20141210Comments.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF AVISTA CORPORATION, )
IDAHO POWER COMPANY, AND )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER'S PETITION FOR AN EXEMPTION TO)
UTILITY CUSTOMER RELATIONS RULES )
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR-U-14.01
COMMENTS OF THE
COMMISSION STAFF
311(4) AND ($.
The Staff of the Idaho Public Utilities Commission comments as follows on Avista
Corporation, Idaho Power Company, and PacifiCorp dba Rocky Mountain Power's Petition for
an exemption to Utility Customer Relation Rules 311(4) and (5).
BACKGROUND
On September 30, 2014, Avista Corporation, Idaho Power Company, and PacifiCorp
dba Rocky Mountain Power (the "Petitioners") petitioned the Idaho Public Utilities
Commission for an Order exempting them from Utility Customer Relations Rule ("UCRR")
311.04 and .05, IDAPA 31.21.01.311.04 and .05. The Rule states:
311. TIMES WHEN SERVICE MAY BE TERMINATED
OPPORTUNITY TO AVOID TERMINATION OF SERVICE (Rule
311).
04. Opportunity to Prevent Termination of Service. Immediately
preceding termination of service, the employee designated to terminate service
shall identi$ 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
STAFF COMMENTS DECEMBER 10, 2014
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 authorize reconnection.
The Petitioners explain that they seek the exemption so they can opt to stop accepting
payment at the door and providing customers with on-site personal or paper notice. The
Petitioners note that they may petition the Commission for an exemption if "unusual or
unreasonable hardships result from the application of any of these rules." See Petition at 5,
quoting UCRR 003 and 009. They argue that "good cause exists to grant" the requested
exemption because it would enable them to use advances in metering, communication, and
electronic payment technologies to potentially reduce operating costs and increase the safety
of utility employees without sacrificing customer service. .Id
The Petitioners maintain that customers will not be harmed if the exemption is granted
because customers will still receive multiple notices before disconnection. The differences
between the Petitioners' cunent notification practices and their proposed notification practices
under the exemption are summarized in Attachment 1. The Petitioners request that the
proposed exemption from UCRR 311.04 and .05 take effect at the end of the winter
disconnection moratorium on March 1,2075.1
The Commission's Staff held a public informational workshop in this matter on
November 21,2014. Representatives of the Commission Staff, Avista, Idaho Power, Rocky
Mountain Power, Community Action Partnership Association of Idaho, Snake River Alliance,
' The "winter disconnection moratorium" is specified in UCRR 306, IDAPA 3 I .21.01.306. That rule generally
precludes utilities from terminating service in December through February for residential customers who declare
that they cannot fully pay for utility service and whose household includes children, elderly, or infirm persons.
STAFF COMMENTS DECEMBER 10, 2014
United Water Idaho, and Intermountain Gas attended the workshop either in person or
telephonically.
STAFF REVIEW
Although the Petitioners central question to the Commission is whether to grant a rule
exemption, the implications of this case are much broader. Granting a rule exemption to Idaho's
three major electric utilities will signal a fundamental shift in Commission policy with respect to
utilities' customer relations.2 Technological changes now enable utilities and customers to
interact without face-to-face contact. Consumer expectations also have changed, with increasing
demand for 2417 availability of information and services. At the same time, opportunities for
face-to-face communication have changed as local utility offices have closed to the public and
new communication and payment options have become available. Concems have been
expressed regarding utility employee safety and customer privacy. The Petition provides the
Commission with a timely opportunity to explore ways to adapt to all of these changes.
Deployment of Remote Metering Technology
Idaho Power has and Avista plans to have Advanced Metering Infrastructure (AMI) that
would let them remotely disconnect and reconnect customers if the exemption is granted.
Remote connect/disconnect meters have been installed at the premises of residential and non-
residential (primarily small business) customers. Rocky Mountain Power, on the other hand, has
no Idaho meters with remote disconnection and connection capability. Idaho Power's and
Avista's meters are discussed below.
