20141217Reply Comments.pdf

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LISA D. NORDSTROM ,..i,,i. , i ;.
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December 17,2014
VIA HAND DELIVERY
Jean D. Jewel!, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. GNR-U-14-01
Exemption from UCRR 311 - ldaho Power Company's Reply Comments
Dear Ms. Jewell:
Enclosed for filing in the above matter are an origina! and seven (7) copies of ldaho
Power Company's Reply Comments.
Sincerely,
3;a@
Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ idahopower. co m
Attorney for ldaho Power Company
IN THE MATTER OF THE JOINT
PETITION OF AVISTA CORPORATION,
IDAHO POWER COMPANY AND
ROCKY MOUNTAIN POWER COMPANY
FOR AN EXEMPTION FROM UTILITY
cusToMER RELATIONS RULE 311(4)
and (5).
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR.U.14-01
IDAHO POWER COMPANY'S
REPLY COMMENTS
On September 30, 2014, Avista Corporation ("Avista"), ldaho Power Company
("!daho Powe/' or "Company"), and PacifiCorp dba Rocky Mountain Power ("PacifiCorp"
or "Rocky Mountain Powe/') (collectively referred to as the "Utilities" or "Petitioners")
petitioned the ldaho Public Utilities Commission ("Commission") to issue an order on or
before December 31, 2014, exempting the Utilities from the provisions of Utility
Customer Relations Rule ("UCRR') 31 1 (4) and (5) effective March 1, 2015 ("Joint
Petition"). In its Notice of Petition and Modified Procedure Order issued on October 23,
2014, the Commission established a procedural schedule to review the Joint Petition.
Order No. 33157. Commission Staff ("Staff') held a public workshop on November 21,
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
2014, to provide customers with an overview of the Joint Petition, dispense information,
and provide a forum for interested persons to ask questions of the Utilities. Staff and
the Community Action Partnership Association of ldaho ("CAPAI") subsequently filed
comments on December 10, 2014.
ldaho Power appreciates Staffs support for Commission approval of the
requested exemption and Staffs recognition that the requested change in collection
practice will reduce upward rate pressure for all customers. Staff Comments at 13 and
4. ln these Reply Comments, ldaho Power responds to Staff recommendations
regarding how to best implement the change in utility practices as we!! as CAPAI's
suggestion that the Commission deny the Joint Petition. CAPAI Comments at 9.
I. WRITTEN CUSTOMER COMMUNICATIONS
Staff believes that if an exemption is granted, the Utilities should undertake an
effective customer-communication campaign that would inform customers about
available payment options, 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. Staff Comments at 7. Idaho Power agrees with Staff that it is
important to inform customers about changes to its collection practices and that
Company representatives wil! no longer visit their location to attempt to collect payment
on a past due balance or accept payments at the door to prevent disconnection.
To accomplish this in the most effective way, ldaho Power proposes to send a
letter via direct U.S. Mail to its approximately 14,000 residential customers with remote
connecUdisconnect meters. The letter will highlight the fact that a Company
representative will no longer be visiting the customeds location to attempt to collect
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
payment on a past due balance or accepting payments at the door to avoid a
disconnection. The letter will also point out that there are multiple other convenient
ways to make payments and that it will be advantageous for the customer to utilize the
payment option that best meets their needs. Customer feedback and questions will be
encouraged by offering customers options to comment or ask questions by calling ldaho
Poweds customer service center, sending an email, or sending a letter via U.S. Mail.
ldaho Powe/s contact information will be provided in the letter. Additionally, in this
letter ldaho Power will inform customers of their rights under UCRR 307 to designate a
third party who must be given notice as suggested by CAPA!. CAPAI Comments at 9-
10.
For the Company's approximately 500 non-residential customers with remote
connecUdisconnect meters, Staff recommends that the Company make persona!
contact with these customers either in person or by phone to advise the customer of the
change in collection practice and advise these customers about steps they should take
to protect their employees and customers in the event of disconnection. Staff
Comments at 9.
ldaho Power agrees that it is important to notify these customers about the
change in collection practices. However, in order to provide the best possible service
and ensure customer satisfaction, the Company recommends communicating this
change to non-residential customers via direct mail letters in a manner similar to that
proposed for residential customers. Because non-residential customers can and do
have numerous stakeholders, some stakeholders may not be aware of the credit profile
of the premises owner/utility customer. Stakeholders who are aware that a Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
representative is visiting an establishment to discuss changes in ldaho Powe/s
collection practices may draw conclusions that the premises owner/utility customer will
not appreciate. Similar to an in-person visit, a phone call would pose similar challenges
of communicating the information to the appropriate person and only that person.
