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HomeMy WebLinkAbout20141010Gervais Direct .pdfAvista Corp. 141 1 East Mission P.O. Box3727 Spokane. Washington 99220-0500 Telephone 509.489'0500 TollFree 800-727-9170 October 9,2014 Jean D. Jewell, Secretary Idaho Public Utilities Commission P O Box 83720 Boise, lD 83720-0074 Dear Ms. Jewell: Re: Case No. GNR-U-14-01 - Exemption from UCRR 3ll - Joint Utilities Application and Testimony Dear Ms. Jewell: Enclosed for filing with the Commission is an original and seven (7) copies of Avista Corporation, doing business as Avista Utilities (hereinafter Avista or Company), at l4ll East Mission Avenue, Spokane, Washington, Direct Testimony in support of the above referenced Case No. Additional copies have been provided to the service list. Please direct any questions on this matter to myself at (509) 495-4975. Sincerely, 4"*,&"'-; Manager, Regulatory Policy Avista Utilities linda. servais@avistacom.com 509-495-4975 Attachements C r\t-{€-e =EB N aT c)oI. c, mn l-rv,..- -L-AF' # irl 67 trr L-'/ (!) = (r,(-' t(,z. DAVID J. MEYER AFA-tt rr t'tt..'t*1.-\'..-lll i:-V- VICE PRESIDENT AND CHIEF COUNSEL FOR REGULAToRY & GovERNMENTAL AFFATRs ZU|E0CT l0 PH 2:39 AVISTA CORPORATION P.O. BOX 3727 ].41]. EAST MISSION AVENUE SPOKANE, WASHINGTON 99220-3727 TELEPHONE: (509) 495-431,5 FACSIMILE : (s09 ) 49s- 8851- DAVTD . MEYER@AVISTACORP . COM BEFORE THE IDNIO PT'BIJIC UTIIJTTTES COMMISSION rN THE IvIATTER OF THE iIOINT PETITION OF AVISTA CORPORATION, IDAHO POWER COMPAIIY, AI{D ROCKY MOT'NTATN POWER COMPAI{Y FOR AN EXEMPTION FROM UTILITY CUSTOMER RELATIONS RULE 3]-1 (4) AI{D (5) . cAsE NO. GNR-U-14-01 DTRECT TESTIMONY OF LINDA M. GERVAIS FOR AVISTA CORPORATION (ELECTRIC AI{D NATURAL GAS) I 2 aJ 4 5 6 7 8 9 l0 1l t2 13 t4 15 t6 t7 l8 t9 20 2t 22 I. IMTRODUCTION o. addrees. PIeaEe st,ate your narne, employer and business A. My name is Linda M. Gervais and I am employed as the Manager of Regulatory Policy for Avista Corporatj-on (Company or Avista), at 1,41,1, East Mission Avenue, Spokane, Washington. A. Would you please briefly describe your educational background and profesgional oqterience? A. Yes. I earned a Bachelor of Science degree in Business Administration from Kennedy Western University. I joined the Company in ,June of L993. Over the past 2L years I have served in a number of different roIes, including contract construction,and demand-side- management. I have spent approximately 1-2 years in the Rates Department with j.nvolvement in Commission rulemak j-Dgs , compliance, j-ntegrated resource planning, Iow-income issues and other aspects of state and federal policy. In 2007, L became the Manager of Regulatory Policy. a. What is the purpose of your teatimony in this proceeding? Gervais, Di 1 Avista Corporation 4 5 6 7 8 9 10 11 t2 13 T4 l5 t6 t7 l8 t9 20 2l 22 23 24 25 26 27 28 29 30 31 32 JJ 34 35 36 37 38 39 A. Avista 1s among the utilities filing a joint petition for an exemption from IDAPA Utility Customer Relations Rules (UCR) 31L (4) and (5). Specifically, UCR 3L1 (4) and (5) state: 04. Opportunity to Prevent Termination of Service. Immediately preceding terminat,ion of service, the employee designated to terminate service sha11 identify himself or herself to the customer or other responsible adult upon the premises and shaI1 announce the purpose of the employee's presence. This employee sha1l have in his or her possession the past due account record of the customer and shal1 request any availableverificatj-on that the outstanding bi1Is are satisfied or currently in dispute before this Commission. Upon presentation of evj-dence that outstanding bi1ls are satisfied or currently in dispute before this Commission, service shal1 not be terminated. The employee sha11 be authorized to accept fu11 payment, or, ?t the discretion of the utility, partial payment, and in such case sha11 not termj-nate service. Nothing in this rule prevents a utility from proceeding with terminati-on 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 terminateservice shal1 give to the customer or leave j-n a conspicuous location at the affected service address, a notj-ce showing the time of and grounds f or termJ-nat j-on, steps to be taken to securereconnection, and the telephone numbers of utility personnel or other authorizedrepresentatives who are available to authorize reconnection. My testimony will describe the Company's experience with a limited waiver of UCR 311 and explain why it should Gervais, Di 2 Avista Corporation I 2 J 4 5 6 7 8 9 10 11 t2 t3 t4 l5 t6 t7 l8 l9 20 2l 22 23 be allowed to perform remote disconnection/reconnection in its Idaho servlce territory. O. Are you sponsoring any exhibits in this proceeding? A. Yes. I am sponsoring Exhibit No. 1-, Schedule Nos. 1 and 2. Schedule No. l- includes the Company's Petition for limited wai-ver and Schedule No. 2 includes the Company's Updated Summary Report, both filed in Case No. AVU-E-07-09. rr. REQUEST FOR EXEMPTTON a. Didn't Avista request a limited waiver of UCR 311 in another Caee? A. Yes. Avista originally filed its application seeking approval to implement a one-year pilot program for remote reconnects and disconnects with the Idaho Public Utilities Commission (IPUC) on August 30, 2007 in Case No. AVU-E-07-09. The Company also requested a limited waiver of Utility Customer Relations Rule 311-.04 and 311.05 (IDAPA 3L.2:-..0L.31-l-.04 and .05) related to the f inal customer notification prior to disconnection. On September 19, 2007, the Commission issued a Notice of Application and Notice of Modified Procedure, establishing a deadline for the submission of comments Gervaj-s, Di 3 Avista Corporation 1 2 3 4 5 6 7 8 9 l0 ll t2 l3 t4 15 T6 t7 l8 l9 20 2t and/or protests. Commission Staff filed comments supporting the Company's Application. AARP Idaho filed comments opposing the Company's Application. Likewise, the Community Action Partnership Assocj-ation of Idaho (CAPAI) filed comments opposing approval of the Company's Application as well as the Commission's use of Modified Procedure. Additionally, CAPAf requested that the Commission convene a technical hearing and order a workshop regarding the Company's proposal. On December 4, 2007, the Commj-ssj-on deferred judgment on the Company ApplicaEion and ordered workshops to further refine and develop details of the pilot program.l On March 27, 2008, a public workshop was held at the Commission' s office in Boise during which the parties reached a tentative agreement on most of the issues. Representatives from Avista, Commission Staff, CAPAI and AARP attended the workshop. At the conclusion of the workshop, participants agreed to continue working informally on the issues of customer notifj-cation and identification of the data to be collected during the course of the pilot. Gervais, Di 4 Avista Corporation t Order No. 30471 I 2 3 4 5 6 7 8 9 l0 t1 t2 l3 t4 l5 t6 t7 18 19 20 2t 22 23 24 25 26 27 28 29 On April 28,2008, Avista submj-tted its Revised Application pursuant to Order No. 30471,. The Revised Application incorporated certain changes to the pilot program agreed to during the March 2008 public workshop as well as subsequent correspondence between the parties. On July 30, 2OO8, the Commission approved Avista's Application to implement the 18-month pilot program and ordered that, upon completion of the pilot program, the Company shall prepare rra detailed report with the Commission documenting its findings." (Order No. 30603 at l_0. ) On ,January 28, 20L0, Avista submitted a letter to the Commission requesting an extension of its limited waiver of IDAPA 31-.21,. 01.31-1. 04 and 311. 