In 2008, the Commission authorized Avista to implement a remote disconnect/reconnect
pilot program for 600 customers and Avista currently has 479 meters with remote
connect/disconnect capability in place.3 In Idaho, Avista uses two types of devices. One device
uses power line carrier and the other devices uses radio frequency paging to activate the switch
that connects and disconnects service. Avista is evaluating the installation of AMI in its
Washington service territory beginning in 2016, with further deployment in Idaho thereafter.
' Avista also provides gas service in ldaho. Only electric meters have remote connect/reconnect capability.
3 See Case No. AVU-E-07-09, Order No. 30603. Avista was authorized to continue the pilot program for an
indefinite time period by Order No. 3 1009.
STAFF COMMENTS DECEMBER 10, 2OI4
Avista's new AMI meters will have built-in remote connect/disconnect capability. If the rule
exemption is granted, Staff assumes Avista will want to use this capability throughout its Idaho
service territory.
By the end of 2014, Idaho Power will have replaced 14,500 AMI meters with new meters
that have remote connect/disconnect capability.4 Idaho Power has not said whether it plans to
install more remote connect/disconnect meters after 2014.
Avista and Idaho Power have certain criteria that they use to decide which customers
should receive remote connect/disconnect meters. Avista decides where to place these meters
based on: a history of multiple disconnect visits or disconnection, employee safety (e.g., threats
posed by customers or animals), and lack of meter access. Idaho Power selects sites based on a
history of multiple disconnect visits or disconnection for non-payment. Both companies have
identihed other possible uses for meter placement, such as remote or difhcult-to-access service
locations.
Meters with remote connect/disconnect capability cost much more than meters without
that capability, and widespread deployment represents a large capital expenditure.s However,
the resulting reduction in labor and transportation costs associated with utility employees making
field visits to disconnect service, leave notices, and collect payment will produce on-going
savings in operating costs6 that ultimately will reduce the upward pressure on rates for all
customers.
Given the higher cost of remote connect/disconnect meters at the present time, Staff
believes it is reasonable for Avista and Idaho Power to strategically place meters at locations that
meet the screening criteria described above. Most customers selected thus far for meter
placement have a history of non-payment, requiring multiple premise visits and disconnection.
a Staff notes that Idaho Power has not sought authorization to install meters with remote connect/disconnect
capability. However, this capability was considered as a potential benefit when the Commission approved
installation of Idaho Power's AMI infrastructure.
t ldaho Power's net investment in its newly-installed remote connect/disconnect meters is $1,244,500. See
Testimony of Company witness Tami White, p. 12, lines 9-12.
u Idaho Power estimates annual cost savings of approximately $700,000. See Joint Petition for Exemption, p. 4.
STAFF COMMENTS DECEMBER IO, 2014
Customer Impact
UCRRs 3l 1.04 and 05 require utilities to knock on customers' doors before
disconnecting service, and to accept payment at the door. Under the rules, if someone is at the
premises, the utilities advise that person that disconnection is imminent and that they may avoid
disconnection by paying at the door or requesting a disconnection delay. The utilities also tell
the person how to restore service if it is disconnected. If no one is home, a written notice with
this information is left on site.
If the Commission grants the Petitioners requested exemption, then the Petitioners will
have the discretion to take or not take the actions required under Rule 31 1. Both Avista and
Idaho Power say they will continue to follow the rule for customers with manual disconnect
meters. However, they would cease the knock-and-accept-payment practices for customers with
meters having remote connect/disconnect capability. On the other hand, although Rocky
Mountain Power only has manual-disconnect meters, it intends to stop knocking and accepting
on-site payment. Rather, if the exemption is granted, Rocky Mountain will leave an
informational door hanger when manual disconnection occurs.
