20140930White Direct.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSTON
IN THE MATTER OE THE JOINT
PETITION OF AVTSTA CORPORATION,
IDAHO POWER COMPANY, AND ROCKY
MOUNTAIN POWER COMPANY FOR AN )
EXEMPTTON FROM UTTLTTY CUSTOMER )
RELATTONS RULE 311 (4) AND (5) . )
)
CASE NO. GNR-U-14-01
IDAHO POWER COMPANY
DIRECT TEST]MONY OF TAMI WH]TE
IN SUPPORT OF JOINT PETITION
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is I22t West Idaho Street, Boise, Idaho 83702.
O. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("Idaho
Power" or "Company") as the Senior Manager of Rate Design
in the Regulatory Affaj-rs department.
Please state your name and business address.
My name is Tami V'Ihite and my business address
Please describe your educational background.
I earned a Bachelor of Business Administration
degree in Accounting from California State University,
Stanislaus. I have attended various electric utility
courses, including "El-ectric Util-ity System Operation," a
course offered through Professional Training Systems, Inc.,
and "Overview of System Operations" presented by the
Western Electricity Coordinating Council. In 2014, I
attended the Utility Executive Course at the University of
Idaho.
O. Please describe your work experience with
Idaho Power.
A. I began my employment with Idaho Power in 7999
as a Einancial Analyst in the Company's Delivery Finance
Support area where I provided accounting and financial
support services to the Delivery Business Unit. In 2005, I
was promoted to Finance Team Leader where I was responslble
for leading a group of Financial Analysts, Accountants, and
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Idaho Power Company
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Accounting Specialists in providing accounting and
f lnancj-a1 support services to the Operations Busi-ness Unit.
I was responsible for aII aspects of the monthly accounting
closing process for the Operations Business Unit and for
the monthly billing and settl-ements processes for
transmissj-on sales and purchases, wholesale energy
transactions, Public Utility Regulatory Policies Act of
1978 (PURPA) transactions, large special contracts, and
joint use transactions. Whil-e working in Operations
Einance Support, I participated in the development of the
Company's Eederal Energy Regulatory Commission (*FERC")
Open Access Transmission Tariff (*OATT") formula rate for
transmission services .
In October of 201,0, after 11 years in finance, I
accepted a position as Manager of EERC and Regional Affairs
in the Regulatory Affairs department. In this position f
was responsible for managing regulatory activities such as
the preparation and filing of Idaho Power's OATT rates for
transmission service, supervising participation and
settlement negotlations of Bonneville Power Administration
rate cases, and creating analyses that form the basis for
Idaho Power's FERC regulatory strategy.
In January of 2012, T was promoted to Senior Manager
of Rate Design. As Senior Manager of Rate Desj-gn, I
oversee the Company's rate design activities such as
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fdaho Power Company
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regul-atory ratemaking and compliance filings, tari-ff
admj-nistration, and the development of various prj-cing
strategies and policies.
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proceeding?
What is the purpose of your testimony in this
A. The purpose of my testimony is to describe
Idaho Power's request for an exemption from the provisions
of Utility Customer Rel-atj-ons Rules (*UCRR") 311 (4) and (5)
and the Company's planned efforts to inform its customers
regarding the anticipated changes if the request is
approved.
r. REQT EST FOR EXEMPETON
Pl-ease describe Idaho Power's proposal.
Idaho Power is requesting an exemption from
the requirement to have its personnel knock at the door
during a disconnection for non-payment transaction when
that location has a meter with remote connect/disconnect
capability. This change will all-ow Idaho Power to more
fuI1y utilize its metering capabilities and reduce
operating and maintenance ("O&M") costs. Idaho Power j-s
requesting an exemption from the provj-sions of UCRR 311(4)
and (5) only for locatj-ons where remote connect/disconnect
capable meters have been installed. UCRR 311(4) requires
that immediately preceding termination of service, utility
personnel must attempt to make face-to-face contact with
wHrTE, Dr 3
Idaho Power Company
1 the customer or other responsible adult on the premises to
2 accept payment on an outstanding bill. UCRR 311 (5)
3 requires the utility employee designated to terminate
4 service to notify the customer in person or with a
5 conspicuously placed notice of the procedure to reconnect
5 service. Idaho Power is requesting an order by December
7 37, 2014, with an effective date of March l, 201,5.