Recognizing that this could be a sensitive situation for the customer, the Company
recommends sending a letter to all affected non-residential customers rather than
personally contacting them as Staff suggests. The Company believes that this
approach yields the highest probability of promptly getting the information to the correct
person in a confidential manner.
With regard to the suggestion on page 9 of Staffs Comments that the Company
"advise customers to take any necessary steps to protect its customers and employees
if disconnection is unavoidable," ldaho Power does not believe that it is appropriate for
utilities to offer this type of advice. Disconnection for non-payment is no more or less of
a potentia! safety concern than an unexpected, unplanned outage. Not only is the
Company concerned that this may be perceived by non-residential customers as
presumptuous and/or meddlesome, the utility may be unnecessarily exposed to lawsuits
if such counsel is subsequently construed as having provided legal advice.
II. UCRR CUSTOMER NOTIFICATIONS
To more completely satisfy the customer notification requirements of UCRR
304.02, Staff recommends that Idaho 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 connecUdisconnect
meters. Staff Comments at 8.
IDAHO POWER COMPANY'S REPLY COMMENTS.4
ldaho Power believes it is fully complying with UCRR 304.02's requirement to
diligently attempt to contact the customer by placing a phone call at least 24-hours
before the proposed termination of service. While the Company does not believe that it
is necessary to increase the number of phone calls for customers at a service address
where a remote connecUdisconnect meter is installed as recommended by Staff, the
Company agrees to increase the frequency of phone call attempts for this subset of
customers as a way to compensate for no longer knocking on the door prior to service
disconnection.
As stated on page 9 of the testimony of Tami White, all ldaho Power customers
with remote connecUdisconnect meters installed at their service location will have a
special insert included in both the initial reminder notice (seven days prior to disconnect)
and fina! disconnection notice (three days prior to disconnect) informing them that an
ldaho Power representative will not be visiting their location to attempt to collect
payment, accept payment at the door, or to disconnect service. The insert will also
include information about how the customer can make payments, avoid service
disconnection, and apply for energy assistance.
ldaho Power will also describe in these disconnect notices how customers may
make a third-party designation under UCRR 307, which ldaho Power also does in its
annual ldaho Residential Consumer lnformation brochure. Once a third party is
designated, ldaho Power mails third-party notices at least seven calendar days before
the proposed disconnection. To avoid confusing the majority of customers whose
accounts are not past due or are taking service at a location where a remote
connecUdisconnect meter is not installed, ldaho Power believes it is appropriate to
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
include this information in the initial reminder and final disconnect notices rather than
notifying al! customers as suggested by CAPAI on page 9 of its Comments.
III. CUSTOMER SERVICE CENTER INTERACTION
AND EMPLOYEE TRAINING
Staff recommends on pages 10 and 11 of its Comments that, prior to
implementation, ldaho Power be directed to implement a customer-education campaign
for customers with remote connecUdisconnect meters like that proposed by Rocky
Mountain Power and submit those plans to the Commission within 14 days after
issuance of the Commission's order. Staff suggest that, at a minimum, each utility
must:
o Provide field personnel and customer service representatives with additional
training for handling customer questions and concerns;
o Prior to implementation and for at least one (1) year thereafter, do the
following:
o 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;
o lnclude a message regarding the change in utility practices in customers'
bills with past due account balances on the initial past due notice and the
final disconnection notice; and
o lnform customers of the change in utility practices when contacting a
customer by phone prior to disconnection.
lf the Commission approves the requested exemption, ldaho Power fully intends
to provide education and training to field personnel and customer service
representatives regarding the change in collection practices and how to handle
customer questions and concerns. However, the Company is concerned that providing
information regarding the change in collection practices each and every time a customer
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
with a remote connecudisconnect meter contacts the Company about their account, or
whenever the Company contacts the customer about a pending disconnection, will be
perceived as redundant, annoying, and perhaps even harassing. ln addition, this
discussion will add to the length of the phone call - increasing costs to the Company
(and therefore all customers) and further exacerbating customer frustration.