Establishing Different Practices for Customers with Remote Connect/Disconnect Meters
Avista and Idaho Power will knock and accept payment from customers with'oregular"
meters but not from customers with remote connect/disconnect meters. This disparity may result
in some customer confusion, but is an unavoidable consequence of having meters with differing
capabilities.
Staff finds it somewhat contradictory that the employee safety concerns expressed in the
Petition do not apply to customers regardless of meter type. Staff assumes that both Avista and
Idaho Power are confident that they will be able to identify customers that pose a safety risk and
install a remote connect/disconnect meter at those locations. Staff recognizes that this is a time
of transition, and is willing to accept Avista and Idaho Power's decision to only change its
practices with respect to customers who have remote connect/disconnect meters. Staff notes,
however, that in the future, both companies may want to consider adopting uniform procedures.
STAFF COMMENTS DECEMBER IO, 2014
Customer and Company Benefits From Exemption
For Avista and Idaho Power, remote connection and disconnection provides several
benefits:
o Decreases opportunity for on site conflicts between customers and utility;
Increases field-employee safety by reducing the risk of physical harm or robbery;
Increases certainty on when disconnection and reconnection will occur;
Encourages customer's to communicate with the utility call center to make
payment arrangements, make the utility aware of a medical emergency, etc.;
Reduces utilities' operating costs associated with field disconnection visits; and
Allows for quicker reconnection of service after the customer pays or makes
payment arrangements. 7
Rocky Mountain Power, which does not have remote connect/disconnect meters, says not
being required to knock provides several benefits during a manual disconnection visit:
o Decreases opportunity for on site conflicts between customers and utility;
o Increases field-employee safety; and
o Encourages customer's to communicate with the utility call center to make
payment arrangements, make the utility aware of a medical emergency, etc.
On the other hand, if someone is at the premises when the field disconnection visit
occurs, there are benefits to knocking on the door and/or accepting payment:
o Customer avoids disconnection of service;
o Customer is made aware of imminent disconnect; and
o Customer has the opportunity to delay disconnect.
Customers of Avista and Idaho Power who do not have a remote connect/disconnect meter will
continue to have these options.
'Avista reports that service typically was restored in less than l5 minutes.
STAFF COMMENTS DECEMBER 10, 2OI4
Payment at the Door and Other Payment Options
A relatively small percentage of customers respond to a knock on the door by paying to
prevent disconnection. Of the total field disconnect visits made by Avista, Idaho Power and
Rocky Mountain Power in CY 2013, the percentage of customers who paid at the door ranged
from20%o (Avista and ldaho Power) to 14%o (Rocky Mountain Power). Although payment at the
door allows customers to pay at the last possible minute, the customer risks disconnection if he
or she is not on the premises at the right time or is unable to answer the knock at the door when it
comes. Staff agrees with the Petitioners that there are many other payment options available to
customers, each of which provides better assurance that service will not be disconnected. See
Attachment2 for a list of payment options with associated costs. In addition, a field-visit
charges is assessed when a customer pays at the door, making it the most expensive payment
option currently available to customers.
Staff believes that if an exemption is granted, the utilities should undertake an effective
customer-communication campaign, including informing customers about available payment
options, to notify customers in advance that the utilities will no longer accept payment at the
door and allow customers to consider which payment option best fits their needs.
Customer Notification
UCRR 304 requires utilities to notiff customers of a pending disconnection for non-
payment. The content of the notice is prescribed by Rule 305. See Attachment 3 for the
complete text of these two rules.
If the Commission grants the utilities an exemption from UCRR Rules 3l I .04 and .05,
the utilities would continue to provide written and oral (phone) notices to all customers.
However, Avista and Idaho Power customers with remote connect/disconnect meters would not
receive an on-site visit and, consequently, the utilities would not provide these customers with
the opportunity to avoid disconnection by payment at the door or to receive an at-the-door
disconnection notice. Since Rocky Mountain Power does not have remote connect/disconnect
capable meters, on-site visits are necessary. If the exemption is granted, instead of knocking on
customer doors, Rocky Mountain Power would leave an on-site notice informing customers that
I Avista charges a field visit charge of $16.00 and both Idaho Power and Rocky Mountain Power charge $20. The
charge is assessed if payment is made by the customer to avoid disconnection during a utility field visit to
disconnect service.