05 (Utility Customer Relations Rules granted for the purpose of implementing its Remote Disconnect and Reconnect Program. ) In Commission Order No. 3L009 dated February L7, 201-0, the Commj-ssion stated that it had: "...reviewed Avista' s current f iling and Staf f ' s recommendation of the filing. Accordingly, the Commission approves Avista's reguest to continueits Remote Disconnect and Reconnect Pilot Program, including the previously approved waiver of UCR Rules 3L1.04 and 3l-1.05. A 503 reduction in reconnect fees is authorized until the Commission has had an adequate opportunity to revj-ew the Company's forthcoming report regarding the results of the pilot program, and to assess Gervais, Di 5 Avista Corporation I 2 J 4 5 6 7 8 9 l0 l1 t2 13 t4 15 16 t7 18 t9 20 2t 22 23 24 25 26 its effectiveness. In reaching this finding, the Commission notes that it has not received any objection or negative feedback regarding the Company's reguest for a brief continuation of the terms of the pilot program. " The Company filed its Summary Report on May 4, 2010 and an Updated Summary Report on February 11 , 201-3. III. AVISTA PILOT PROGRAM o. Program. Please describe the terms of Avista's Pilot A. As provided earlier, the Company filed an application seeking approval to implement a one-year pilot program reguesting waiver of the Utility Customer Relations Rule 311.04 and 311-.05. After discussions with the Parties2, customers selected for the pilot included customers with 200 amp services that met at least one of the following criteria: o Premises where employee safety is a concern, i.e., customers who have threatened to harm Avista employees or property, premises where there is a danger f rom anj-ma1s, or premises that have an obstructed access to the meter; o Customers who have prevlously had two field collection visits or disconnection in the preceding 12 months; and Gervais, Di 6 Avista Corporation 2 Commission Staff, AARP and CAPAf. I 2 J 4 5 6 7 8 9 l0 1l t2 l3 t4 l5 l6 t7 l8 l9 20 2t 22 23 24 o Excluded will be CARES customers, customers subject to t,he moratorium, who are on a winter payment plan, who have provided medical certificates, or who have made satisfactory payment. arrangements. The Company's authorized reconnection fee was set at $24 during regular business hours and $48 after hours. For purposes of the pilot, the Company reduced the charge to 50? of the normal reconnect fees. O. What are aome of the benefitg identified from thig piJ.ot? A. Safety of Avista's employees continues to be a significant benefit of the pilot program. Avista has adopted a practice in both Idaho and Washington whereby a service switch is installed on any customer that is deemed to be a potential safety risk to our employees. We continue to see an increase in the number of customers that pose a real threat to our employees. Safety is a concern for the meter readers and service people tasked with disconnecting power or acting as impromptu bill collectors. Aggressive dogs are often used to deter utility personnel from doing their jobs. Over the years, Avista servicemen have encountered situations where angry Gervais, Di 7 Avista Corporation 1 2 J 4 5 6 7 8 9 l0 11 t2 13 t4 15 l6 t7 18 t9 20 2t 22 homeowners threaten to release their dogs to attack them. Others have threatened physical harm, sometimes with a gun in hand. Concern for safety is especially import,ant when you consider these *bi11 collectors" are unarmed and can be carrying collections on their route. Due to the numerous safety concerns, two-person crews are typically used, as well as in some cases, a police escort. IV. TECHNOIJOGY O. Does the Company have the ability to remotely disconnect gervice in Idaho using an Advanced Metering InfraEtructure (AlfI) ? A. No. However, both the Two-way Automatic Communicatj-ons System (TWACS@) and Paging co11ar devices continue to be utilized in Company's Idaho service area in accordance with the qualifying rules of the original pilot program. Both of these devices can be remotely disconnected and reconnected. A. DoeE the Company have plans technology in ldaho? to inetall AMI A. Yes, the Company is currently evaluating the installation of AIvII in lts Washi-ngton servi-ce territory Gervais, Di I Avista Corporatj-on 1 2 J 4 5 6 7 8 9 l0 ll t2 l3 t4 l5 t6 t7 l8 19 20 2t 22 23 beginning in 201-5. Once complete, w€ will install AIqf in Idaho. V. UTII,ITY PRACTICE OF DISCONNECTIONS O. Can you please explain the Company's position on whether or not the utility practice of disconnectionE will change with an exemption to the rule, as well aE with remote capabilities. Yes. It is always the Company's desire to keep customers connected. The need to dj-sconnect non-paying cusEomers or to avoid a potential safety risk is nothing new for ut,ilities, but the tools of today a11ow for more efficient handling of these arrears or unique situations. Due to large service areas and long feeders in the Company's service territories, significant "windshield time" is required to manually connect/disconnect these customers. When doing field collections in Idaho, the Company currently collects a payment from customers at the door less than 15? of the time. O. What practice would change with the waiver of the rule? A. Specifically,after the meter has been installed, an Avista employee would no longer be required to physically visit the premises to disconnect or Gervais, Di 9 Avista Corporation 1 2 ) 4 5 6 7 8 9 10 1l t2 l3 t4 l5 l6 t7 18 t9 20 reconnect the meter. However, the Company will 1et the customer know of the possible disconnection and/or reconnection by following its current notification process3, but without otherwise sending an employee to the premises. After the meter installatj-on, a special notice that was developed with the assistance of the Commission Staff, is provided with the mailed past due notice and the final notice reminding customers they have a remote device. a. What optione doeE the cugtomer have to satisfy payment if an employee does not come to the door prior to disconnection? A. In addition to the traditional methods of paying by check or money order through the United States maiI, pay stations, or drop boxes, or paying by cash at pay stations, the Company also offers customers the options of online payment through the Company's website and pay-by- telephone. Some of these methods, such as online payment and pay-by-telephone, provide almost immediate account 3 the bill is mailed and due within L5 calendar days, after which the Company aIlows a 3-day grace period for payments to post. A Past Due Notice is mailed after the grace period ends, dated 7 calendar daysIater. The Final Notice is mailed 3 business days before the past due notice expires. The Interactive Voice Response System (M) then callsthe customer on the day the notice expires. Gervais, Di 10 Avista Corporation I 2 3 updating and the customer can make the payrnent without leaving their home. VI. CONCI,USION a. Pleage summarize the reason the Company is requeating a waiver to RuIe 311 (4) and (5) ? A. As stated earlier in my Eestimony, it is always the Company's desire to keep customers connected. The need to disconnect non-paying customers or to avoid a potential safety risk is nothing new for utilities, but the tools of today allow for more efficient handling of these arrears or unique situatj-ons. O. Does this conclude testimony? your pre-filed direct A. Yes. Gervais, Di 11 4 5 6 7 8 9 l0 l1 t2 l3 t4 Avista Corporation drlfi cory, 1{tlifrslrl'rssi'lt P0EqSrZ, spstrneilstrirgto[ SurE t ? Telephsro tts{SS:m TsilFree 8UH2f'$m AprilzSj 2008 'IegnIgwell, Secretary Id:&o Publis Utilities Commission W. qlZ Washington Street Boise; ID 83720 Re: AVU-E-07-09 - Avista Corporation's Revised Application to Implernent A Pilot Program for Remote Dsconnects and Reconnects DearMs. Jewell: Enclosed for filing with &e Commission is an original and 7 copies of ths Company's revised application requesting approval of a '"Rernote DisconnectlReconnect Pilot Program" and a request that the Cornmission provide the Company with a limited waiver of IDAPA 31.21.01 (31 1 .03) and (31 I .04) [Utility Customer Relation Rules] for the term of the pilot. The Company requests that this filing be processed under the Commission's Modified Procedure rules. Please direct any questions on this matter to myself at (509) 4954975 or Greg Paulsen at (509) 495-4976. Sincerely, &*d*;#-wr;** Linda Gervias Manager, Regulatory Policy Avista Corporation linda- gervai s@avistacorp.com Enclosures Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 1 of 19 DAVID J. MEYER VICE PRESIDENT AND C}IMF COUNSEL FOR REGULATORY AND GOVERNMENTAL AFFAIRS AVISTA COPJORATTON P.O. BOX 3727 I4I 1 EAST MISSION AVENUE SPOKA}.