ldaho Power believes a message regarding the change in collection practices on
custome/s bills with past due account balances is not necessary. The direct-mailed
letter that will be sent to all customers with remote connecUdisconnect meters installed
at their service location, coupled with the special insert to be included in the initial
reminder notice and the final disconnect notice for customers who have a remote
connecUdisconnect meter, adequately and appropriately inform customers that they
have a remote connecUdisconnect meter installed and that a Company representative
will not visit their location or knock on the door prior to service disconnection.
ln the event the Commission approves the requested exemption and directs
ldaho Power to submit a detailed employee training and customer education plan, ldaho
Power respectfully requests that these plans be submitted to the Commission within 30
days of the Commission order rather than the 14 days suggested by Staff to provide the
Company with adequate time to develop and file its plans.
IV. BENEFITS TO CUSTOMERS
Throughout 2014, ldaho Power installed approximately 14,500 meters with
automated electric service connecUdisconnect functionality at selected service
locations. Although this represents less than 3 percent of ldaho Power customers, due
to multiple field visits each year, these locations account for approximately 40 percent of
IDAHO POWER COMPANY'S REPLY COMMENTS - 7
total field visits for disconnections. ldaho Power estimates these one-time installations
cost approximately $1 million, but will result in a reduction in its operating expenses of
approximately $700,000, annually, through reductions in metering Iabor and
transportation costs.
lf the Company's request is approved, this annua! cost savings is significant,
straightforward and easily understood. Because the current field visit charge was
established in 2004 and does not reflect the actual cost of performing this work, the
difference in cost is borne by other customers. These cost savings will be realized for
ldaho Power customers in the next general rate case where rates are updated. ln the
meantime, ldaho Power customers will realize the benefit of lower costs through the
revenue sharing arrangement approved by the Commission in Order No. 33149 in Case
No. IPC-E-14-14. ln light of these financial benefits and those enumerated on page 6 of
Staff's Comments, ldaho Power struggles to understand why CAPAI believes that an
exemption from UCRR 311 (4) and (5) is of questionable benefit to ldaho Power
customers. CAPAI Comments at 6.
ldaho Power is also perplexed by CAPAI's statement that "the Joint Petition is
simply premature and should be considered only when facts justify it." CAPAI
Comments at 9. Despite its initial support of the eight-year Avista pilot program that
deployed approximately 645 remote connecUdisconnect meter collars and by all
indications is a success, CAPAI now appears to have had a significant change of heart.
CAPAI previously filed comments on May 5, 2008, in Case No. AVU-E-07-09 in which it
stated "AVISTA has adequately addressed its concerns and no longer opposes the Pilot
Program." lt further commended Avista for its willingness to engage in a constructive
IDAHO POWER COMPANY'S REPLY COMMENTS - 8
dialogue and work cooperatively with concemed parties. ldaho Power representatives
mirrored Avista's approach when they met with CAPAI's Executive Director on
September 22, 2014, to explain ldaho Powe/s portion of the Joint Petition. ldaho
Power received no indication that CAPAI objected to its proposal or that it had specific
issues it wished ldaho Power to address prospectively.
V. LOW INCOME CUSTOMER CONCERNS
ldaho Power disagrees with characterizations and conclusions contained in
CAPAI's assertion that "ldaho Power specifically targeted customers with higher field
visit trips for the purpose of disconnection, and given that the reason for these field
visits is most often non-payment, it is intuitive that the customers most likely affected by
the Joint Petition will be low income." CAPAI Comments at 2.
First, ldaho Power does not "target customers." ldaho Power objectively
identified locations where remote connecUdisconnect meters could be best deployed to
speed up reconnection and at the same time decrease costs borne by the resident and
all customers. The remote connecUdisconnect meters are location-specific and will not
be relocated if the occupant moves to a different location. ldaho Power appreciates
Staff's concurrence that it is reasonable to strategically place remote
connecUdisconnect meters at locations that meet the screening criteria. Staff
Comments at 4.