STAFF COMMENTS DECEMBER 10,2014
service has been disconnected and how they can get service restored. Rocky Mountain Power
also would no longer accept payment at the door.
Rule 304.02 requires utilities to make a diligente attempt to contact a customer by phone
or in person at least twenty-four Q\ hours before the scheduled disconnection. Utility practice
has been to both call and make a site visit, except for the few Avista customers who have a
remote/disconnect meter. More than one phone call attempt may be necessary to make actual
contact with a customer or leave a message. Each utility uses an automatic dialing system to
place calls. The system can tell whether a call is not answered or answered by a person, voice
mail or answering machine. Utilities may not be able to make actual contact with a customer,
but the rule clearly requires utilities to make a serious attempt.
With many more remote connect/disconnect meters in place, coupled with the changes in
utility practices being considered in this case (no site visit, knock on the door, or opportunity to
pay atthe door), making phone contact with customers becomes even more critical.
Unfortunately, Avista is the only utility currently making a "diligent" attempt to contact its
customers by phone prior to disconnection, making up to seven phone call attempts to contact a
customer. Idaho Power makes only one call. Rocky Mountain Power makes only one phone
call, but if the Company is aware that a customer has a life-threatening medical condition, two
phone calls are made. This is unacceptable. Staff recommends that Idaho Power and Rocky
Mountain Power increase the frequency of phone call attempts to no less than three calls made at
different times of the day, with at least one made after 6 p.m. for all customers, not just those
with remote connect/disconnect meters.
Non-Residential Customers
UCRR 304 also applies to small-commercial customers. See UCRR 300-02.
Disconnecting service for these non-residential customers without warning at the time of
disconnection poses risks to persons other than the customer. For instance, if a business
customer's employee operates equipment when disconnection occurs, the resulting sudden power
loss could damage equipment and possibly cause injury. The business's customers and
employees will be affected. Staff notes that the person who receives bills and notices may not be
e "Webster's Ninth New Collegiate Dictionary defines "diligent" as "characterized by steady, €arnest and energetic
application and effort".
STAFF COMMENTS DECEMBER 10, 2014
on the premise when disconnection occurs, and employees may not know that disconnection is
imminent.
Avista currently has eight non-residential customers with remote connect/disconnect
meters, while Idaho Power has 509. Staff recommends that prior to May 1,2015, Avista and
Idaho Power contact non-residential customers with remote connect/disconnect meters in person
or by phone to advise the customer that the Company will no longer be visiting the premises to
disconnect service and will no longer accept payment at the door. Avista and Idaho Power
should also advise customers to take any necessary steps to protect its customers and employees
if disconnection is unavoidable. Staff understands that Rocky Mountain Power, which has no
remote disconnection meters, will still try to make face-to-face contact at the time of
disconnection for non-payment. This additional step will provide an extra safety layer.
Customer Education and Employee Training
Each utility says it will conduct a customer-education campaign to inform only those
customers who will be affected by the change in company practices. A major reason cited by
both Idaho Power and Rocky Mountain Power for not informing all customers is to avoid
confusion for the majority of customers whose bills are not past due or subject to disconnection.
In addition, Rocky Mountain Power states that customers who are not past due on their accounts
do not like receiving notification about collection-related activity, and are not aware that
payment can be made at the door. Further, notification of the change could potentially cause an
increase in incoming phone calls and complaints. Staff thus agrees with the utilities' intent to
notify only those customers who will be impacted by the change.
Rocky Mountain Power provided the most detailed description of its communication
campaign. Staff believes the comprehensive proposal outlined by Rocky Mountain Power
provides a good model for educating employees and customers about the proposed change.