{E, 1VASHINGTON 99220.37 27 TELEPHONE: (509)4954316 FACSMILE: (509)49s*8851 BEFORE THE IDAHO PUBLIC UTILITIES COMIVNSSION IN THE MATTER Or THE APPLTCATION ) CASE NO. AW-E-07-09 or AVISTA CORPORATTON FOR THE ) AUTHORITY TO IMPLEMENT A PILOT ) PROCRAI\{ FOR REMOTE DISCONNECTS ) A}ID RECONNECTS ) REVISED APPTICATION OF AVISTA CORPORATION Exhibit No. Case No. GNR-U-14-0 Schedule 1, Page 2 of 19 J 4 5 6 7 I 9 l0 ll 12 I3 14 l5 I6 t7 t8 l9 20 2t 22 23 24 )5 ?6 27 28 I. INTRODUCTION Avista Corporation, doing business as Avista Utitities (hereinafter Avista or Company), at l4l I East Mission Avotue, Spokane, Washington, respectfully rsquests that the Commission approve a pilol program for "Remote Disconnect/Reconnect" and requests that the Commission issue in its order providing the Company with a limited waiver of IDAPA 3 1 .21 ,01 (3 I I .03) and (3 I 1 .04) [Utility Customer Relation Rules] for the term of the pilot. The revised proposed pilot is intended to implement a system for rsmote disconnection and reconnections, rvithout the need for an ernployee visit to the affected premises. The Company requests ihat this ftling be proccssed under the Commission's Modified Procedure rules. Communications in reference to this Application should be addressed to: David J. Meyer, Esq. Vice President and Chief Counsel for Regulatory and Govemmental Affairs Avista Corporation P.O. Box 3727 l4i I E. Mission Avenue, MSC-13 Spokane, WA 99720-3727 Phone: (509) 4954316 Fax: (509) 495-8851 Revised Application of Avista Corporation Case No. AVU-E-07-09 KellyNorwood Vice President - State and Federal Regulation Avista Corporation P.O. Box 3727 14ll E. MissionAvenue, MSC-7 Spokane, WA 99220-37?7 Phone: (509) 495-4267 Fax: (509) 495-8856 Page I Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 3 of 19 II. BACKGROUNI} Avista originally filed its application seeking approval to impleanent a ooe-year pilot program for remote reconnects and disconnects with the Idaho Public Utilities Commission (IPUC) (hereinafter the Comrnissiou or Staff) on August 30, 2007. The Company also requested a limited waiver of IDAPA 31.21.01 (311.03) and (311.04) [Util$ Customer Relation Rulesl for the term of the pilot. The Commission authorized the use of Modified I 2 3 4 5 6 7 I 9 l0 1l 12 13 l4 15 16 17 l8 l9 20 ?i 22 ?1 Procedure and established a comment deadline. Commission Staff filed comments supporting the Company's application. The American Association of Retired People (AARP) and Community Action Partrrership Association of Idaho (CAPAD (referred to as the "Parties") filed comments opposing the Company's application. In Order No" 30471, the Commission ordered the Parties to conduct workshops to further rEfine the details of the progftun. ThE Parties attempted to resolve any remaining issues through two different conference calls, and a formal workshop that rvas held March ?7,2008in Boise, at which all Parties were represented. The Company and Parties were able to resolve all rsrnaining issues through this process. Among the issues resolved were: program criteria; ths distinction between urban and rwal customers; form of customer special notice; an evaluation plan; and cost recovery. The purpose of this Revised Application is to reflect ths conssnsus reached on the remaining issues with respect of the pilot program. IU. SCOPE OF PROPOSED PILOT PROGRAM This pilot program will include the installation of approximately 600 remote disconnect collars using Power Line Carrier (PLC) and wireless pa$ng as the eommunication protocol. PLC is a technology that allows communications auross power lines to a disconnecUreconnect collar at the electric meter. This capability allows remote disabling/enabling of flre electric service from Avista's office. The wireless paging allows communication to a collar at the electic meter which allows remote disabling/enabling of the slectric servics. The specifications for disconnect collars and the wireless pa$ng collar are Revised Application of Avista Corporation Case No. AW-E-07-09 PageZ Exhibit No. 'l Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 4 of '19 10 l1 t2 r3 t4 l5 16 t7 t8 l9 7A 2l z? included as Attachment A. The Company proposes that the pilot's duration be eighteen months from the time the last collar is installed.r lncreased ernployee safety is an advantage of the program. Dangerous pets, treacherous driving conditions, obstructed and unsafe meter &ccess and potentially confrontational customer contacts can be greatly reduced by utilizing this technology. In the Company's original application, there was a distinction made between'trfban" and "rural" installations. After further discussion with the Parties, the Company agresd to eliminate this distinction tbr purposes of the pilot. Customers selected for this pilot will include customers with 200 amp services that meet at least one of the following criteria: o Premises where ernployee safety is a conceffi, i.g, customers who have threatened to harm Avista employees or property, premises where there is a danger from animals, or prernises that have an obstructed access to the meter; r Customers who 'have previously had two field collection visits or disconnection in the preceding 12 months; and o Excluded will be CARES customers, customers subject to the moratorium, who are on a winter payment plan; who have provided medical certificates, or who have made satisfactory payment errangsmefits. 'Ihe Company proposed in its original application to keep the current authorized reconnection fce at $24 during regular business hours and $48 after hows. Certain Parties, however, believed that Avista would see a savings in cost by not having a field representative on I By *ay of further backgr:ound, in 2005, thc Company bcgan a four-ycar projsct Io convsrt alt natural gus and clcctric meters to AMR in the State of ldaho. Nearly 180,000 natural gas and electric metcrs havs been automatcd. Over 139,000 natural gas and elcctric metsrs wcre automatsd using radio'basod terhnology artd 40,000 were automflted utilizing power line carrier (PLC) technology. Electric meierc on the PLC system are read rutomatically, and do not require a meter reader or nrobile unit to eotlect the nlstqr rcading. The Company bslievcs this technology could provide the opportunity for operational savings by reducing or eliminating both regulu atd after-hours *ervice calls tiue to reconnecting or disconnecting senice at the metcr. ln the casc of an after-hour$ reconncct. thc scrvicc can be remotely activated within minutcs a.s opposul to hours in the more remote areasr thus providing faster response to cu$tomers and eliminatiog the need to send a scrlice peson to the premisc on overtime. Revised Applieation of Avista Corporation Case No. AVU-E-07-09 Page 3 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 5 of 19 I 2 3 4 5 6 7 8 9 l0 11 12 t3 t4 l5 l6 17 l8 r9 2A 2t 22 z) site and asked that these costs be passed to the customer. Even though Avista continues to believe that the customsrs w-ho cause the Company to incur additional expense should bear those costs, for purposes of the pilot, the Company has agreed to reduse