O. Why is Idaho Power requesting this exemption?
A. Due to advancements j-n meter technology, it is
10 now possibl-e to acquire meters with remote
11 connect/disconnect capability eliminating the need to send
72 a Company representative to a customer's location to
13 connect or disconnect service. Idaho Power identified
14 14,500 locations where it made sense, from a cost/benefit
15 perspective, to instal-I these meters. Idaho Power began
L6 install-ing these meters in April of 20L4.
L7 O. What criterion did Idaho Power use to
18 determine where remote connect/disconnect meters should be
1,9 installed?
20 A. The criterion Idaho Power used to determine
2t which locations should have remote connect/disconnect
22 metering capability was any locatlon that was field visited
23 two or more times during an approximately 18-month period
24 ending August 2073.
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WHITE, DI 4
fdaho Power Company
The reasons for the field visits were primarily due
2 to collection activity, payments collected at the door, and
3 disconnections for non-payment. These visits also included
4 customer requested connections and disconnections. After
5 these 74,500 meters are installed, Idaho Power will have
6 the capability to remotely connect/disconnect service at
7 these l-ocations and avoid the cost of sending an employee
I to the location.
O. Does Idaho Power plan to install remote
10 connect/disconnect capable meters at more locations in the
11 future?
L2 A. Idaho Power wil-I continue to look for
l-3 locations where this remote connect/disconnect metering
L4 technology provides cost reductions. This could include
15 remote locations, Iocations that are difficult to access,
L6 or where safety is a concern. These meters are being
Ll installed at residential- or small commerciaf customer sites
18 of 240 volt, single phase services that are 200 amps or
19 less.
20 O. Is Idaho Power seeking an exemption from
2L UCRR(4) and (5) for these locatj-ons?
22 A. Yes.
23 O. If Idaho Power's request for an exemption i-s
24 approved, when will it start using the remote capability of
25 these meters?
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Idaho Power Company
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A.Although Idaho Power began installing remote
connect/disconnect capable meters at select locations in
April 2074, the Company will continue to adhere to the
applicable UCRRs until such time that its request for an
exemption from the rules is granted by the Idaho Public
Utilities Commission ("Commission") .
As required by UCRR 306 (1) , Idaho Power wlII not
termj-nate service or threaten to terminate service during
the months of December through February to any residential
customer who declares that he or she is unable to pay in
full for util-ity service and whose household includes
chil-dren, elderJ-y, or infirm persons, whether they have a
remote connect/disconnect capable meter or not. Idaho
Power refers to this December through February time period
as "winter moratorium. " During winter moratorj-um, Idaho
Power plans to continue to knock on the door of all
customers (including customers with remote
connect/disconnect meters) before a disconnection for non-
palrment.
Idaho Power will continue to follow all other rules
health and safety exceptions and all- rules regardj-ng
and time restrictions on disconnecti-ons.
II. CUSTOMER IMPACT A}ID OT'ITREACB
for
day
a.
granted, how
If Idaho Power's request for exemption
will customers be impacted?
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Idaho Power Company
1 A. The primary change for customers at locations
2 where remote connect/disconnect capable meters have been
3 installed is that Idaho Power will- no longer need to visit
4 their location to connect or disconnect service and they
5 wil-l- no longer have the opportunity to pay at the door to
6 avoid a disconnection for non-payment.