Rocky Mountain Power says it will include a messagel0 on bills with past due account balances,
and on the initial past due reminder notices and final disconnection notices. Further, a 3x5 card
in English and Spanish stating that Rocky Mountain no longer accepts payment at the door will
l0 M.rrug. reads as follows: "Rocky Mountain Power employees no longer accept payments at your home or
business for safety reasons. Several payment options are available. Learn more at rockymountainpower.neVpay or
call l-888-22l-7070."
STAFF COMMENTS DECEMBER 1O,20I4
be stapled to a door hanger at the premises 48-hours before the disconnection date. On the day
of disconnection, any customer answering a door knock will be verbally told of the change and
handed a 3x5 card. If customer contact is not made on the day of disconnection, a second card
will be stapled to a door hanger and left at the residence.l' Cull Center representatives will
inform customers of the new process when contacted by customers who have a past due balance
that are asking about payment arrangements or where to pay. Field metering specialists will
undergo additional training to handle customer questions and concerns.12
After field metering specialists stop knocking on doors to verbally communicate with
customers, Rocky Mountain Power will continue to inform customers of the change. After
implementation, communication will continue through the use of a message on bills with past
due account balances, on the initial past due reminder and final disconnection notices, 3x5 cards,
door hangers, and customer interaction with customer service representatives and field metering
specialists.
Staff believes that training call center and field personnel about the reason for the change
and the resulting benefits will help ensure a smooth transition. Additionally, educating
customers with past due balances who initiate contact with the utility prior to implementation,
will help reduce confusion and the number of inquiries. Staff recommends that the Commission
direct Avista and Idaho Power to implement a customer-education campaign like that proposed
by Rocky Mountain Power, and to submit those plans to the Commission within 14 days after
Commission's order issues. At a minimum, each company must:
o Prior to implementing the change in utility practices, provide field personnel and
customer service representatives with additional training for handling customer
questions and concems;
I I In the fall of 20 I 5, when the door hanger is due for an annual review and reprinting, the door hanger will be
updated to include the message that is contained on the 3x5 card. The 3x5 card inventory will be used until
depleted.
12 A special training session will be held to inform the field metering specialists of the change, why the change is
being made, and their role in the campaign. Metering Managers will periodically accompany specialists to ensure
customers are being informed of the change and to evaluate how receptive customers are to the change.
l0STAFF COMMENTS DECEMBER 10, 2014
o Prior to implementation and for at least one (1) year thereafter, do the following:
Provide information regarding the change in utility practices to customers who
contact the Company about either a past due balance, a payment arrangement,
where to make a payment, or a pending disconnection;
Include a message regarding the change in utility practices in customer bills with
past due account balances, on the initial past due notice and final disconnection
notice; and
Inform customers of the change in utility practices when contacting a customer by
phone prior to disconnection.
Currently, Avista uses a special notice developed for its pilot program to provide
information to customers at the time a remote connecVdisconnect device is installed. When
reviewing complaints regarding Avista's pilot program, Staff found that the notice caused some
customer apprehension about the new meter.
Idaho Power does not intend to advise customers at locations where it has installed
meters with remote connect/disconnect capability of the new meter's functionality or how or
why it will be used in the future. Staff believes it is not necessary to notify a customer about the
connect/disconnect meter or device at the time of installation and recommends that Avista be
given the option to discontinue doing so. Staff believes it is better to focus customer
communication on the change in practices rather than on metering technology.
Field Visits During the Moratorium
Idaho Power intends to make field visits during the winter moratoriuml3 to knock on a
customer's door before disconnecting the customer for non-payment regardless of the meter
type. Avista does not intend to do so for its remote connect/disconnect customers. Avista field
employees will continue to knock only at premises without remote disconnection capability
before disconnecting service for non-payment.
13 During the months of December through February service cannot be terminated for any residential customer who
declares the he or she is unable to pay their utility bill in full and whose household includes children under the age
of eighteen ( I 8), elderly, sixty-two (62) years or older, or the infirm whose physical health or safety would be
seriously impaired with termination of service.
