electronic/digital hardware and
software, which combine interval data measurement with continuously available remote communications.
These systems enable measurement of detailed, time-based information, and frequent collection and
transmittal of such information to various parties. AMI or Advanced Metering lnfrastructure typically refers
to the full measurement and collection system that includes meters at the customer site, communication
networks between the customer and a service provider, such as an electric, gas, or water utility, and data
reception and management systems that make the information available to the service provider.
JOINT PETITION FOR EXEMPTION - 3
200 ampere. The following chart reflects the approximate number and types of meter
technologies currently used for residential and small commercial customers by the
Petitioners in ldaho:
Current Metering Technology Rocky Mtn
Power
Avista ldaho
Power
Non-AMl meters
AMI meters w/ remote connecVdisconnect
AMI meters w/ manual connecUdisconnect
600
181,000
3,740
14,500
494,515
73,355
0
0
4. ln Case No. AVU-E-07-9, Avista requested that the Commission approve
a Remote ReconnecUDisconnect Pilot Program with a limited waiver of portions of
UCRR 311 for the term of the pilot. The pilot was intended to implement a system for
remote disconnections and reconnections without the need for an employee visit to the
affected premises. On July 30, 2008, the Commission approved an 18-month pilot
program subject to specific reporting requirements and subsequently extended the
program indefinitely in Order Nos. 30603 and 31009, respectively.
5. ln 2014, ldaho Power is installing approximately 14,500 meters with
automated electric service connect-disconnect functionality at service points that are
remote, difficult to access, or had multiple connect-disconnect site visits in an 18-month
period. Although these meters have been installed, ldaho Power has not implemented
the remote disconnect functionality pending approval of an exemption from the
provisions of UCRR 311 (4) and (5). ldaho Power estimates this one-time investment of
approximately $1 million will result in a reduction in its annual operating expenses of
approximately $700,000 through reductions in metering labor and transportation costs.
JOINT PETITION FOR EXEMPTION - 4
6. !n the states of Utah, Wyoming, Oregon, and California PacifiCorp has
discontinued2 its practice of accepting any payments at the door at the time of
disconnection of service, and has discontinued making personal contact at the door at
residential sites prior to disconnection of electric service. Door tags are left at all
premises 48 hours before the scheduled disconnection informing customers that their
past due payment must be received by a set date or their service will be disconnected.
Then at the time of the disconnection visit another door hanger is left providing the
affected customers the time of and grounds for termination, steps to be taken to secure
reconnection, and the telephone numbers of utility personnel or other authorized
representatives who are available to authorize reconnection.
II. REQUEST FOR EXEMPTION
7. UCRR 003 and 009 authorize utilities to petition the Commission for an
exemption if "unusual or unreasonable hardships result from the application of any of
these rules." Good €use exists to grant the Petitioners' request for an exemption,
which has the potential to reduce operating costs and increase the safety of utility
employees benefitting customers without sacrificing customer service.
8. Although the Utilities are jointly petitioning this Commission for an
exemption from UCRR 311 (4) and (5), the practice of each utility following this
exemption may vary to meet individual business needs. As described more specifically
in the testimony that accompanies this Joint Petition, each utility believes its request for
an exemption will enable it to reduce operating costs and/or enhance employee safety.
9. Stakeholder Enoaqement. Prior to filing this Joint Petition, one or more of
2 PacifiCorp sought and received regulatory approval in Oregon (Docket No. UM 1631, Order No.
14-049), and Wyoming (Docket No.20000-426-ER-13, Record No. 13432). Nofilings were required in
Utah or California.
JOINT PETITION FOR EXEMPTION - 5
the Utilities discussed this proposal with the Staff of the Idaho Public Utilities
Commission, MRP ldaho, and the Community Action Partnership Association of ldaho
(cAPAr).
III. CUSTOMER IMPACTS
10. Discontinued Pavment and/or Notification at Disconnection. The majority
of the Utilities' customers rarely require a site collection or disconnection visit.
However, if the exemption is granted, the Utilities would have the option to discontinue
collection of payment at the door and to use other forms of customer notice in lieu of
mandatory on-site personal or paper notice at the time of disconnection.