the c,harge to 50% of the normal reconnsct fees. This will result in fees for participating customcrs of $12 during normal business hours and $24 if reconnection is performed after hours. The reasonable capital costs of this pilot would be included in Avista's normal cost of operation and the Company will propose that the costs be spread emong all rate classes in its next general rate case. The avoided costs achieved would be returned to customers, as well, through the rate making process. tV. CURRENT NOTITICATION PROCESS Avista's current process to disconnect and reconnect an account requires that an ernployee be dispatched to drive to the customer's premises, disconnect the service and leave a disconnect notice in a conspicuous lseation. A *'disconnect" consists of the removal of the eleckic meter, installation of insulated boots, and reinstallation of the meter. If there is a safety risk to the ernployee, the disconnection will occur at the nearest upskeam device2 from the electris meter. Once the account is brought back into good standingi or has been opened by a new customer, an employee is dispatchsd to drive back to the site to restore the service. Avista continually looks for ways to reduce costs and provide a safe work environment for eruployees. It is believed that this project will reduce employee field trips to repeated delinquent accounts, enhance employee safety (avoidance of ernployee risks associated with, e.g., dangerous animals, etc.), allow quicker restoration of service, and ultimately encour&ge timely customor paynent, thereby reducing customer accourt balanses. 2 An upstre*m device includss equipment such as a fune or serviqe wire *rat can be operted or cut 10 intcrrupt the circuit and $op thc flow of cncrgy. Revised Application of Avista Corporation Case No. AVU-E-07-09 Page 4 Exhibit No. 'l Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 6 of 19 4{ 6 1 8I r0 11 t2 l3 t4 15 l6 17 l8 i9 2A 71 2? 23 Avista currently conducts disconnecUreconnect services in compliance with ldaho Utility Customer Relation Rule IDAPA 31.21.01 (300 through 313), which include the following: IDAPA 31.21.01 (311.03) * Opportuuify to Prevent Terminstion of Service - Immediately preceding termination of service, the ernployee designated to terminate serviee shall identifo himself or hersElf to the customs or other responsible adult upon the premises and shall arnounoe the purpose of the employee's presenco. This employee shall have in his or her possession the past due eccount record of the customer and shall request any available verification that the outstanding biils are satisfied or currently in dispute before this Commission. Upon presentation of evidence that outstanding bills are satisfied or surrently in dispute before this Comrnission, 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 ser/ice. Nothing in this rule prevo:rts a utility &om proceeding with trrmination of service if the customer or other responsible adult is not on the premises at the time of termination. IDAPA 31.21.01 (31 1.04) - Notice of Procedure for Reeonnection Service - The ernployee of the utility designated to terminate serrice shall give to the customsr or leave in a conspicuous losatiou at the servise address affected a notice showiug the time of and grounds for termination, steps to be takea to secure reconnection, and the telephone numbers of utility personnel or other authorized representatives who are available to authorize reconnection. V. PROPOSED NOTTFICATION PROCESS In order for this pilot to be effective and achieve the desired results, Avista requests a waiver of rule IDAPA 3-1.21.01 (311.03) and (311.04) for those accounts included in the pilot program. Specifically, at the time the disconnect device has been installed, an Avista employee would make an attempt to personally oontast the customer and a special notice will be left with the customer (if personal contact is made) or on the prernises (if customer is not home). The Company has worked tuith the parties to develop the special notice as provided as Attachment B. The next time the customer is eligible for disconnection, the Company would not be required to physically visit the prernises to disconnect or reconnect the meter and would not 24 25 26 27 28 29 30 3l 32 JJ Revised Application of Avista Corporation Case No. AW-E-07-09 Page 5 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 7 of 19 34 I z 3 t+ 5 6 1 8 9 l0 1l 12 13 14 t5 l6 t7 18 l9 20 2l 22 be required to give the custorner (or leave in a conspicuous location at the service address affected) a notice showing the time of, and grounds for, terminatiou. However, the Company will let the customer know of the disconnection or reconnection by following its current notification proces$3, but without otherwise sending an employee to the prernises. AII meters with the device attached will be flagged as part of a pilot program and entered into the Company's customer service system. The Company will continue to be otherwise compliant with rule IDAPA 3l .21 .01 (31 1.03) and (31 L04) with all customers not included in the pilot who have been disconnected or reconnected, VI. MEASUREMEN? AND EVALUATION Measurement & evaluation is integral to defining benefits of a pilot program and identifuing areas for improveinent or modification. Avista and the parties have worked together to define what should be included in the Company's report at the oonclusion of the pilot program. The Company's evaluation plan will include, but is not limited to, the following: All data collected will be for the duration of the pilot program. Individual customer data for progf,am participarits will be available upon request. Evaluation criteria may require some manual collection of data and will be collected and evaluated as completely as possible. 5 The biU is mailed and due within I5 calendar days, aftcr which the Company allows a 3-day grace period for payments to post. A Past Due Notice is mailed after thc grace period ends, dated 7 calendar days later. The Final Noticc is mailed 3 businc.ss days bcfore thc past due notice expires. The Interactivc Voice Response System (IVR) then calls the customer on the day the notice expires. Revised Application of Avista Corporation Case No. AVU-E-07-09 Page 6 Exhibit No. 'l Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 8 of 19 I 1 J 4 5 6 n 8 9 10ll t? r3 t4 l5 r6 t7 18 t9 zCI 2l 72 23 24)\ 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 4l 42 43 44 45 46 47 48 For program p*rticipants: The total number of customers selected for the pilot by rate schedule, the reason for selectiort, and the month of installation of disconnection device; The total number of disconnect devices installed by type (TWACS or Nighthawk) and by month; The total number of remote disconnections by month, rate schedule, and reason for disconnection (e.g., non:payment of bill or failure to pay deposit); The total number of customers by rate schedule who were remotely disconnected during the pilot period: Never Once Twice Three or more times The total number of customers who were remotely disconnected and received a LIHEAP benefit one or more times during the pilot period; The totsl number of instances by rate schedule where a customer was not reconnected within 24 hours following a remote discorrnection; By device type, the total numbEr of instances where the disconnection device failed to: a. Disconnect a customer following remote activation b. Reconnect a customer following remote activation By rate schedule, the minimum, rnaximum and average length of time from rernote disconnection to rernote reconnection; By rate schedulo, in instances where thE customer was disconnected for non-payment, the minimum, maximum and average lenglh of time from when the mstomer paid or made satisfactory arrangements and remoie