1lSTAFF COMMENTS DECEMBER 10, 2014
Rocky Mountain Power will no longer knock on a customer's door, regardless of the time
of year, for disconnection due to non-payment. In response to Staff Production Request No. 14,
Barbara Coughlin stated:
The Company has requested exemption to UCRR 3l 1 to establish a consistent no-
knock policy for residential customers throughout the year. Implementing a
policy in knocking part of the year would reduce the overall effectiveness of this
initiative. This will allow Company employees to be consistent with their
approach and will give customers confidence in how the Company conducts
business. A change in the process during the year could result in confusion, and
an increase in customer frustration after the Company stops knocking after the
moratorium.
Staff agrees with Rocky Mountain Power and recommends that a consistent no-knock policy be
followed throughout the year for Avista and Idaho Power's customers with remote
connect/reconnect meters, and for all Rocky Mountain Power's customers.
Reconnection Charges
Presently, the amount of a reconnection charge to restore service depends on when the
customer makes the reconnection request. Customers who place a reconnection request outside
of a company's normal business day or business hours are charged a higher reconnect fee.
Attachment 4 describes in greater detail each utility's reconnection charges.
Avista and Idaho Power propose to reduce the reconnection charge for customers with a
remote connecVdisconnect meter. In its pilot program, Avista reduced its reconnect charges by
fifty percent (50%) for affected customers. Requests made during business hours were reduced
to $12; after business hours and weekendlholiday charges were $24. Avista intends to continue
to charge these reduced fees. Idaho Power proposes to reduce its reconnect charge to $13
regardless of when a request for reconnection is received. Rocky Mountain Power does not have
remote connect/reconnect meters; therefore, no proposal was offered for a reduction in the
reconnection charge. Neither Avista nor Idaho Power provided detailed cost justification for
their proposed reduction in reconnection charges.
Staff recommends that Avista charge the same reconnection fee ($12) regardless of when
a customer makes a reconnection request. With that exception, Staff would accept the proposed
reduced reconnection charges at this time. The proposed charges provide cost savings to
affected customers, but the charges are still high enough to encourage customers to avoid
disconnection. After the new procedures have been implemented and the cost of remote
t2STAFF COMMENTS DECEMBER 10, 2OI4
reconnection is better known, Staff will reexamine the appropriateness of the reconnection
charges.
Implementation Date
The utilities ask the Commission to approve the exemption by December 31, 2014, with
the change in practices to be implemented at the end of winter moratorium on March I,201,5.
Customers who declare winter protection are at a higher risk of disconnection for non-payment at
the end of the moratorium period. Even customers who have not received winter protection may
have difficulty paying high winter bills and face the possibility of disconnection. Staff believes
that the utilities should not implement the new process, in which there is no knock and payment
can no longer be made at the doors, until the moratorium ends. Staff recommends a May l,
2015, implementation date to allow additional time for the utilities to educate employees and
customers who will be impacted by the change.
Customer Comments
Customers were given until December 10, 2014 to file comments. As of December 10,
2014, one customer submitted written comments to the Commission. The customer states that
people who live paycheck to paycheck are good at budgeting for pre-paid commodities such as
food and gas, but are often challenged in budgeting for electricity. The customer believes being
able to prepay for usage could potentially prompt customers to monitor usage and conserve
energy. As a result, the need for on-site disconnection visits would decrease, and both utilities
and customers would achieve cost savings.
Although none of the regulated electric utilities in Idaho have a pre-paid metering system
in place, Staff notes that customers can pre-pay for service, make payments at intervals other
than just monthly, or set up a level payment plan. Avista and Idaho Power customers have on-
line access to usage information as well.