1 The vast majority of Idaho Power customers rarely
8 require a site collection or disconnection visit. However,
9 some customers have repeated on-site collection and/or
10 disconnection activity. For example, 8r 105 customers (or
11 1.6 percent of the 5011104 total customers as of December
72 31, 20L2) in 2072 required Idaho Power to visit them
13 between two and eight times for col-lection and/or
!4 disconnection activity.
15 O. Will customers with remote connect/disconnect
t6 capabJ-e meters find it difficult to pay their electric bill
l7 if payment at the door at the time of dj-sconnection is
18 discontinued?
19 A. No. Idaho Power offers many ways for
20 customers to pay their biIl. Below is a table showing the
2L different methods of payment available to Idaho Power
22 customers and how many payments were received over the past
23 few years using each method. A11 customers have many
24 convenj-ent ways to pay their Idaho Power bi1l.
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WHITE, DI 7
Idaho Power Company
2010 2011 2012 2013
Drop Box 132.307 2.7Yo 127,010 2.6%'t18,0/tB 2.4o/o 136.287 2.7o/"
Postal Service (mail)2.511.676 50.7Yo 2.378.874 48.2o/o 2.232.588 M.7o/o 2.101.991 41.4o/o
Paystations 386.915 7.8o/o 364.230 7.4o/o 341.678 6.8o/o 332.525 6.5%
Prefened Pay (1)458.987 9.3o/o 475,396 9.60lo 481,999 9.6%497,621 9.8o/o
Paperless bank debiting (2)'t.11't.358 22.4%1.206.593 24.4o/o 1.243.656 24.9%1.309.184 25.8%
myAccount Bill Pay (3)24.248 O.5o/o 292.528 5.9o/o 444.808 8.8%
On-line or phone payment (4)331,209 6.7%340,727 6.9%270,000 5.4%248,169 4.9o/o
Pay at Door (5)18.170 0.4o/o 19.255 0.4o/o 17.691 0.4%11,487 0.2o/o
4.950,622 100.0olo 4.936.333 100.0%4.998.189 100.0%5.082.072 100.0%
(1) Auto bank debiting
(2) Paperless bank debiting through CheckFree or other banks or credit unions, or through vendor electronic data
interchange.
(3) Electronic bank payment through myAccount at idahopower.com.
(4) On-line or phone payment with check, debit or credit card, $2.85 fee applies to transaction.
(5) 2013 payments collected at the door reflect data through August of 2013.
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Currently, Idaho Power receives approximatel-y 40
percent of palments vj-a the postal service, while the
remaining 60 percent of payments are received through other
means. During 20L2, there were 34L,618 payments processed
by the Company's pay station network. This compares to
l7 ,691- payments coll-ected in the field during a disconnect
visit. The 71 ,691 payments taken during a disconnect visit
represent l-3, 094 customers. This means that 4,591 palrments
(26 percent) were repeat customers using the field
collector as a payment method.
O. How will customers that have remote
connect/disconnect capabl-e meters be informed of the change
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in the service disconnection process if Idaho Power's
request for exemption is granted?
A.Idaho Power wil-1 inform the customer via an
insert included in the initial disconnect notice and again
in the final di-sconnect notice. Thls insert will inform
the customer that Idaho Power will not be visiting their
location to accept payment at the door or to disconnect
service and will also incl-ude information about how the
customer can make payments, how they can avoid service
disconnectj-ons, and where they may apply for energy
assistance. The insert will also provide information on
the steps the customer can take to have service reconnected
should servi-ce be disconnected.
0.Does Idaho Power believe an insert in the
disconnection notice is adequate communication to customers
with remote connect/disconnect meters?
A.Yes. Providing detailed information at the
time the customer is facing a potential service
disconnection makes the information timely and pertinent.
In additj-on, providing the detail-ed information to only
those customers whose behavior triggers a service
termination event avoids confusion or possible upset for
those customers who have the remote connect/disconnect
meters but for whom the technology wiJ-I not be used for
invo1untary service disconnections. Because Idaho Power 1s
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Idaho Power Company
1 instalting remote connect/disconnect meters in only a smal1
2 portion of its customer locations, a broader educational
3 campa j-gn does not seem appropriate.