reconnection; The total number and nature of inquiries, complaints, or comments (negative or positive) received from eustomers who had a disconnestion device installed; Detailed analysis of costs, cost savings, and non-monetary benefits of pilot program; and Any evidence that installation of the disconnection device influenced customer behavior (positive or negative). a. b. c. d. Revised Application of Avista Corporation Case No. AVU-E-07-09 Page 7 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page I of 19 I 2 3 4 5 6 7I 9 l0 TI tz l3 l4 l5 l6 t7 l8 l9 20 2t 22 23 24 25 26 a1lrl For non-particlp*uts The average number of custorners by rate schedule during pilot period; The total number of disconnections by month, rate schedule, and reason for disconnection (e.g;, non-payment of bill or failure to pay deposit); The total number of customers by rate schedule who were disconnected during the pilot period: a. Onceb. Twice c. Three or more times The total number of customers who were disconnected and received a LIHEAP beirefit one or more times during the pilot period; The total numbsr of instances byrate schedule where a customsr was not reconnected within ?4 hours following disconnection; By rate schedule, the minimum, maximum and average length of time from disconnectiou to reconnection; and By rate schedulq in instancss where the customer was disconnected for non-paymenf the minimum, maximum and average lengtb of time from when the customer paid or made satisfactory arrangernents artd reconnection. 28 Revised Application of Avista Corporation Case No. AVU-E-07-09 Page 8 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 10 of 19 I 2 J 4 5 6 7 8 9 l0 ll L2 l3 l4 r5 l6 t7 l8 l9 20 2l Yrr. REQLTEST rOR APPROVAL Avista respectftlly requests approval of the "Remote Disconnect/Reconnect Pilot Program" and requests that the Commission provide the Company with a limited waiver of IDAPA 31.21.01 (311.03) and (311.04) lutilrty Customer Relation Rules] for the term of the pilot. WHEREFORE Applicant respectfully requests the Commission issue its Order authorizing the proposed pilot program, with this revised application being processed under Modifi od Proc.edure. DATED at Spokane, Washington, this 25th day of April, 2008. AVISTA CORPORATION Vice President and Chief Cotxsel for Regulatory and Governmental Affairs Revised Application of Avista Corporation Case No. AW-E-07-09 Page 9 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 11 of19 STATE OF WASHTNGTON ) $s CountyofSpokane ) David J. Meyer, being duly sworrl on oath dcposos and says: That he is the Vice President and Chief Counsel for Regulatory and Governmental Affairs of Avista Corporation; That he has read the foregoing Application, knols the coutents thereof a*d belierres the safire to be tue. (;- David J. Meyer Subscribed and swom to before me this 25th day of April, 2008. Notary Publis in and for the State Washington, residing in Spokane Application of Avista Corporation Case No. AVU-E-07-09 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 12 of 19 ATTACHMEI\TTA Exhibit No. 1 Case No. GNR-U-1+01 L. Gervais, AvBta Schedule 1 , Page 13 of 'l 9 A,?wtsrfr A,Wvtsrfr UtilitiesUtilities 1-888-427-3403 wttrlil.avi sta uti I itieo.com Your alectric service was disconnected today. Your residence or business was selected to b* part of a pilot program approved bythe ldaho Public Utilities Commission. A device was installed on your electric meter to allow Avista to disconnect or reconnect your service remotely. ln the future, AvJs& wlll not need lE send a field rcprwntative to your sdruice lscatian to diecanneet or reconnact service. You will not have the opportunig to pay a field rEpresentative at your door to avoid disconnection. No notice willbe left for you at the seruice location following disconnection. Avista willcontinue to send notices and attempt to coniact you by telephone in advance whenever it intende to dismnnect service. lt is very important that you call Avista to make sure all your contact information, including telephone number, is conect You may reach Avista at the number below. 1-888-427-3403 wrru.avlcta utllitiee.com $EE REVEBSE SII}E FOH IM PORTAHT INFOBIiilATIOT.I 1-888.497-3403 www-avista u$l itlee.com Your electric service was disconnected today. Your residen@ or business was selected to be pail of a pilot program approved bythe ldaho Public l.Jtilities Commissicn. A device was installed on your electric met€r to allow Avista to disconnect or reconnect your service remotely. ln the future, Aviera- will not narld to sand a fleld rsprese.nlative ta your service lacation ta disconnacf or raconnecf qerulcr,, You will not have the opporhlnfiy to pay a field representative at your door to avoid disconnestion, No notice will be left for you at the service localion following disaonnection. Avista willeontinue to send notices and attempt to contact you by telephone in advane whenever it intends to dismnnect service. lt is very important that you call Avista to make sure all your contact infonnation, including telephone number, is conect. You may reach Avista at the number below. 1€89-427-3403 unrnt avistautilities,com $EE REVERSE SIIIE FB*uitrro. r ]M PORTANT I N FOHIIATNBN- 1 4-O 1 L. Gervais, Avista Schedule 1, Page 14 of 19 AWwrcTfi Utilities The ramote disconnect/reconnect dovics installed on your metprwillallowAvista to reconnect service more quicldy. When the reason for the disconnection {such as non- payment of a past due bill) has been remedied, you will need ts mntact Avista to request reconnection. Your service willthen be reconnEcted immediately by means of an electronic signal; you will not need to wait for a field representative to be sent to your service location. lf you have any questions or experience problems at any point in the remnnection prscess, please csntact Avista at the number below, 24 hours a day, 7 days a week. lrnportant: lf your service is shut-otf, you willbe required to pay the amount past due, a daposit, and a reconnect fae. A medical certiticate notifying Avista of a serious illness or medical emergency may delay termination, We are willing to make mutually satisfactory payment arangemenls. An informal or formal cornplaint conceming this action may be filed $,ih fB ldaho Public UrifBes Commission - P.O. Box 8$720, [krise, lD 8372C 0074 (208) 334-0369 ortoll free (800) 432-0EGg" 1-88H27-3403 rnrw.avisiautil itiee"Fm 8EE REVEBSE SIBE FOR IIIPORTANT I!{FOH*TATIOH A'Wvtsrr Utilities The remote dlseonnecUre@nnecl device installEd on your mEter will allowAvi$ta to reconnect seMce more quickly. When the roason for the disconneclion (sucfr as non- payment of a past due bill) has been remedied, you will need to conhc{ Avista to request reconnection. Your service will then be reconnected immediately by means of an electrcnic signal;you willnot need to wait for a field representative to be sent to your seruie location" lf you have any questions or experience problems at any point in the reconnection processr please contact Avista at the number below, 24 hours a day, 7 days a week. lmportant: lf your servica is shut-off, you will be rEquired Io pay the amount past due, a deposit, and a reoonnact fes. A medicalcertificate notitying Avista of a serious illness or medical emergency may delay termination. llYe arc wllling to make mutually satisfactory payment arrangenrsnts. An informal orformal complaint conceming this ac{ion may bB filed with the ldatp Public Utilities Commission - P.O. Box 83720. Bobe, lD 83720- 0074 (208) Stll-0369 or tollfree (800) {}2#69. ,-936.427*3403 rrnmn avlstautllities.cCIm sEE HEvEHsE se8'E#ltjli.:;1 IrirPoHrANilNmBJg*f,m?#13 ATTACHMENTB Exhibit No. 1 Case No. GNR-U-1+01 L. Gervais, AvBta Schedule 1, Page 16 of 19 .