Second, it is wrong to intuit that locations with these meters serve low income
customers. CAPAI Comments at 2. Although ldaho Power does not track or maintain
information related to customer income, the Company notes that only 8 percent of the
12,743 remote connecUdisconnect meters installed as of November 4, 2014, are at
IDAHO POWER COMPANY'S REPLY COMMENTS - 9
locations where the current customer of record received at least one Low lncome Home
Energy Assistance Program payment during the 201 3-2014 heating season.
ldaho Power likewise disagrees with CAPAI's claim that the actions proposed in
the Joint Petition are "discriminatory in nature" and "unlawful" under "ldaho Code 61-301
and 1315." CAPAI Comments at 2. With regard to ldaho Code S 61-301, CAPAI does
not elaborate on which charge for electric service it believes is not 'Just and
reasonable." The only charge ldaho Power proposes to modify is its reconnection
charge, which Avista reduced from $20 to $12 and which ldaho Power proposes to
reduce from $20 to $13 for reconnection of customers with remote connecUdisconnect
meters. ldaho Power's proposal to reduce the reconnection charge for those customers
with a remote connecUdisconnect meter is based on its actual cost to perform that
function.
ldaho Code S 61-315 prohibits utilities from granting any preference or
disadvantage to any corporation or person as to "rates, charges, seryice, facilities or in
any other respect." ldaho Powe/s request for exemption from UCRR 311 (4) and (5) is
an attempt to reduce costs paid by all its customers - those with the remote
connecUdisconnect meters and those without. For customers facing disconnection of
service, a trade off exists between an expensive opportunity to pay at the door at the
time of disconnection and faster reconnection with less expensive reconnection fees.
However, ldaho Power does not believe that this amounts to a "preference" or a
"disadvantage" under ldaho Code S 61-305. ln the eight years Avista has operated its
remote connecUdisconnect pilot program, it has not received any complaints from
customers believing they have been disadvantaged. The vast majority of customers
IDAHO POWER COMPANY'S REPLY COMMENTS. 1O
who pay their bill on time and reside continuously in the same Iocation are indifferent to
which type of meter is installed at their premises. Although the Commission has
previously permitted a partial rollout of remote connecUdisconnect meters and
presumably did not believe it to be discriminatory, the Commission is empowered by
ldaho Code S 61-315 "to determine any question of fact arising under this section."
ldaho Power is sensitive to the needs of its more vulnerable customers. ldaho
Power operates a Gatekeeper Program year-round through which Company employees
connect customers with social service programs in the communities it serves. ldaho
Power customer-facing employees are trained in the Gatekeeper Program in order to
detect when customers identified as low income or senior citizens may be in need of
assistance and to refer the situation to an appropriate assistance provider. ldaho Power
customer service representatives also refer customers to statewide community
information and referral services such as the ldaho Care Line and Oregon SafeNet.
Customers living on a thin margin usually are connected with Community Action
Partnership agencies, food banks, churches, senior centers, etc. These social service
providers likewise have personnel who are trained to assist these customers.
VI. CUSTOMER PAYMENT OPTIONS
CAPAI claims that payment at the door is their only viable opportunity for some
customers to pay their past due balance and avoid disconnection. CAPAI Comments at
5. ldaho Power does not believe that UCRR 311 (4) and (5) are intended to provide a
regular payment option for customers, and less than 0.5 percent of all ldaho Power
customers use it as such. Direct Testimony of Tami White at 8. Idaho Power believes
and Staff agrees that there are many other payment options available to customers,
each of which provides better assurance that service will not be disconnected. Staff
IDAHO POWER COMPANY'S REPLY COMMENTS - 11
Comments at 7. ldaho Power has approximately 60 pay stations available at locations
specifically chosen to provide convenience for customers. As described in the Joint
Petition and the Direct Testimony of Tami White, customers have many payment
options and many of those are offered with no fees.
CAPAI suggests that the Petitioners should provide written verification to the
Commission that its pay stations will have the capability to transmit payment data to the
utility instantaneously. CAPAI Comments at 10. Idaho Power provides authorized pay
station services for its customers under a contract with Western Union. Under the terms
of the contract, payment information is transmitted to the Company daily. ldaho Power
is not aware of any service provider that can provide instantaneous transmittal of
payment data as requested by CAPAI.