11. Customer Benefits. Granting this Petition will enable the Utilities to be
more efficient, reduce operating costs, and help customers avoid the most expensive
payment option of payment at the door. As described in greater detail in the testimony
that accompanies this Joint Petition, customers will also benefit from greater
predictability in disconnections, timelier reconnection, enhanced privacy and reduced
reconnection fees where meters with remote connecUdisconnect capability have been
installed.
12. Current Customer Notifications. Granting the Utilities' requested
exemption will not harm customers because they receive multiple notices prior to
disconnection. Disconnecting electric service for non-payment is always a utility's last
resort. Petitioners already provide customers with multiple notifications of past due
account balances and potential disconnection of service. Specifically, the Utilities
provide the following before disconnecting service:
JOINT PETITION FOR EXEMPTION - 6
Gurrent Disconnect Notifications
(ucRR 304)
ldaho
Power
Rocky Mtn
Power
lnitial 7-day Past-Due Notice Letter
Final 3-day Past-Due Notice Letter
48-hour door hanger
24-hour in person/telephone notice
Knock/door hanger at disconnection
13. Proposed Customer Notifications. !f the proposed exemption is approved,
the Utilities will provide the following customer amount due and disconnect notifications:
x
x
x
x
x
x
X3
x
x
X
x
X
X
Proposed Amount Due &
Discon nect Notifications
Avista ldaho Rocky MtnPower Power
Monthly bill
lnitial 7-day Past-Due Notice
Final 3-day Past-Due Notice
48-hour door hanger
Z4-hour in person/telephone notice
Knock + door hanger at manual disconnect
Door hanger only at manual disconnect
No on-site notice remote disconnect
It should be noted that having a remote connecUdisconnect capable meter will not
change the service of those customers who declare under UCRR 306 that they are
unable to pay in full for utility service and whose household includes children, elderly, or
infirm persons. Service to these customers will continue to not be terminated during the
months of December through February.
14. Pavment Options. Utilities have expanded payment methods
beyond the traditional use of U.S. Mail and accepting payments at local offices. Over
the past decade technological advances have allowed customers to utilize newer,
more convenient payment methods. As shown below, the Utilities currently offer a
number of no- or low-cost payment methods for customers' convenience. Online and
t Avista attempts seven (7) phone calls 24 hours in advance of disconnection.
JOINT PETITION FOR EXEMPTION - 7
X
X
x
X
X
x
X
X
X
X
X
x
pay-by{elephone payment options allow customers to make payment from their own
residence, any lnternet connection, or through their mobile phones (including smart
phones), and provide almost immediate account updating.
Current Customer Payment Options Avista ldaho Rocky MtnPower Power
Automatic payments
Online Payments
Payments via U.S. Mail
Payments at pay stations
Payments by telephone
Secure drop box
At customer door at time of disconnect
15. ln the Utilities' experience, the vast majority of customers make their
payments via U.S. Mail or through automatic bank debiting. By comparison, the number
of customers who pay at the door at the time of disconnection is quite small and
reflected in the following table:
x
x
X
X
X
X
X
X
X
X
X
X
x
x
x
X
X
x
X
X
ldaho Customers Who Paid
At the Door at Time of Disconnect
in a Calendar Year
ldaho Customers Paid at Door
Total ldaho Customers
Percentage
Avista
2,415
1423224
1.7o/o
ldaho Rocky MtnPower Power
16,563 516
482,6695 73,355
3.4o/o 0.7o/o
While the majority of utility customers choose the no- and low-cost options described
above, other customers have chosen the mosf expensive payment option, paying the
field collector at the door at the time of disconnection, which, for ldaho Power and Rocky
Mountain Power, includes a field visit charge of $20.00 during normal business hours.
Given the number of payment options available, and the small number of payments
o Open residentialaccounts 2013.t Meter count as of the end of 2012.
JOINT PETITION FOR EXEMPTION - 8
collected in the field, allowing Utilities to discontinue collecting payments in the field will
not harm customers.