%i,"' ""r, 'i :t',r I +j NIEHTHAWK TAXE RE'iIOTE COilTAC,L cEo700 ltlhole House DisconnecUReconngct a a ) I o a Paging Format Oper$*g Ternperafure: POCSAG 512, 1200, 2400 BaM -200 c b +700c Featrs$ AvailaUe in UHF, VHFamd 900 MHz Freryerx*rs Low profile, 2.75 inch oftet dng or ringi{ess sodce 4 and 5 Jar Model Mufti.Leve] seqrrity dee Optional Horfleo$ner re$st button LOWCOST- Conholfundi,om am bcated on a sirEle c*wil board de$gned ftn mass prpdudion Long lerm avaihtdlity ard short produdhn bad limes Speuificathns Ftequendeo:UHF, VHF,9OOMhZ Elsrfical$BiEhingCapaciS: 200Amps'fhe CEOT& is a cmplets in@mM wirelss remote whole horce dismnrpd pdage urples wih net€r dapter, 200 amp switdt, and Nbhhawk stbol boatd. lnsdlaliqt is fighfdrq fa$ requiring mly tre rcrpual d tta exislirg meta, pltg ln of &e CEO700, ad replacemont of he neter inb he CE0700. Upon insbllat*m the Uility command oenter can then page the switch 'ofl' or'off. li is literalty frat simple. An optional hornodvnor Ieset surttdt is avaihbb trat would require the honrcormer b pu$ an easyto seebufton on ffre rneterhou$ng bfu hs swit* wuJH actualty dose. Ihe CEOT@ can be pogrammed b uott on any public orpiwle paging rrctrffork. Ttre devices can be adhated by any totdt tone phone 0r I mmputer nrodetn using our mer-fiiendly softvara. The CEO700's ideal fur seassral use buildings, student apart- ment oornplercs, drronic n0 pays, ad remotesafety dlsconned, lnsta$alion is fast requiring only fte renuel of the odsting meta, plug in of he C80700 and replaernent of fre metr inb he CEO700 (the remoE contd fundiom are adive immedhtely upon irchllation). Ttre slim, bur profils, inbgrabd circuit boad frb snugly betreen tre meter hck and the $0 Atttp disconned srr'ritdr allor$ng for use of a lov proffie UL adapter. PagingAirtirne The CEO700 can be shipped to pt comdetely pregogmammed to pagirq si1rnals in pur mglm. Pagrtts can be provided ttmqh Nighfur,vk Systen6, lnc. atvery hlv nonhly rabs. ff yar arnently have pagirq service prefuonce, the CE0700 can be prognammed b accomnrcdab your piltate or public paging service in all UHF, VHF, and 900 MHzfiequencies, AboutfiteCompany Non in its second decad€, Nhhffffie Sysbms, lnc., desbns and marufadurcs easy to use ?ltq ard Plat' pa$ng ptduds tnt rBmobly conUd vitfualty any elecffical device, fom any locatbn. Ourproduch are dxfined b be easily inshlled and operated. MGilTHAVIIK SYSTEITiS, lNC. 10715 GULTDAIE, SUIIE 200 SAN AHTONIO, fX 78216 TEL 210.341.il8l I tA)( 210.3{I.20t I TOtt-rRIt A7.764.4484 UIWW.NIGIIIHAWI$YSIEMS.COrII OTCBB; NIHX Exhibir No. 1 Case No, GNR-U-14-01 scneo,reLiSi#X'i#'I3 Tha Disconnect Switch hterbase (DsD from TwAcs. ofFrs a stand-alone. trto, urry, addressable disconnect ssdtch whicn prwides tamper detection capabilitie and paves tfie wry for prepay servtces TIE Dst comblnes the funcflonalityof a 2@Amp lstched relayvulth the convenience of the superlor TwAcs trrv+way power line communications $Etem. shn*alone Deslgn Tlp stand-ahre desigr offers a plt8:in. setfrontained solution, rdtich requires no additional crnnections and b lndepenthnt of fls metert)0e or rechnologr. Allfiatb required is inslaDatbn on aTwAcsenabl€d dbdbution q,stem. Whole HousG Dlscoilnect No ,!ur can prordeforrernde whob house disconnect and l"c$nect wittt dre Dsl. Tfie DSI utiltres a depe,idable and rellable ?00Amp htched rclay and comblrps it wtfr tie poilertuI TwAcS syEterr Tltis comt ination permits tle cUStOnErseNice neprEsBntadv€ (csR)s disconnect and reconnect indlvidually metered residential or small commercial, singl+ phase 2ooAmp services remotely from the utllltyoffica The DSI dsconnects tfie electric s€rylce to UE home while loavjrEfie meter powercd for ;nonltorlng or communicAtion purpo$es. E€motFConirol--From tl$lity offfce NolorEgiS itnecxsary to create a vvork order and dispatfi a rEter technldan to reflxlve or"boof a meteli The csR orTwAcs slrem operator can simplyissue $e command for an lmrpdiate or s$eduled discrnnection. Reconrcqtion is equally es}. Eadl DSI is unlryelyddrsable based on a secure,factory ass8ned identiur 6r t& h$rest integrity. RemoE communication ls pwided via teTtt Acs system which linl(s the utilltycon$ol cen&rard fie metersite. Rapid coffnrutiql of servlce dismnnect or reconnect can be obtalned wi&in 20 seconds of @mm8nd initiation. Uriversal Desitn TtE DSI'S universalclesien Rts nEst residential applications" Compatibility ii as$ured with 200Amp4-iaw form 2s and s-iaw fom 12s/25s residential sofiksts. The DSI ururks witl meters both dd and mltil; elBctomechanicsl and elec'lronic. The Dsl consists of an interbse&llar, a 20OAmp ta$hed relayandaTWACS communlcaflon module wi$r an elecsonic sy'/itch controller. The collar has bur (or five) jaws frat accept the blades from the meter on tha topside and four (or five) blades ftat insert iilo a standaro meter soc*et on the botom side. tltlity and consumer Beneftts U$lhles utllizing fiis product will have at $eir disposal apolrerful revenue $llection tool for prcblem accoJnts. mwellasSteabilityb enhance customer service by providirg a corvenlence br seasonsl and rental customers. Adtlitionally, tris improws utility e{ficlency and personnel safety by allowlm connecB and disconnects to be perfurned from the convenhnce of the utiliry office. The twcFway addressable Dg also paveg th€ way fcr future prspfry metering implenentadons. LnparDe&c{on Tamper Detecilon is provided through the use of a periodic two-way communications checK load side dstector, and diagnostic reglster. Tweway Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 1, Page 18of19 (DSt) 8lhut,s t,le consufiEf b make sure treir hone is readyfor conrEctlon. Flrst a sorftumre command ishsuedbarm the svi&h follorred by thecln$fiter manualfi depressingthe'on' t ush-guilon. LowProfib Ttc towProfteebsign enhances the universal ft 6nd minimiees any drangeof appearance to the consumers seryice. Petl( Overlbsd I '- : ',1 TqE Argtr$e Riseiretdc* ,: .:'', gsepa8q Aid Cleafanca ;Srfiilti endilranca SbrxlaflB oomotlancs EMIXH slggepuU&ly AC uneqlrge Elecflcel Fastllnsism Ef,4URR €missiofts irehr Foms TWACS@ Disconnect Switch Interbase cornmunlcdons confi rm f ufie ffil ims not been remowd. l-oad slde detection verifim Prqper operatbn and wlllirdicm a Umffi condidon. TfiedireUc register gerentes an alarm ffag that is sent btle utiliU office lf tamper ls detectgr. suttrfi $tEtl8 l^ED and con$ect PmltAuftoll The DSl orfhrs two option$ to dose the swftdr: a) a direct softvars commaM frorn Dcsl,s master stason softl|rarg or b) a twlstep process that IrB u$ 0r &B oecqmact swihl, Mw 'otr ,4fit,,'tr,l8 twt ob d&f,,ut6{,/N{Ete[f flry 0a s&Fd e 6rah sr*r, ru$rlr&r]$, i edlat&tsl letftL ffi{o l,t&gBr6lrr,, f66tre, OJduserbrB{pmnBdsroroompfiarl@ #&arsuarrtsii& WthWNr*Ari6, *wffiaL#te DCg, A rhlrfianrrlrssrn ras oflfffin d &/ve taniffif,, ati wfr t tB b d* t 96dttEDM.ueclstitrl frtctuaselkfirrB d illG Pfrtd ?opArypq-: :'to@Arps-ps uL 108J1999 10.om AmnS FeruL s08,:J999 12,000ArrF pErAlr$ c1el -19J5 6 Cld€s 8t 7000 Anps per en6l crz.r,1995 _ : UL 508. 1999 ald t^tr414 rsoo'rotts at 6gt tu t mliute per t L:soB ' tL50s-1999 SO,mMedranhalOptrat@srm FullLoad Fltgl9al Tl{ols AttISlCt2.l Testib26 ANSI/IEEE G62.41-1991 por ANSI ClZl- 2001 Test nlo17 IEC 6{00 Pf4 per AN$ CrZ.l-2001 Tbst No25 cFR 47 Part15. Subparts*S8 perAilS c12.1-2001 Tst filoz7 dat8'zm 25. 