20141010Decision Memo.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM
TO: COMMISSIONER KJELLANDER
COMMISSIONER REDFORD
COMMISSIONER SMITH
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: KARL KLEIN
DEPUTY ATTORNEY GENERAL
DATE: OCTOBER 10, 2014
SUBJECT: APPLICATION OF AVISTA, IDAHO POWER, AND ROCKY
MOUNTAIN POWER FOR EXEMPTION TO UTILITY
CUSTOMER RELATIONS RULE 311.04 AND .05, CASE NO. GNR-
U-14-01
On September 30, 2014, Avista Corporation, Idaho Power Company, and PacifiCorp
dba Rocky Mountain Power petitioned the Commission for an Order exempting them from
Utility Customer Relations Rule 311.04 and .05. 31.21.01.311.04 and.05. In summary, these
rules require a utility employee to try to make face-to-face contact immediately before
terminating the customer’s service for non-payment to: (1) give the customer a final chance to
avoid termination of service by paying the bill at that time (see UCRR 311.04); or (2) if the
customer does not pay at that time, notify the customer about how the customer can have
service reconnected. The utilities explain that they want the option of discontinuing payment at
the door practices, and of notifying customers in ways besides providing mandatory on-site
personal or paper notice. The utilities seek the exemption so they can use advances in metering,
communication, and electronic payment technologies to reduce operating costs and increase the
safety of utility employees without sacrificing customer service.
The utilities ask that the exemption take effect at the end of the winter disconnection
moratorium on March 1, 2015. In the Application, the utilities ask for the Commission to issue
an Order by December 31, 2014, so the utilities will have time to educate customers on the
change before the effective date occurs. The utilities have since advised Staff that an Order by
early- to mid-January 2015 will also work. The utilities request that the Commission process
the case under Modified Procedure.
DECISION MEMORANDUM 2
STAFF RECOMMENDATION
Staff recommends that the Commission issue a Notice of Application and Notice of
Modified Procedure setting a December 10, 2014 comment deadline, and a December 17, 2014
reply deadline. Staff also recommends that the Commission direct Staff to hold a telephonic,
public workshop for the utilities’ customers and other interested persons. The proposed
workshop would occur before the initial comment deadline. The utilities have advised Staff
that they concur with this type of schedule.
COMMISSION DECISION
Should the Commission issue a Notice of Application and Notice of Modified
Procedure setting a December 10, 2014 comment deadline, and December 17, 2014 reply
deadline and directing Staff to hold a telephonic public workshop?

Karl T. Klein
Karl T. Klein
Deputy Attorney General

M:GNR-U-14-01_kk