VII. REPORTING AND ADDITIONAL PROCEEDINGS
On page 9 of its Comments, CAPAI requests that the Petitioners be directed to
file a monthly report with the Commission and all interested persons containing
information about its low income customers. ldaho Power is willing to provide data
similar to that requested by CAPAI on a monthly basis and proposes to do so for one
year following implementation of the change in collection practices. Because the
monthly report would contain interim non-quarterly financial and energy sales
information that is not released monthly in a Securities and Exchange Commission filing
or other means of broad public distribution, ldaho Power requests that CAPAI and other
parties sign a nondisclosure agreement prior to receiving the report.
Despite the lack of customer complaints related to similar endeavors in Avista's
eight-year pilot program and the four other states where PacifiCorp has ceased making
in-person contact to attempt to collect on a past-due bill, CAPAI proposes that "one year
IDAHO POWER COMPANY'S REPLY COMMENTS - 12
after suspension of Rule 311, a proceeding be initiated for the purpose of ascertaining
the impact, both positive and negative, that the rule suspension has had on customers."
CAPAI Comments at 10. Rather than assume that customers will be negatively
impacted by the proposed change in utility practices, ldaho Power believes it would be a
better use of Commission and utility resources to initiate a future proceeding only if
action is necessary to resolve unforeseen issues.
VIII. CONCLUSION
ldaho Power continues to look for opportunities like the proposed remote
connecUdisconnect meter project to reduce costs paid by all customers and increase
customer satisfaction. ln addition to decreasing ldaho Powe/s annual operating
expenses by approximately $700,000, customers with remote connecUdisconnect
meters will enjoy faster and more predictable reconnection of seryice, and reduced
reconnection fees.
In response to the concems expressed and recommendations proposed by the
Staff and CAPAI in their respective comments filed on December 10, 2014, ldaho
Power commits to:
. Send a letter to residential and non-residential customers with a remote
connecUdisconnect meter providing information concerning the change in
co!lection practices;
o lncrease the frequency of notification attempts through outbound calling for
customers who have a remote connecUdisconnect meter and who are in the
process of disconnection for non-payment;
. Provide monthly reporting for a one-year period containing low income
customer data to be sent to parties that sign a nondisclosure agreement; and
. Submit a customer education and employee training plan within 30 days of
receiving the Commission's order granting the exemption, if the Commission
so desires.
IDAHO POWER COMPANY'S REPLY COMMENTS - 13
Because it wil! take additiona! time to program ldaho Powe/s systems, train
employees, and communicate with customers, ldaho Power will not be able to achieve
the March 1, 2015, effective date requested in the Joint Petition. Therefore, ldaho
Power respectfully requests that the Commission issue an order by January 31, 2015,
exempting the Company from provisions of UCRR 311(4) and (5) effective May 1 ,2015,
or the date ldaho Power can satisfy the commitments outlined above, whichever is later.
Respectfully submitted this 17th day of December 2014.
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of December 2014 ! served a true and
correct copy of the IDAHO POWER'S REPLY COMMENTS upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff X Hand Delivered
Karl T. Klein _U.S. Mail
Deputy Attomey General _Overnight Mail
ldaho Public Utilities Commission FAX
4T2WestWashington (83702) X Email [e-mail]
P.O. Box 83720
Boise, ldaho 83720-007 4
Rocky Mountain Power
Daniel E. Solander
Ted Weston Overnight Mail
201 South Main Street, Suite 2300 _FAX
Salt Lake City, Utah 84111
Barbara Coughlin
PacifiCorp
825 NE Multnomah, Suite 800
Portland, Oregon 97323
Avista Gorporation
David J. Meyer
_Hand DeliveredX U.S. Mai!
X Email [e-mail]
ted .weston@ pacificorp. com
_Hand DeliveredX U.S. Mail
Overnight Mai!
FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
1411 East Mission Avenue-- MSC-23 _Overnight Mail
P.O. Box 3727 _FAX
Spokane, Washington99202 X Email [e-mail]
Linda Gervais _Hand Delivered
1411 East Mission Avenue-- MSC-23 X U.S. Mail
P.O. Box 3727 Overnight Mail
Spokane, Washington992O2 _FAXX Email [e-mail]
IDAHO POWER COMPANY'S REPLY COMMENTS - 15
CAPAI
Brad M. Purdy
2019 N. 17th Str.
Boise, ldaho 83702
Christina Zamora
3350 West Americana Terrace, # 360
Boise, ldaho 83706
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
Hand DeliveredX U.S. Mail
Overnight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S REPLY COMMENTS - 16