12q zss # ,:4Sg,to. Stetue fu-ffi Schedule 1, Page 19 of 19 /lffrrusrtt Avista Corp. 1411 East Mission P.O. Box3727 Spokane. Washington 99220-0500 Telephone 509-489-0500 TollFree 800-727-9170 Update to the Idaho Public Utilities Commission Staff on Avista Utilities Remote Reconn ect/Disconnect Pilot Case No. AVU-E-07-09 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 2, Page 1 of 10 Background In compliance with Idaho Public Utilities Commission Order No. 30603, Avista Utilities provided a summary study on its Remote Reconnect/Disconnect Pilot Program. The 18 month pilot began July 30, 2008 and completed January 29,2010. The original report was delivered to the Commission at the end of April 2010. The Company, at the request of Commission Staff, provides an update on Avista's current program in Idaho as well as an assessment of the current state of the industry and other information that is pertinent to the pilot. Since the end of the pilot project in early 2010, there have been several developments in the industry related to the service switch. Widespread deployment of AMI (Advance Metering Infrastructure) has occurred, and in a majority of deployments an integrated service switch has been installed in the meter. Companies and their customers are seeing the benefits of this aspect of the technology. Companies are able to reduce truck rolls and the associated costs and provide better customer service by restoring the customer's power in a timelier manner. In 2011, Avista deployed approximately 13,500 AMI electric meters and 5,000 natural gas meters as part of the Smart Grid Demonstration Project (SGDP) in Pullman, Washington. These meters are equipped with an integrated service switch. Avista began full production use of the service switch on November 15, 201I and have had very good results to date. Introduction It is always the Company's desire to keep customers connected. The need to disconnect non- paying customers or to avoid a potential safety risk is nothing new for utilities, but the tools of today allow for more efficient handling of these arrears or unique situations. The Company believes that the remote relay switch offers a significant opportunity to positively impact utility operations and add value to customer relationships. Due to large service areas and long feeders in Avista's service territories, significant windshield time is required to manually connect/disconnect customers. Today's technology allows real-time Update on Avista Utilities Remote Reconnect/Disconnect Summary Report February 8,2073 Page 2 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 2, Page 2 ol 10 remote disconnection and reconnection of meters, providing significant cost savings and reducing the utility's exposure to potentially dangerous situations. Specifically, after the collar has been installed, an Avista employee would no longer be required to physically visit the premises to disconnect or reconnect the meter. However, the Company will let the customer know of the possible disconnection and/or reconnection by following its current notification process', but without otherwise sending an employee to the premises. After the meter installation, a special notice that was developed with the assistance of the Commission Staff is provided to the customer or left on the front door educating customers about the remote device. Also, a special notice is provided with the mailed past due notice and the final notice reminding customers they have a remote device. Both the Two-way Automatic Communications System (TWACS@) and Paging collar devices continue to be utilized in Company's ldaho service area per the qualifying rules of the original pilot program. In regards to the technology deployed in Idaho, the manufacturer of the paging type collar (Nighthawk) has transitioned to integrating cell phone technology into the collar. Further, they have worked with Itron to embed a switch with cell phone technology into an Itron meter. The benefit of cell phone technology is that it provides two-way communication to the collar/meter. This is a significant improvement in the technology as the one-way nature of the paging type collar did not provide any confirmation back to dispatchers regarding the state of the switch. Lack of confirmation caused Avista to incorporate a process to call the customer after initiating a command to restore power to confirm that the operation was successful. The new technology provides confirmation (success or failure) regarding the status of the switch so that the appropriate decision regarding whether or not to dispatch field personnel can be made. The new technology also provides indication of whether or not the device has appropriate coverage when field personnel are installing a device. The Company has tested 100 of the new cell phone based collars in its Washington service area and has been pleased with the overall results of the program. ' The bill is mailed and due within 15 calendar days, after which the Company allows a 3-day grace period for payments to post. A Past Due Notice is mailed after the grace period ends, dated 7 calendar days later. The Final Notice is mailed 3 business days before the past due notice expires. The Interactive Voice Response System (IVR) then calls the customer on the day the notice expires. Update on Avista Utilities Remote Reconnect/Disconnect Summary Report February 8,20L3 Page 3 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 2, Page 3 of 10 As the industry continues to evolve, the security associated with these systems continues to be enhanced. This holds true for the evolution from paging to cell phone based technology. The new cell phone based collars have enhanced security. To date, Avista has had no incidents related to security surrounding any of the systems associated with its Remote Connect/Di sconnect program. Safety of Avista's employees continues to be a significant benefit of this program. Avista has adopted a practice in both Idaho and Washington that is supported by management at all levels whereby a service switch is installed on any customer that is deemed to be a potential safety risk to our employees. We continue to see an increase in the number of customers that pose a real threat to our employees. Safety is no laughing matter for the meter readers and service people tasked with disconnecting power or acting as impromptu bill collectors. Aggressive dogs are often used to deter utility personnel from doing their jobs. This past year, one of Avista's servicemen encountered a situation where an angry homeowner threatened to release their dog to specifically attack him. Others have been threatened physical harm, sometimes with a gun in hand. Concern for safety is especially important when you consider these "bill collectors" are unarmed and can be carrying collections on their route. Due to the numerous safety concerns, two-person crews are typically used, as well as police escort. It should also be noted that the remote reconnect/disconnect program may also alleviate the emotional aspects of shut offs for our servicemen. Customers that are still participating in the program continue to see the benefits of having their power restored faster, as the data shows further in this report, than those that rely on traditional visits from field personnel. Employees continue to request expansion of the program in Idaho. Obviously the remote operation of reconnects/disconnects saves significant "windshield time" for servicemen which translates into real dollars. As noted above, for safety, manual disconnect crews can spend considerable time traveling to and from the residence in question. In addition, a two-person crew provides for at least one witness in case of any customer disputes. This accrues not only additional labor costs but vehicle fuel and maintenance costs. For rural communities, service calls to reconnect customers routinely happen after hours, incurring overtime labor charges. It Update on Avista Utilities Remote Reconnect/Disconnect Summary Report February 8,20L3 Page 4 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 2, Page 4 ot 10 should also be noted that disconnect activities often take crews away from other responsibilities that are crucial to the performance of the utility, adding opportunity costs into the equation. Costs and Avoided Costs At the time of the original pilot project, the cost