O. Is Idaho Power proposing to change its current
5 service disconnection practices for customers that do not
6 have remote connect/disconnect capable meters?
A. No. Idaho Power proposes to continue knocking
I and offering to take payment before disconnectj-on for al1
9 service points that do not have remote connect/disconnect
10 capable meters.
11 O. Why is Idaho Power proposing to continue
1-2 knocking on the door for these customers?
13 A. Locations without remote connect/disconnect
14 meters wiII stil-I need to be visited by an Idaho Power
15 representative to connect or disconnect service. Because
L6 customers that do not have remote connect/disconnect
l1 capable meters have less on-site collectlon activity and
18 are l-ess likely to expect field personnel on their
19 property, Idaho Power plans to continue knocking on the
20 doors of these customers so as to avoid startling occupants
27 whil-e crossing the property to the meter.
22 III. STAKEEOLDER OUTREACE
23 O. Has fdaho Power consulted with any of its
24 stakeholders regarding this proposal?
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fdaho Power Company
1 A. Yes. On trlednesday, April 23, 201,4 and again
2 on Tuesday, August 29, 20L4 representatives from Idaho
3 Power's Regulatory Affairs department met with Commission
4 staff to dj-scuss its proposal.
5 On Monday, September 22, 2074 representatives from
6 Idaho Power's Regulatory Affairs department and Customer
7 Relations department visited with the executive director of
8 the Community Action Partnership of Idaho (*CAPAI") to
9 discuss its proposal. Additionally, on Tuesday, September
10 30, 2074 representatives from Idaho Power's Regulatory
11 Affairs department and Customer Relations department
72 visited with the executive council volunteer and the
13 dlrector of advocacy of AARP, Idaho to discuss i-ts
L4 proposal.
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rV. BEIIEFITS ATID REDUCED CHARGES
O. What benefits will be derived if Idaho Power/ s
l7 request for exemptj-on j-s granted?
18 A. There are many benefits of the remote
79 connect/disconnect meter technology, both for customers who
20 have these meters and those who do not. The primary
2L benefj-t for both the Company and its customers of
22 implementing this remote connect/disconnect meter
23 technology is estimated reduced O&M costs of approximately
24 $700,000 per year. This reduction comes from the
25 eIj-mination, through attrition, of seven meter specialist
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Idaho Power Company
1 positions - which is 24 percent of the total number of
2 meter specialist positions. This savings includes labor,
3 overtime, and benefits costs. It is expected that 36
4 percent of total- on-site collection and
5 connection/disconnection activity will be eliminated by
6 this proposal.
O. What costs will- be incurred if Idaho Power's
8 request for exemption is granted?
A. In order to install the 14,500 remote
10 connect/disconnect capable meters, Idaho Power will incur a
11 one-time capital expense of $2.7 million and will return to
L2 inventory and re-use meters valued at $855,500.
13 Idaho Power purchased the remote connect/disconnect
74 capable meters in late 2013 to take advantage of a discount
15 price offer. Idaho Power wil-I use the meters that are
76 removed in this process for new customer instal-Iations or
11 for maintenance replacement meters.
18 O. Are there other benefits to customers
19 generally?
20 A. Yes. Because there will be fewer meter
2l specialists needed in the fieJ-d, there will- be fewer
22 vehicles required and fewer miles driven. In addition to
23 the O&M savings identified above, implementing Idaho
24 Power's proposal will- result in fewer vehicles on the road,
25 thus reducing vehicle expenses and emissions.
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o.How do customers who have remote
connect/disconnect capable meters benefit?