16. Prior to filing requests with state regulatory agencies to discontinue the
requirement to attempt collection of payment at the door prior to disconnection,
PacifiCorp conducted an informal survey of utilities from members of the National
Association of Credit Managers. PacifiCorp received multiple responses from various
utilities across the United States and Canada. Based on the information gathered from
the responses, more than half of the utilities do not knock on the door prior to
disconnecting service, and nearly 75 percent of the utilities do not collect payment at the
door. A summary of the survey responses is included as Attachment 1 to the Joint
Petition.
IV. CUSTOMER EDUCATION
17. If the exemption request is approved, the Utilities will each conduct a
communications campaign hilored to inform affected customers of changes in its
respective operations. These educational campaigns are described in greater detail in
the testimony that accompanies this Joint Petition. However, the Utilities planned
educational efforts can be summarized as follows:
Proposed Gustomer Education PIan Avista* ldaho
Power*
Call center interactions during Jan-Feb 2015
Billmessages
Automated voice message
lnitial and Final Disconnect Notice
U.S. Mail/billstuffer
Card attached to 48-hour notice and door tags
Rocky Mtn
Power
x
x
X
x
*For those customers with remote connecUdisconnect meters
JOINT PETITION FOR EXEMPTION - 9
18. PacifiCorp has found, through first-hand experience in implementing this
policy change in Utah, Wyoming, California, and Oregon, that customers accept the
concerns the Company has for the safety of field personnel and have been very
understanding of this policy change. To date, PacifiCorp has not received any escalated
customer issues or commission complaints due to the change in business practice in
these states.
19. To allow time for the Utilities to educate customers on the proposed
change in utility practices, the Utilities respectfully request the Commission issue an
Order on this matter no later than December 31, 2014, with the exemption to become
effective coincident with the end of the winter disconnection moratorium on March 1,
2015.
V. MODIFIED PROCEDURE
20. The Utilities believe that a hearing is not necessary to consider the
exemption requested herein and respectfully requests that this Joint Petition be
processed under Modified Procedure; i.e., by written submissions rather than by
hearing. RP 201, ef seg. lf, however, the Commission determines that a technical
hearing is required, the Utilities stand ready to present testimony in support of the Joint
Petition in such hearing. Avista, ldaho Power, and/or Rocky Mountain Power have or
will file testimony describing in greater detail its individual need for the requested
exemption and planned efforts to educate their respective customers regarding the
anticipated operational changes if the Utilities' Joint Petition is approved.
JOINT PETITION FOR EXEMPTION - 1O
VI. COMMUNICATIONS AND SERVICE OF PLEADINGS
21. Communication and service of pleadings with reference to this Joint
Petition should be sent to the following:
David J. Meyer
Avista Corporation
P.O. Box 3727
1411 E. Mission Avenue, MSC-23
Spokane, WA 99220
david. [e-mail]
Lisa D. Nordstrom
Regulatory Dockets
ldaho Power Company
P.O. Box 70
Boise, ldaho 83707
I no rd strom@idahopower. co m
[e-mail]
Daniel E. Solander
Ted Weston
Linda Gervais
Avista Corporation
P.O. Box 3727
141'l E. Mission Avenue, MSC-29
Spokane, WA 99220
Li nd a. G erva i s@avistaco rp. com
TamiWhite
ldaho Power Company
P.O. Box 70
Boise, ldaho 83707
[e-mail]
Barbara Coughlin
PacifiCorp
Rocky Mountain Power Company 825 N.E. Multnomah, Ste 800
201 South Main Street, Suite 2300 Portland, OR97232
Salt Lake City, Utah 84111 [e-mail]
Daniel. [e-mail]
Ted .Weston @ pacificorp. com
VII. REQUEST FOR RELIEF
22. As described in greater detail above and in the testimony that
accompanies this Joint Petition, the Utilities seek an exemption from UCRR 311(4) and
(5) for numerous reasons. lf approved, the requested exemption would permit the
Utilities to utilize technology to reduce operating costs, speed reconnections, and
increase service disconnection predictability. An exemption would also allow the
Utilities flexibility to minimize exposure to confrontations with customers that pose a
threat to the safety of field personnel, customers, and the public.