STAFF RECOMMENDATIONS
Staff recommends that the Commission:
1. Exempt Avista, Idaho Power and Rocky Mountain Power from UCRR 311.04 and .05;
2. Require each utility to comply with UCRR 304.02 and provide adequate notice before
disconnection by increasing the number of call attempts to three or more;
STAFF COMMENTS t3 DECEMBER IO, 2014
3. Require Avista and Idaho Power to submit a detailed employee training and customer
education plan, similar to that of Rocky Mountain Power, within 14 days of issuance of the
Commission's order;
4. Require Avista and Idaho Power to make contact in person or by phone with non-
residential customers who have remote connect/disconnect meters prior to May l, 2015, to
advise the customers that the Company will no longer be visiting the premises to disconnect
service, will no longer accept payment at the door, and the business should take steps to protect
its customers and employees;
5. Approve reconnection charges of $12 for Avista and $13 for Idaho Power applicable
to locations with remote connect/disconnect meters;
6. Require a consistent no-knock policy be followed throughout the year for both Avista
and ldaho Power's customers with remote connect/reconnect meters, and for all Rocky Mountain
Power's customers; and
7. Authorize Avista to discontinue its practice of notifying customers about the
connect/disconnect meter at the time of installation.
8. Direct Avista, Idaho Power and Rocky Mountain Power to implement the approved
changes to their business practices effective May I ,2015.
Respectfully submitted this lO'L day of December 2014.
lq 1>
Karl T. Klein
Deputy Attorney General
Technical Staff: Beverly Barker
Curtis Thaden
i : umisc/comments/gnru I 4. I kkbabct comments
STAFF COMMENTS t4 DECEMBER IO, 2014
Attachment I
Case No. GNR-U-14-01
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PAYMENT OPTIONS
CHEGKS BY PHONE
/endor Kubra NCO ePavments Bill Matrix Bill Matrix
lransaction Fee S3.50, unless enrolled{1)s2.8s 52.7s S1.95(''
lransaction Cao s10,000 s2s0,000 s500 S600(')
CREDIT AND DEBIT CARDS BY PHONE
y'endor Kubra NCO ePayments Bill Matrix Bill Matrix
fransaction Fee s3.s0 s2.8s s2.7s s1.g5t')
[ransaction Cap s3,OOO(8)s2,soot't s600 SSoot't
AUTHORIZED PAY STATIONS
/endor Multiple Vendors Western Union Western Union CheckFreePav
fransaction Fee Free Free s1.00 S1.oo(o'
fransaction Cap s2.s00 52,500 per cust per day s2,500 No Cap
E-BILLING TYITH FREE PAYMENT OPTION
/endor APS (Auto Pvmt Service)CheckFree IGC RMP
fransaction Fee Free Free Free Free
ONLINE PAYMENTS AT COMPANY WEB SITE
/endor Kubra NCO ePavments tGc RMP
fransaction Fee S3.50, unless enrolled'''s2.8s No fee (checking only)'''No fee (chk or svngs acct)
AUTOMATIG WITHDRAWAL FROM CUSTOMER'S FINANCIAL INSTITUTION
)rogram Name APS (Auto Pvmt Service)Preferred Pay Auto Pay Automatic Payment
fransaction Fee Free Free Free Free
Residential and Residential and Residential and Residential and
Commercial handled same Commercial handled same Commercial handled same 3ommercial handled samel'/
ONE TIME ONLY ONLINE PAYMENTS AT COMPANY WEB SITE
Fee I SE.so, unless enrolled{') | No fee No fee No fee (chk or
OTHER WAYS TO PAY
)ropbox{o'Free Free Free Not an option
Mailed Payments No cost except postage No cost exceDt Dostase No cost exceDt Dostase No cost exceDt oostase
r'r'alk-ln to office Not an option Not an option Not an ootion Not an ootion
(tl Free if enrolled (checking account only). Call Avista to enroll. $10,000 limit for payment with check by phone, S25,O0O limit for payment on-line.