A.Eor those customers who are facing a
disconnection for non-payment, the new process will be more
predictable and tj-mely because the customer will know
precisely what day their service is subject to
disconnectj-on and wiII not have to guess when the Idaho
Power field personnel will arrive. Unlike on-site manual
service disconnections, service disconnection at locations
where the meter has remote connect/disconnect capability
will- be on a specif ic schedul-e. Idaho Power plans to
schedule remote disconnections for non-payment early in the
day so that customers will have time to make payment
arrangements in order to have their power turned back on in
the same day in most cases. Predictabil-ity of disconnects
and reconnects will resu1t in a more consistent process
that can help customers more easily manage these
situations.
Additionally, the remote connect/disconnect meter
has the ability to reconnect service much quicker once
payment is received. Idaho Power anticipates that
customers with remote reconnect technology will experience
reconnection within minutes rather than the hour(s)
sometimes required for a crew to travel to customers'
premises and manually reconnect them.
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Idaho Power Company
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Because Idaho Power personnel will no longer be
required to visit the premi-ses to connect or disconnect
service, customers are afforded more privacy in their homes
and back yards where the meters are typically J-ocated.
Residential and Small General Service customers who
in the past have paid at the door have been subject to a
520 Eiel-d Vlsit Charge which is incurred when Idaho Power
travels to the customer premises to collect payment or to
disconnect service. Because this option wj-11 no longer be
avaj-Iable, customers will not incur this fee. This Field
Visit Charge is reflected on ldaho Power's Schedule 66.
0.What are the current Service Connection
Charges a Residential or Sma1l General Service customer
pays when Idaho Power travels to the customer premises to
reconnect the service?
A.When Idaho Power sends personnel to reconnect
service at the customer's location, the customer is subject
to a Service Connection Charge that varies by the time of
day and day of week the reconnection 1s made. These
charges are refl-ected on Idaho Power's Schedul-e 66 and are
shown below:
Service Connection Charge for Schedules 1, 3, 4, 5, 7, 9
Monday-Friday 7:30 am to 6:00 pm
6:01 pm to 9:00 pm
9:01 pm to 7229 am
Company Holidays and Weekends
7:30 am to 9:00 pm
9:01 pm to 7229 am
$20
$4s
$80
$4s
$80
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Idaho Power Company
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these fees?
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V'lhat is ldaho Power's proposal concernlng
For Residential and Smal-I General Servi-ce
customers with remote connect,/disconnect capable meters,
Idaho Power proposes to reduce the Service Connecti-on
charge to $13 for a1l hours of the day and all days of the
week because Idaho Power will not incur additional costs to
reconnect customers durj-ng non-business hours. The reduced
Service Connectj-on charge for customers with remote
connect/disconnect capable meters represents the costs of
back office operations necessary to reconnect and re-
establish service, but does not incl-ude any field visit
costs.
v.
O. By what date
CONCLUSION
does Idaho Power request an
order?
A.Idaho Power is requesting an order by December
31, 2014, for the exemption to become effective March 7,
20L5. The December 31st date will give the Company time to
prepare and implement the communication plan and to make
any modj-fications in technology systems needed for
implementation.
Does this concl-ude your testimony?
Yes it does.
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Idaho Power Company
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,lr/'Lv Tami lrlhite
SV{ORN to before me this 30th day of
ATTESEATION OE TESIII@NY
STATE OF IDAHO )
) ss.
County of Ada )
T, Tami White, having been duly sworn to testify
truthfully, and based upon my personal knowledge, state the
following:
I am employed by Idaho Power Company as a Senior
Manager in the Regulatory Affairs department and am
competent to be a witness in this proceeding.
I declare under penalty of perjury of the laws of
the state of Idaho that the foregoing pre-fi1ed testimony
and exhibit are true and correct to the best of my
i-nformation and belief .
DATED this 30th day of September, 20L4
SUBSCRIBED AND
September, 2014.
wHrTE, Dr 16
Idaho Power Company
NotAry eqfrfllc for Ida.hon."iai,s Y, S+^,. ,aA.ol.-oMy commission expires z l> )0 -Aotf