JOINT PETITION FOR EXEMPTION - 11
23. Although Avista and ldaho Power employees would no longer physically
visit the premises where remote connecUdisconnect technology exists, the Petitioners
will let the customer know of the possible disconnection and/or reconnection by
following its current notification process but without the mandatory requirement to knock
on the customer's door. Customers will ontinue trc receive a variety of notices of
balances owed and pending disconnection. Additionally, customers may pay bills
through numerous no- or low-cost payment methods. Eliminating the ability to pay at the
door removes onlythe most expensive payment option from the list.
24. The Utilities respectfully request that the Commission approve the
requested exemption to Utility Customer Relations Rule 311(4) and (5) no later than
December 31, 2014, to become effective following a customer communication
campaign and coincident with the end of the winter disconnection moratorium on March
1,2015.
Respectfully submitted this 3oth day of September 2014.
EL E.
Attorney for ldaho Power Company
DAVID MEYE
Attorney for A
evv;l e?fr"v"!
tt51t.^.
e,fidt l aYProval
JOINT PETITION FOR EXEMPTION - 12
Attorney for in Power
<l*lt4 t'227m.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 30th day of September 20141 served a true and
correct copy of the JOINT PETITION FOR EXEMPTION upon the following named
parties by the method indicated below, and addressed to the following:
AARP ldaho
Lynn Young
AARP ldaho
3080 E. Gentry Way
Meridian, ldaho 83642
Lee Flinn,
AARP ldaho
3080 E. Gentry Way
Meridian, ldaho 83642
CAPAI
Christina Zamora
CAPAI
3350 West Americana Tenace, # 360
Boise, ldaho 83706
_Hand Delivered
U.S. Mail
Overnight Mail
FAXX Emai! [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mai!
FAXX Email [e-mail]
_Hand Delivered
U.S. Mail
Ovemight Mail
FAX
Email [e-mail]
JOINT PETITION FOR EXEMPTION - 13
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
CASE NO. GNR-U.I 4.01
IDAHO POWER COMPANY
ATTACHMENT 1
6o
oz
c)u
(J
lgo
.2
outL(EE()
o
uac,
=oo
.}
o
:lL)
i,
oz
E'
OJ.trE'
ll,!,c(!
tG.EEc(!
6qJ!(o
P-9
.!p iOy6ElUo>'=(tJG'
>-6col!<
E_c8;
cfoU(Jr!
Lo
E.9!o
E
=JuoCJ
=
co
E
o4
g
oLI
t,
.gfooG
q,)
-o
IE
=
on
(,
(!
OJ(J
oz
o(!U
o
OJ
(oU
q
0,x
(o
_9(J
oz
x x x
oz x x x x x x x x x x x x x x x x x x x x x x
.YTJocY
:oo
=goc,
x x x x -o
=I
OJ
Eo
U
oE'o
Gco
x
5o x x x x I x x x x x x x x x
oz x x x x x x x x x x x x x x x
o
(!
ttl
l!.E'
ou
vU,co]z
.vI
co!z z
(tro(!
0,,z z z 2
oc o
z
Z
(!0!
z
o(!
Vr
tU
,tr
\z ,z z z z
.gc
o
oL)
0o01
oJ
l!
EoEtE
-v.o z
(E
Es!(E
-.Yo z
'tr3o
,9
=
(uc
o(!tJ
!toz z z
OJ
t!
ttlgo-
=z
oo
ta
.9
=
o
oco
OJ
o0l!
.9trIEo.
(o
-vUocv
>t(! 0,,ooI>xc
=lD?EEC,FC'
(it Lor=
=cd=
Juo,
U
l
_c
(E()
oq,,(JU(g
o
oo
Lo3
c
o2
o
x
o;
L
oz
x N
x x x x x x x x x x x x x x x x 00(n
x x
o3
oz
x x C'l
x x x x x oN
x x x x x x x x x x x x x x Ol(\l
2
oc=
(!
.c
I
(!
OJ cou,23
El!.$c..9 z z.
GEIo
l!,r
(JoII(u
d
obaoo
uo
E'
t!El!
z
(tI4(!a z \.2 ,
loqoN
L z
(!ElocoU
dc
OIot z z.z