of a paging collar was $192 and a TWACS collar was $130, the current cost for the same collar is $162. The cost of the two-way cell phone based collar is cunently $267. For the original pilot, a blended rate of $32.50 was assumed for all calculations regarding labor savings. Labor rates have increased at3o/o annually, so the current equivalent blended rate would be $35.43. All other calculations would be increased by the same 3olo annually. Savings are highly dependent upon the mix of where devices are deployed and the amount of disconnects/reconnects that are completed after normal business hours. We would expect that savings would be similar to those experienced during the Pilot. Savings would accrue more quickly when devices are deployed in rural areas as the costs are higher in these areas due to the distances traveled and the labor force (line servicemen) that are used for collections work. The following illustration represents the avoided costs for 20ll and2012. Illustration No. I - Avoided Costs 2011 nsts Orders zCI12 Co$s Orders Total {econnects Normal .After $ 28 297 $ 8.316.00 $ 148 5r S 8"436 $ 29 202 $ 152 27 5.825.6ts$ 4.116 $ 14.141.68 s 12"551 .88 499 84 Jisconnects Normal Affer $ 28 341 $ 9.548$148 0 5 s29 $ 152 182 $ 5.2490$5ZJ $ 14,196.UU-$ $ 41..t90 44 Update on Avista Utilities Remote Reconnect/Disconnect Summary Report February 8,2073 Page 5 Exhibit No. 'l Case No. GNR-U-14-01 L. Gervais, Avista Schedule 2, Page 5 of 1 0 Updated Summary of Results For purposes of this report, Avista has included Residential Rate Schedule 001 information only. The reason the other rate schedules are not captured in this study is due to very small participation, their complexity, and the minimal amount of relevant data. An account can have multiple meters and rate schedules associated to that account; 98o/o of the participants are on residential rate schedule 001. The following data has been collected as effectively as possible: Illustration No. 2 - Total number of customers where a device was installed. Total Number of Disconnect Devices tnstalled bv Tvpe and Month Update on Avista Utilities Remote Reconnect/Disconnect Summary Report February 8,20L3 Page 6 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 2, Page 6 of 10 Illustration No. 3 - The total number of remote disconnections by disconnection (e.g., non-payment of bill or failure to pay deposit). month,and for l J#i:faE rhr!l t[t]M*'iun ;,lal 'iud !i}a:irottl ,to,'Oet iTio,Ul 2(m }ROKEN PAYMENTARRANGEMENT {ON PAYMENT EALANCE t4 18 33 IETURNED CHECK/PAYMENT 2 3 3 8 ]ALANCE&DEPOSIT 10 10 20 total 3 27 31 61 2m9 }ROKEN PAYMENT ARRANGEMENT I 7 1 {ON PAYMENTBALANCE a7 59 7a &t u 53 56 51 33 46 47 u 7tl IETURNED CHECK/PAYMENT 1 1 5 9 I 4 2 1 2 3 2 12 IAtANCE&DEPOSIT 24 t7 31 29 29 27 19 10 17 9 13 7 212 lotal 112 87 115 LZt 95 95 T7 62 52 58 63 4t 974 2010 IROKEN PAYMENT ARRANGEMENT 3 1 1 1 5 {ON PAYMENT BALANCE 42 &47 47 55 50 29 32 36 31 32 E 460 IETURNED CHECK/PAYMENT I 2 3 3 2 2 2 1 1 t7 }ALANCE&DEPOSIT 8 4 10 12 8 5 4 8 8 7 2 7 u 'otal 51 M 62 56 65 58 35 42 4 q v v 557 2011 ]ROKEN PAYMENT ARRANGEMENT 1 I 1 3 {ON PAYMENT BALANCE 26 3r 31 29 27 31 ?t 27 19 18 15 19 29tt IETURN ED CHECK/PAYMENT 1 3 3 7 lALANCE&DEPOSIT 4 8 5 2 2 2 3 2 1 2 31 Total 31 31 39 37 33 33 ?3 31 ZL 19 t7 20 335 mL2 IROKEN PAYMENTARMNGEMENT 1 ,lON PAYMENT BALANCE 19 6 13 1 15 15 15 1 1 27 11 !4 t7t IETURNED CHECK/PAYMENT 4 }ALANCE&DEPOSIT 3 'otal 20 6 14 11 t7 18 t7 L2 11 27 L2 15 180 TOTAT IROKEN PAYMENT ARRANGEMENT 3 3 1 1 1 I 2 2 t4 \lON PAYMENT BAI-ANCE t74 LM 159 LU L62 160 L22 t2r E)L23 119 110 1,569 IETURNED CHECK/PAYMENT 4 1 8 15 7 8 4 3 2 6 5 5 68 }ALANCE&DEPOSIT 36 2t 50 46 39 35 26 22 27 t7 27 24 370 lotal 214 168 2n 225 211 2U 153 r47 LzA t47 153 L4t 2.Lzt Illustration No. 4 - The length of time between remote disconnections to remote reconnections. Update on Avista Utilities Remote Reconnect/Disconnect Summary Report February 8,2013 PageT Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 2,Page7 oI 10 Illustration No. 5 - Any evidenc€ that installation of the disconnection device influenced customer behavior (positive or negative). The information provided in lllustration No. 5 represents the number of times customers kept an arrangement prior to the remote switch installation verses after the installation of the remote switch. For example:o 84 accounts kept their arrangements prior to installation of the device when compared to after installation;o 165 accounts kept their arangements after installation of the device; and. 94 accounts had no change in payment arrangement behavior. The number of arrangements made remained steady, only 7 oZ less arrangements were set up after the device was installed. The information provided in Illustration 3 on page 7 also shows a decline in the number of disconnections annually with the customers with the remote device as noted below: # of Disconnects Update on Avista Utilities Remote Reconnect/Disconnect Summary Report February 8,2073 Page B Exhibit No. 't Case No. GNR-U-14-01 L. Gervais, Avista Schedule 2, Page 8 of 10 Illustration No. 6 - Idaho collection field requests per account over a three year period and how they continue to increase. ldaho Collection Field Requests 6000 4000 2000 0 _ ....'.".!?;. .' | :t ;:: t :qr.., :.,:rl'"all I, ::..r":l liiiiil :='i+,E:}!,]ll..)r' . r::$ir:il| llh.tiif $"lN\\\NNlll#$:4$ .$M ffi##r ..: ..- t.:::._:;i: _,..t ".' ' ':,i'tl,i;;:;I irilill[il$.iNIffiMI 2 3 4 5+ r1yr 2701 1376 696 912 I2yrs 4252 2183 1270 2730 tr3yrs 5547 2842 1667 4075 Requests per Account Illustration No. 6 represents the number of accounts with more than one field request in either a 1,2, or 3 year period of time. For example: o 2,701 accounts experienced ! collection related field orders for disconnect in a 1 year period of time, 4252 accounts for a2 year period of time and 5547 accounts in a 3 year period of time. o 912 accounts experienced ! or more collection related field orders for disconnect in a I year period of time, 2730 accounts for a2 year period of time and 4075 accounts in a 3 year period of time. Conclusion Avista appreciates the opportunity to discuss any outstanding issues or concerns regarding this pilot. As stated earlier in the summary report, it is always the Company's desire to keep customers connected. The need to disconnect non-paying customers or to avoid a potential safety risk is nothing new for utilities, but the tools of today allow for more efficient handling of these arrears or unique situations. Update on Avista Utilities Remote Reconnect/Disconnect Summary Report February 8,2013 Page 9 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 2, Page I of l0 The Company believes that the remote relay switch offers a significant opportunity to positively impact utility operations and add value to customer relationships and requests a permanent waiver of IDAPA 31.21.01 (311.03) and (311.04) [Utility Customer Relation Rules] to implement a system for remote disconnection and reconnections, without the need for an employee visit to the affected premises be implemented. The Company also requests that the criteria for selection of customers be at Avista's discretion based on safety, collection activity and access to customer property with the exception of Avista CAREs customers. The Company commits to maintain its current notification process that advises customers that they have a remote device. Based on the results provided, Avista is hopeful that the Commission and concerned parties will understand the overall benefits that the service switch brings to Avista's entire customer base and support the Company's proposed outcomes. Update on Avista Utilities Remote Reconnect/Disconnect Summary Report February 8, 2013 Page 10 Exhibit No. 1 Case No. GNR-U-14-01 L. Gervais, Avista Schedule 2, Page 1 0 of 1 0