(2) Residential fee only; Commercial fee is 54.95 per transaction up to S1,0oo.(3) lf an ldaho Power Customer Service Representative assists, payment can be as high as S5,OOO.(a) See individual company websites for a list of drop box locations,(t) ss,ooo limit.(6) Pay station fee 51.50 starting in Q1 2015.
(7) Electronic Data lnterchange (EDl) is an additional option for commercial customers.
(8) Capis$3,OOOforastandardtransactionfeeofS3.5O. Anypayment aboveS3,0OO (limitisS25,OOO)issubjectto a 3%fee.
^4- l-Attachment 2
Case No. GNR-U-14-01
StaffComments
12lt0lt4
304. REQUTREMBNTS FOR NOTTCE TO CUSTOMERS BEFORE TERMTNATTON OF
SERVICE (Rule 304).
01. Initial Notice. If the utility intends to terminate service to a customer under Rule 302, the
utility shall send to the customer written notice of termination mailed at least seven (7) calendar
days before the proposed date of termination. This written notice shall contain the information
required by Rule 305.
02. Final Notice. The utility may mail a final written notice to the customer at least three (3)
calendar days, excluding weekends and holidays, before the proposed date of termination.
Regardless of whether the utility elects to mail a wriffen notice, at least twenty-four (24) hours
before the proposed date of termination, the utility shall diligently attempt to contact the customer
affected, either in person or by telephone, to advise the customer of the proposed action and steps
to take to avoid or delay termination. This final notice shall contain the same information required
by Rule 305.
03. Additional Notice. If service is not terminated within twenty-one (21) calendar days after the
proposed termination date as specified in a written notice the utility shall again provide notice
under Subsections 304.01 and304.02 if it still intends to terminate service.
04. Failure to Pay. No additional notice of termination is required if, upon receipt of a
termination notice, the customer:
a. Makes a payment arrangement and subsequently fails to keep that arrangement;
b. Tenders payment with a dishonored check; or
c. Makes an electronic payment drawn on an account with insufficient funds.
305. CONTENTS OF NOTICE OF INTENT TO TERMINATE SERVICE @ute 305).
01. Contents of Notice. The wriffen or oral notice of intent to terminate service required by Rule
304 shall state:
a. The reason(s), citing these rules, why service will be terminated and the proposed date of
termination;
b. Actions the customer may take to avoid termination of service;
c. That a certificate notifliing the utility of a serious illness or medical emergency in the
household may delay termination as prescribed by Rule 308;
d. That an informal or formal complaint concerning termination may be filed with the utility or
the Commission, and that service will not be terminated on the ground relating to the dispute
between the customer and the utility before resolution of the complaint (the Commission's
address and telephone number must be given to the customer); and
e. That the utility is willing to make payment arrangements (this statement must be in bold print
on written notices).
f. That for purposes of termination, partial payments will be applied toward utility service charges
first, unless the customer requests otherwise, and that charges for non-utility services cannot be
used as a basis for termination.
02. Additional Requirements for Gas and Electric Utilities. During the months of November,
December, January and February, oral and written notices provided by gas and electric utilities to
residentialcustomers shall include or be accompanied by an explanation of restrictions on
termination of service and the availability of the Winter Payment Plan described in Rule 306.
Attachment 3
Case No. GNR-U-14-01
Staff Comments
t2ll0l14
Attachment 4
Case No. GNR-U-14-01
Staff Comments
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS lO'H DAY oF DECEMBER 2014,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. GNR-U-I4-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220
E-MAIL: [e-mail]
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
DANIEL E SOLANDER
TED WESTON
ROCKY MOI-INTAIN POWER CO
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84I11
E-MAIL : daniel. solander@pacifi corp.com
ted. weston@pacifi corp. com
datarequest@pacifi corp. com
LINDA GERVAIS
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220
E-MAIL : linda. [e-mail]
TAMI WHITE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
BARBARA COUGHLIN
PACIFICORP
825 NE MULTNOMAH STE 8OO
PORTLAND OR 97232
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE